Privacy Policy

Thank you for your interest in MOIA. Here we would like to inform you about how we handle your personal data. Protecting your privacy is very important to us. Your personal data is only processed in accordance with data protection regulations.

This privacy policy applies to all websites and apps provided by MOIA that refer to this policy.

Overview:

Section A: General provisions

Section B: Use of MOIA Websites

Section C: Use of MOIA App and MOIA Mobility Services

 

 

Section A – GENERAL PROVISIONS


A.1. What is personal data?

Your personal data includes any information that can be associated with you as a natural person. Such details include your name, e-mail address, mobile number, location, and payment information.
 

A.2. Who is responsible for processing data?

The responsible party (“Data Controller”) for the processing of your personal data in connection with the use of our websites and apps, unless otherwise stated below, is MOIA GmbH, Alexanderufer 5, 10117 Berlin, Germany, registered with the commercial register of the Berlin Charlottenburg District Court, no. HRB 189716 B (“MOIA”, “we”, “us”).

If there are links to third-party websites, the respective provider is responsible for data processing in connection with use of the linked website.
 

A.3. Purposes and legal basis of data processing

We process personal data for the following purposes and on the legal basis explained below.

Providing services: First and foremost, we process your data in order to provide the services you use and, where applicable, to charge for this (e.g. creating a user account, booking of MOIA Mobility Services). The legal basis for processing data in this context is the necessity for the performance of a contract with MOIA (article 6 (1)(b) GDPR) and/or legitimate interests pursued by us (article 6(1)(f) GDPR).

Legal obligations: We process personal data if and to the extent necessary to fulfill our legal obligations (e.g. retention requirements under tax law) (article 6(1)(c) GDPR).

Compliance with the MOIA Code of Conduct and enforcement of legal claims: We also process personal data if this is necessary to assert financial or other legal claims, or to investigate violations of the MOIA Code of Conduct and to be in a position to take action based on this document (e.g. instances of vandalism). The legal basis for processing data in these cases is the necessity for the performance of a contract with MOIA (article 6(1)(b) GDPR) and/or legitimate interests pursued by us (article 6(1)(f) GDPR).

System security and crime prevention: Another purpose of data processing is to ensure the security of our systems and, for instance, to prevent and detect fraud and other crimes. For this purpose, we store information such as your IP address when you register or book fee-based services. The legal basis for data processing in this context is the protection of MOIA’s legitimate interests (article 6(1) GDPR).

Improving our services: We are constantly working to enhance our services. For this purpose, we use anonymized data if possible. The legal basis for data processing here is the protection of MOIA’s legitimate interests (article 6(1) GDPR).

Marketing: We pursue the purpose of successfully marketing our services. That is why we, for example, provide optional personalized e-mail marketing to our users and measure the success of our online campaigns. The legal basis for processing personal data for marketing purposes is the user’s consent (article 6(1)(a) GDPR) and/or the legitimate interests pursued by MOIA (article 6(1)(f) GDPR).
 

A.4. Data transfers and transmitting data to third countries

We use various services that process data on our behalf (e.g. website hosting, email delivery, customer service). Each service provider is checked by us and guarantees an adequate level of data protection. 

In some cases, data may be transferred to countries outside the European Union or the European Economic Area. In such cases, suitable safeguards are in place to ensure an adequate level of protection of personal data for the natural persons concerned. 

We share information with affiliated companies and third parties if this is necessary to provide our services or to protect legitimate interests (e.g. if a MOIA Mobility Service is provided by a Cooperation Partner or if you book a MOIA Mobility Service through a third-party platform).
 

A.5. Contact and feedback

If you contact us, for instance to submit a request or to provide feedback, we will store this information to process your request or respond to the feedback. We will contact you about your request or feedback if this is necessary to clarify matters.

If you submit feedback on a MOIA Mobility Service, no personal data will be passed on to the driver.
 

A.6. Application at MOIA

If you would like apply for a job at MOIA, you can find information about data protection with regard to your application on our application portal.


A.7. Data deletion

We either delete or anonymize personal data as soon as it is no longer necessary to store it for the purposes of providing our services, protecting our legitimate interests, or complying with statutory retention periods. In the case of anonymization, all information that would make it possible to identify a specific natural person are rendered unrecognizable.


A.8. Rights of the data subject

You have the right to receive information about the personal data we hold about you. In addition, you are entitled to request that your data be corrected or deleted and/or transferred, to object to data processing, to withdraw any consent previously granted, and/or to complain to a data protection supervisory authority. 

You may contact our data protection officer at any time to assert your rights as a data subject or to inquire about data protection. The data protection officer can be contacted by e-mail:
datarequest@moia.io 
or by mail: 
MOIA GmbH
-Data Protection Officer-
Alexanderufer 5
10117 Berlin, Germany


A.9. Security

We keep your data secure using appropriate technical and organizational measures. Information that is transferred via our websites and apps is always encrypted.


A.10. Privacy Policy updates

We reserve the right to update this Privacy Policy from time to time. If there are any fundamental changes, we shall inform the MOIA App users about the update.
 

Part B – USE OF MOIA WEBSITES


B.1. Visiting our website

When you visit our website, the browser you use automatically sends a range of information to our servers. This includes your operating system, browser, and screen resolution settings as well as the date and time of your visit. Transferring this data is necessary in order to display the website content properly in your browser. This information is not associated with a specific natural person. 
 

B.2. Cookies, tracking and map content from external providers

To make our websites more user-friendly and to evaluate the interest in our products, we use cookies and similar technology that helps us to track, for example, how long users spend looking at certain content. This information is not associated with a specific natural person.

Detailed information about the use of cookies and similar technology as well as how to disable the relevant settings can be found in our Cookie Policy.

We use the following services for support:


B.2.1 Google Analytics

We use Google Analytics on our website. This is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). By using Google Analytics, we are able to understand usage behavior on our website. For this purpose, user profiles may be created with a pseudonym. These user profiles are not associated with a specific natural person.

As a rule, Google will anonymize your IP address when you use our website if you are inside a member state of the European Union or the European Economic Area. In exceptional cases, the IP address may be sent to a server in the United States, where it is then made anonymous.

You can deactivate Google Analytics by making the appropriate settings on your browser or by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en


Alternatively, you can click here to save a cookie that will prevent your data from being collected when you access this website in the future.

More information about Google Analytics and data usage by Google can be found here:

https://www.google.com/analytics/terms/us.html and https://policies.google.com/privacy?hl=en.


B.2.2 Facebook Pixel and Facebook Custom Audiences

On our website we use both the Facebook Pixel and Facebook Custom Audiences retargeting (also in the Pixel mode). These services are provided by Facebook Inc., 1 Hacker Way, Menlo Park, California, USA and Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). A pixel is placed on our website that establishes a connection to Facebook servers when you visit the website. In this way, Facebook learns that you have visited our website and may associate this information to your personal Facebook profile. We use the Facebook Pixel to determine how effective our advertising on Facebook is. We use Facebook Custom Audiences in order to display advertising to our website visitors on Facebook that reflects their interests. For more information on how Facebook collects and processes data, please visit: https://www.facebook.com/about/privacy/.

You can opt-out of interest-based advertising on Facebook by adjusting your settings here: https://www.facebook.com/settings/?tab=ads#_=_.

Additionally, you can store an opt-out cookie by clicking here. This prevents data from being sent to Facebook when you access this website.


B.2.3 Google Maps

On our website, we use Google Maps so that you can access interactive maps. We use this feature to present our service area on a map, for example. Location data that is sent to Google is always made anonymous.

For more information about how Google processes data, see: https://www.google.com/policies/privacy/. You can find Google’s privacy policy on this page: https://policies.google.com/terms?hl=en.

 
B.3. Downloading the MOIA App from a download link

You have the option of requesting to download the MOIA App on our website. To do so, you need to enter your mobile number. We can then send the download link directly to your mobile device. Your mobile number will be deleted immediately as soon as the download link has been sent and will not be used for any other purpose.


B.4. MOIA NEWS

If you subscribe to our marketing e-mails on one of our websites, we will send you information about vouchers, offers, products, and surveys by e-mail from time to time. You may revoke your consent to this at any time. To do so, select the unsubscribe link contained in each e-mail we send out or send an e-mail to datarequest@moia.io. In order to measure success of our marketing e-mails, we automatically save information about openings and clicks as well as the type of device used to access e-mails.
 

PART C – USE OF MOIA APP AND MOIA MOBILITY SERVICES


C.1. Registration

When registering to use our MOIA App, you enter your login details. We use this information to set up your user account. Fields are marked as optional if the respective information is not required for registration.

If you have added a photo to your user account, you can delete it or replace it with another photo at any time. Select your profile to see the various options that are available to you.

C.2. Requesting MOIA Mobility Services and integration of map content 

C.2.1. Requesting a MOIA Mobility Services within the MOIA App

When you request a MOIA Mobility Service, we use the location details in the request (starting point and destination) to present booking options and to calculate the best routes for our vehicles.

We also use this information – with no reference to individual persons – to better tailor our services in line with demand and to improve our route calculation algorithm. 
We do not use location data to create a movement profile of you.

C.2.2. Integration of map content

Location data is shared with the map provider in order to display maps in the MOIA App and to navigate you to the point where you can start using the MOIA Mobility Service.

The map content is integrated using Google Maps, a service provided Google. Location data that is sent to Google is always made anonymous. For more information about how Google processes data, see: https://www.google.com/policies/privacy/. You can find Google’s privacy policy on this page: https://policies.google.com/terms?hl=en.


C.3. Payment function

Your payment details are transmitted to our payment service provider in order to complete the payment process. PayPal transactions are carried out by PayPal (Europe) S.à r.l. et Cie, S.C.A, 22–24 Boulevard Royal, L-2449 Luxembourg ("PayPal"). For other payments we use Adyen N.V., Simon Carmiggelstraat 6–50, 1011 DJ Amsterdam (“Adyen”).

To prevent and detect instances of fraud, your IP address, e-mail address as well as a device and payment service provider specific ID can be transmitted. All data transfers are encrypted.

Detailed privacy information about Adyen can be found online at:
https://www.adyen.com/policies-and-disclaimer/privacy-policy.

For more information about how PayPal processes data, see:
https://www.paypal.com/webapps/mpp/ua/privacy-full.
 

C.4. Use of MOIA Mobility Services

When you book a MOIA Mobility Service, we will associate the booking details and information about performance of the MOIA Mobility Service to your user account, showing your previous trips in the MOIA App.

In addition, your information will be shared with the provider performing the MOIA Mobility Service. Data processing by the MOIA Mobility Service provider occurs in accordance with this Privacy Policy. 

The driver of the MOIA vehicle is given your first name for identification purposes. Your initials will be displayed next to your stop on the vehicle’s information screen (e.g. “JB” for “Josephine Bloggs”). This allows you to track your position on the screen and see when you have reached your destination.

If there are any disruptions to the provision of our MOIA Mobility Services (e.g. your MOIA vehicle is delayed), we will use your contact details to notify you by phone, e-mail, text message, in-app alert, or push notification.


C.5. Improving our services

C.5.1. Google Firebase

We use Google Firebase to improve our app. Google Firebase makes it possible to use a variety of products. In particular, we use Crashlytics, Google Analytics for Firebase, Dynamic Links, Cloud Messaging, A/B Testing and Remote Config. You can find more information about these services here.

When Google Firebase is used, data is sent to Google using a pseudonym. We are unable to associate this data with a specific natural person. You can find more information about data privacy in connection with Google Firebase here.

You can opt-out Google Firebase at any time by moving the “Analytics” slider inside the MOIA App accordingly. You can find the slider in the MOIA App's privacy settings when you visit your profile.

C.5.2. adjust

We use a service called “adjust” in our MOIA App. Provided by adjust GmbH, Saarbrücker Strasse 37a, 10405, Berlin (“Adjust”), adjust helps us to establish links between advertising campaigns and the subsequent installation and use of the MOIA App so that we are able to measure the success of advertising campaigns.

For this purpose, we use pseudonymized data such as your IDFA or Google Play Services ID as well as truncated IP and MAC addresses. The information collected is not associated with a specific natural person without explicit consent.

The data privacy policy of Adjust can be found under the following link:

https://www.adjust.com/privacy-policy/

You can opt-out adjust at any time by moving the “Analytics” slider inside the MOIA App accordingly. You can find the slider in the MOIA App's privacy settings when you visit your profile.


C.6. Push notifications

Our MOIA App offers push notifications, which are messages created by the MOIA App that can be displayed on your device. You can decide at any time whether you want to allow push notifications or not by adjusting on your device. 
 

C.7. Personalized marketing

We aim to send you messages that are of interest to you. For this reason, we ask for your consent to the following during the registration for our MOIA App:

"I am at least 16 years of age and would like to receive personalized information about vouchers, offers, products, and surveys from MOIA by e-mail, text message, push notification, or through advertisements (e.g. via social media). Data about location, usage, and content will be combined for this purpose. I have read the privacy policy. You have the right to withdraw your consent at any time.”

Your consent is optional. With your permission, we will use the information below to determine whether certain content is of interest to you:

Registration data (e.g. email address, first name, last name), Booking data (e.g. spending, journeys made, preferred starting points and destinations), Usage data (e.g. opening rates and click behavior in the MOIA Apps, websites, and newsletters), Location data (When processing locations, MOIA may use location-based services such as WLAN, GPS, or Bluetooth, which are used for data transmission. Localization only takes place in close proximity to our virtual MOIA stops and inside our MOIA vehicles. The storage of location information is temporary; this data is not used to create movement profiles. Additionally, MOIA may request a “blurred” location when the MOIA App is launched in order to decide which service area is of interest to you. This blurring takes place on your device, so no exact location is transmitted to MOIA. A log of blurred locations is not created.).

Consent is granted for the following marketing channels:

Email, SMS, Push notifications (if enabled on your device), In-app notifications, Advertising on third-party websites (retargeting), Advertisements within the Google and Facebook advertising networks (MOIA may use a campaign management tool provided by emarsys eMarketing Systems AG, Hans-Fischer-Straße 10, 80339 Munich (“emarsys”) to upload a hash of your e-mail address and mobile number (a combination of letters and numbers) to the Google and Facebook advertising networks. Each advertising network can compare this hash value to other hash values that are already known to the network and determine whether you are a network user or not. If this is the case, advertisements may be displayed within the network. For more information about the Facebook data policy, please visit: https://www.facebook.com/policy.php. Google’s privacy policy can be found online at: https://policies.google.com/privacy?hl=en).

You may withdraw your consent to receiving personalized marketing information at any time with effect to the future. To do so, select the unsubscribe link contained in each e-mail we send out, adjust the privacy settings in the MOIA App, or send an e-mail to datarequest@moia.io.

Please note that it can take up to 48 hours to process your withdrawal of consent for technical reasons.

The legal basis for processing your personal information for personalized marketing is your consent (article 6(1)(a) GDPR).

Berlin, 18.03.2019

Cookie Policy

Cookie Policy

A cookie is a small data file that is stored on your terminal device and contains data such as your personal site settings and log-in information. This data file is generated and transmitted to you by the web server to which you have connected using your web browser. We in general set cookies to analyze user interest in our websites and help make them more user-friendly. You may in general access our websites without cookies as well. If you, however, wish to use the full functionality of our websites in the most user-friendly manner, you should accept the cookies that enable the use of certain functions or provide convenience features. 

By using our websites, you consent to the use of those cookies that your browser accepts based on your browser settings. The default setting on most browsers is to accept all cookies. You may, however, set your browser to notify you before cookies are accepted, to accept or reject only certain cookies, or to reject all cookies.

Please note that any changes you make to these settings only apply to the particular browser program in which you made them. If you use different browsers or different terminal devices, you have to change the settings for each browser and each device. You are furthermore able to delete cookies from your storage medium at any time. Please refer to your browser's Help function for information on how to change your cookie settings and delete cookies.

The most common types of cookies are explained below for your information.

Session cookies
While you are using a website, a session cookie containing a session identifier is temporarily stored in your computer's memory, e.g. so that you do not need to log on again every time you change webpages. Session cookies are deleted when you log off or cease to be valid as soon as your session automatically expires.

Permanent cookies (protocol cookies)
A permanent or protocol cookie stores a file on your computer for the duration defined by the file's expiration date. These cookies enable websites to remember your information and settings the next time you visit them. This speeds up your access and makes it more convenient, for instance because you do not need to adjust your language setting for our portal every time. The cookie is automatically deleted once its expiration date is reached when you visit the website that generated the cookie.

Third-party cookies
Third party cookies stem from a provider who is not the operator of the website. They can be used to collect information for purposes of advertising, user-defined content, and web statistics.

Flash cookies
Pieces of data that are stored on your computer by a website are referred to as flash cookies if Adobe Flash is used to operate them. Flash cookies have no time limit.

Google Analytics
On our website we use Google Analytics, a service provided by Google LLC ("Google"). With Google Analytics we can understand the usage behavior on our websites. For this purpose, pseudonymous usage profiles can be created. There is no assignment of these usage profiles to a specific natural person. When using our website, your IP address will usually be anonymized by Google within a member state of the European Union or the European Economic Area. In exceptional cases, it may happen that the IP address is transferred to a server in the USA and is anonymized there. You can deactivate Google Analytics using the settings of your browser application or by downloading and installing the browser plug-in available under the following link:

http://tools.google.com/dlpage/gaoptout?hl=en

Alternatively, you can click here to set a cookie that prevents the future collection of your data when opening this website.

For more information about Google Analytics and Google's data usage, see:: https://www.google.com/analytics/terms/gb.html and 
https://www.google.de/intl/de/policies/privacy/

The following cookies are used on this website:

list of all cookies (PDF)

As per June 2019