Privacy Policy

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest to use our electric bikesharing scheme or obtain information about us or our products and services, when participating in activities on the Sites or Apps or otherwise contacting us.

Monitoring or recording of your calls or e-mails may take place for our business purposes.

The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, demographic information, location information and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), the security code associated with your payment instrument, billing and contact information. All payment data is stored by our payment processor and you should review their privacy policies and contact the payment processor directly to respond to your questions.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information collected through our Apps

We may collect information connected to your geo-location and your mobile device, when you use our app or our bikesharing scheme.

Geo-Location Information: We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. We collect information about the location of the rented bikes and their routes, incl. the status of the bikes. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, camera, sensors, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Information collected from other sources

We may collect limited data from public databases, employers, marketing partners, and other outside sources.

Employers / Partnering Organisations: Where we have agreed with an employer to provide access to staff to our private fleets or public system we may collect limited data, including name, work email and mobile number, and building access card data, so as to enrol staff into the scheme.

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).

We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons").

We use the information we collect or receive:

• To provide you with our services, especially to register, execute payment procedure, manage your account and interact with you through the App, website, email or SMS and meet our commitments related to our service standards and our Terms and Conditions.
• To send you marketing and promotional communications, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
• To send administrative information to you, including service and new-feature information and information about changes to our terms, conditions, and policies.
• Fulfill and manage your MOBY bike usage, payments, returns and exchanges made through the Apps or website.
• Request feedback and contact you about your use of our Sites or Apps.
• To enforce our terms, conditions and policies.
• To respond to legal requests and prevent harm.
• For other business purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Sites, Apps, products, services, marketing and your experience. We may also use information for quality control and training, to prevent unauthorised use of our system and to ensure effective systems operation and in order to prevent or detect crime.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.

We have assessed that there is a legitimate business interest in processing your data so we can maintain an accurate record of our users, offer the scheme to you, provide customer service, and comply with industry standards and legal guidelines. We only process as little data as is practically possible so as to offer access to our scheme to you.

More specifically, we may need to process your data or share your personal information in the following situations:

• Vendors, Consultants and Other Third-Party Service Providers who perform services for us or on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts.
• Business Transfers, in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates, including our parent company and any subsidiaries, joint venture partners or other companies under common control with us.
• Business Partners, to offer you certain products or services.
• Employers, where you have been entered into, or joined, a private fleet scheme offered by your employer.

Booking our services through third-party providers

Our services can also be booked via third-party partner apps. In doing so, the partner facilitates vehicle rental agreements between you and us. The registration of a customer account with us and the use of our app is not required in this case. For this purpose, we usually do not receive any personal identifying data from our partners, but only pseudonymous user IDs and information about the specific booking.

The partner is responsible for data processing in connection with the partner app (including data collection and creation of customer accounts in the partner app, and payment processing, if applicable). We are responsible for data processing in connection with the implementation of the vehicle rental. You can assert your data protection rights both against us and the respective partner.

Our partners who enable the booking of our services are:

• Free Now Ireland Ltd, 7-12 Baggot Court, Dublin 2, Dublin, D02 F891, Ireland ("FreeNow Ireland").

We have categorised each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

• Analytics & Communications: Google Analytics, Mailchimp, Hubspot.
• Payments: Stripe.
• Customer Service: Intercom.
• Service Operations: Fix Your Cycle (UK only).

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. We also use Google Analytics, a service provided by Google. Its usage may collect information such as IP address, time of visit, location and repeated visits. Google Analytics is subject to Google's privacy policy. We use such technologies to monitor traffic, and improve our web, apps and other services.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 6 months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. We will do our best to protect your personal information, however transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account, or contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and comply with legal requirements.

Cookies and similar technologies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, this could affect certain features or services of our Sites or Apps.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

MOBY is providing service to users at the age of 18 and older. If used by minors, it must be under the responsibility of a registered adult only. We do not collect or use any personal data about minors.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO) by emailing info@mobymove.com, or by post to:

MOBY Bikes, Unit 8, 106c Lagan Rd, Dublin Industrial Estate, Glasnevin, Dublin, D11 DXA9.