Privacy policy muvon

1. Who treats your personal data collected through this website?

Nova Mobilitat Compartida SLNE, whose registered office is at Carrer Sol 28 3B, 07001 Palma de Mallorca, Spain, (hereinafter referred to as ” Muvon ” or ” We “) is responsible for the processing of personal data belonging to it. successively, the”User (s)” or “You” ). Your personal data refers to any information that allows us to identify you, either directly or indirectly, and which is collected through this website or through our mobile applications.

2. What kind of personal data are collected?

2.1. Usage data

The browsing of the Muvon sites and applications (as well as the use of any third party application integrated and / or available in them) implies the communication to Muvon of usage data, which are implicitly acquired during the user’s browsing through of the Internet communications protocol (hereinafter, ” Usage Data” ).

The usage data includes, among others, the IP addresses or domain names of the devices used by the Users, the URI (Uniform Resource Identifier) ​​addresses, the time of the request, the method used to send the request to the server, the size of the file received as response, the numeric code that indicates the status of the server’s response (satisfactory result, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the User, the different details of time per visit (for example, the time spent on each page within Muvon) and details about the route followed within Muvon with special reference to the sequence of pages visited, and other parameters on the operating system of the device and / or the computer environment of the user.

The usage data is not collected in order to identify the User. However, you must take into account that identification may be possible through other elaborations and associations, as well as with information held by third parties.

2.2. Data communicated by the User

Users are free to browse the sites or applications of Muvon but, to use the service, Users must register and reveal the information requested in the corresponding forms completely and truthfully.

Whenever a field is described as “optional” or “non-mandatory” or not marked with the symbol “*”, this means that the User is free not to communicate the requested data and that the User can continue with the registration despite of the absence of this information. The data collected by Muvon for registration are: name, surname (s), gender, date of birth, driver’s license, mobile phone number and address. To subscribe to the newsletter, Users will be asked to provide their email address.

The personal data of the User will be treated with the prior, free and informed consent of the User and only for the purposes described in this privacy policy.

The explicit, optional and voluntary shared use of the User’s email address in the contact forms provided in Muvon implies that Muvon acquires the email address in question, as well as any other communicated data, to satisfy the contact request.Users are invited not to share the data of third parties unless this communication is strictly necessary for the request made. Users are responsible for any personal data of third parties obtained, published or shared through Muvon and confirm that they have the consent of the third party to provide the data to Muvon.

In addition to the information found in this privacy policy, Muvon may provide the User with additional and specific information about other services or about the collection and processing of personal data upon request.

3. For what purposes does Muvon collect your personal information?

Through our website and mobile applications, Muvon offers you vehicle loan services. To this end, Muvon treats the personal data that you voluntarily provide to Muvon for the following purposes:

a) Your registration as a member of Muvon and the creation of your account:

This treatment is necessary to identify you and to prepare and facilitate your future vehicle loan reserves with Muvon. The personal data provided for the registration of your account refers to the personal data you must provide to activate your account and access our vehicle loan services (these include, among others: your full name, address, age, driving license , phone, a selfie , etc.).

If during the registration, the user chooses to validate their driver’s license through the Muvon application, the driver’s license images along with their picture they have created will be collected and processed in order to validate the driver’s license.Whenever possible, the driver’s license data will be read electronically from the driver’s license images added by the user; otherwise, the data will be transcribed manually by our customer service team. The images of the user’s face will be compared with the images of the user’s driving license (facial alignment). These image files will be verified as part of the recognition process performed by our customer service. The images will be stored as permanent evidence that the verification of the driver’s license has been carried out correctly, and for the period strictly necessary for the fulfillment of the legal obligations to which Muvon is subject.

b) The processing of your reservation:

i. to confirm your vehicle loan reservation;

ii. to modify or cancel your vehicle loan reservation;

iii. to contact you regarding your reservation (for example, to provide you with information about your reservation, to send you a reminder before your arrival and departure, to answer your questions or suggestions);

iv. to manage your vehicle loan reserve (delivery and return of the vehicle);

v. to manage your invoices;

vi. to manage the payment of arrears;

vii. to manage possible claims;

viii. to manage the recovery of possible damages to Muvon’s vehicles;

ix. to manage your insurance.

x. to manage access to some car parks.

The purposes of the aforementioned treatment are necessary for the booking and compliance with the terms and conditions of the vehicle loan subscribed with Muvon (hereinafter referred to as the “Vehicle Loan Agreement” ).

c) Purposes of payment:

This treatment is necessary for compliance with the Vehicle Loan Agreement , which is concluded between you and Muvon. During the duration of our business relationship with you, Muvon will keep your bank account or credit card information to facilitate the payment of your subscription and reservations.

d) Monitoring of Muvon vehicles through the use of devices connected to vehicles:

Muvon offers its vehicle lending services in a fully digital and automated way through the ZEMTU software platform and on-board vehicle technology. As a result, the Muvon fleet is equipped with devices that have Internet connectivity.

The purpose of these devices and the data collected through them allows Muvon:

i. Monitor the status, performance and functionalities of Muvon vehicles. For example, this allows Muvon to check whether the battery level of the vehicle is adequate or not, etc. The purpose of this information is to guarantee that each vehicle is in good working order and is available for Users’ reservations.

ii. to identify possible breaches of the Vehicle Loan Agreement (for example, make sure that the User (i) has returned the Vehicle with sufficient battery level, iii) has returned the Vehicle in the dedicated parking space, etc. ).

This treatment, intended to protect the integrity of Muvon’s fleet, is based on Muvon’s “legitimate interest”.

e) Monitoring of Muvon vehicles based on geolocation systems and their Internet access devices:

As a result, Users should be aware that (i) geolocation systems and (ii) Internet connection devices are integrated into the Muvon vehicle loan fleet.

Muvon has installed the geolocation systems to verify the presence of the rented vehicle in the correct departure parking at the beginning of the rental and to verify the presence of the rented vehicle in the correct return parking at the end of the rental. These geolocation systems allow Muvon to ensure that the Vehicles are located in their designated area and that they are available for booking.

This information will also be used for the purposes listed below:

i. to prevent any fraud and / or damaging action against your property, as well as to provide a better service to the Users. For example, geolocation systems allow Muvon to ensure that its Vehicles are returned on time in the designated parking lot or, alternatively, (i) allow Users to extend their reservation or (ii) mitigate any consequences for the User whose Vehicle has been delayed.

ii. Location of the vehicle in case of theft or suspected theft;

iii. Location of the vehicle in case of accident suspicion to provide emergency medical assistance or treatment.

The User’s location is collected solely for the purposes mentioned above.

This treatment, intended to protect the integrity of the Muvon fleet, is based on the “legitimate interest” of Muvon and is necessary for compliance with the Vehicle Loan Agreement between you and Muvon.

f) Improvement of your browsing experience:

The User’s Use Data is treated solely to allow the User’s navigation in the Muvon sites and applications from an operational and technical point of view and to improve the User’s browsing experience. Based on these Usage Data, Muvon will be able to adapt its website to guarantee an easier and faster navigation. For example, the Usage Data allows us to make sure that the Muvon website is the most relevant for you, depending on your language and your country of origin.

g) Improvement of Muvon services based on:

i. customer surveys you have completed;

ii. Record your vehicle loan history to suggest preselected options when searching for a new reservation.

This treatment, which aims to better understand the needs of Muvon members and to offer personalized functions to improve their experience with Muvon products / services, is based on Muvon’s “legitimate interest”.

h) Promotional and marketing activities , with prior consent, namely:

i. the sending of emails and text messages for promotions / special offers, as well as advertisements and personalized promotions aimed at your specific interest on Muvon products / services;

ii. sending Muvon newsletters;

iii. sending emails about a reservation that you did not complete or sending a summary about a reservation inquiry;

iv. the management of your loyalty program;

v. the organization of promotional contests / draws;

vi. the management and updating of the customer / client database of Muvon.

The direct marketing treatment, that is, any commercial message of Muvon with the aim of promoting the services of Muvon, is subject to your express consent.

As an exception:

– if you are already a Muvon customer and the message refers to similar services that you have already acquired, the underlying treatment will not be based on your consent but on Muvon’s “legitimate interest”; Y

– the sending of transactional emails (relating, for example, to the updating of the Vehicle Loan Terms and Conditions, the confirmation of your reservation, etc.) are necessary for the execution of the Contract between you and Muvon.

i) Statistical purposes:

The aim of this treatment is to carry out anonymous and aggregated statistical analyzes on customer use data.

j) The management of fines:

This treatment aims to:

i. transfer to the relevant competent authority, responsible for handling the fines, the identity of the driver who has committed a traffic offense;

ii. satisfy the fine collection procedure to which Muvon may be subject.

This treatment is mandatory by law.

k) The management and updating of a watch list of customers that present certain contractual risks based on:

i. payment incidents that have led to legal proceedings;

ii. accidents with vehicles or repeated damage caused by the Muvon customer;

iii. accidents or damages caused voluntarily by the customer of Muvon;

iv. the use of Muvon vehicles in violation of the Vehicle Loan Terms and Conditions.

This treatment, which aims to reduce exposure to Muvon’s risks in the execution of the Vehicle Loan Agreement, is based on the “legitimate interest” of Muvon.

l) The processing of personal data for purposes of law enforcement:

In the event of any intentional act of misconduct, fraud or crime (other than the traffic offenses or crimes mentioned above) being committed against Muvon, personal data may be used, in certain circumstances, to determine individual responsibilities and be transferred to the competent authorities.

In addition, your personal data may be processed in order to comply with the duties and obligations established in the applicable laws and regulations. The User declares to be aware that Muvon may be forced to reveal personal data at the request of the competent public authorities.

For your complete information, Muvon carries out some processing of your personal information through “cookies” and other crawlers collected each time you visit the Muvon website. This treatment is governed by the Muvon Cookies Policy, which we recommend that you review. You can accept or reject these cookies and other crawlers by following the instructions provided in the Muvon Cookies Policy.

4. Who are the recipients of the personal information we collect about you?

4.1 Categories of recipients

Your personal information will be disclosed, as necessary and / or relevant to:

a) the authorized personnel of Muvon and the entities of the same group (including the Europcar group to which Muvon belongs) and / or entities, as the case may be, belonging to the Muvon franchise network, for the purposes described in this privacy policy ;

b) Muvon’s subloaders, which are third-party service providers that collect data to help Muvon provide its products / services. To learn more about the list or categories of these service providers, please click here;

c) with respect to the information processed for the payment of fines, to the pertinent competent authority – in the country where the User made the reservation – that deals with the processing of fines;

d) Muvon may also disclose your personal data to the extent required by law and / or by the competent authorities.

The information communicated is limited to what is strictly necessary for the provision of our services. The communication of said Data will be limited to what is necessary so that Muvon can comply with its contractual and legal obligations.Provided that your personal data is shared with a third party, Muvon will only do so after the conclusion of a contract with the third party in which it commits to protect all personal data using appropriate security measures and not to use such personal data for purposes different from those indicated above.

4.2 International transfers

As necessary or useful to provide Muvon’s products / services, Muvon – for the purposes herein established – will transfer your personal data outside the EU to third parties, as indicated in Annex 2.

Depending on the case, some recipients can be found in countries that have been recognized by the European Commission as guaranteeing an adequate level of protection or in countries that have not been recognized as guaranteeing an adequate level of protection. In any case, Muvon has established adequate security measures to protect your personal data, in accordance with EU Regulation No. 2016/679 (the “General Data Protection Regulation” ).

For more information regarding the countries to which your personal data may be transferred, your level of data protection and the possible guarantees established by Muvon, please click here.

5. How long does Muvon keep your personal data?

Your personal data is kept for a different period of time, depending on the purposes of the treatment:

Purpose

Conservation period

Your registration as a member of Muvon and the creation of your account

Your vehicle loan reserve;

During the duration of the business relationship.

However, keep in mind that:

– the registration information and booking history will be archived for a period of between 6 and 9 months from the time you have requested the cancellation and deletion of your registration account. Such delay in the deletion and / or anonymization of your personal data will be strictly limited in order to protect Muvon from any fraudulent or criminal activity;

– Information that can prove a right or that must be retained in accordance with a legal requirement (such as invoices or evidence of transactions) may be subject to an intermediate filing policy for a period of time not to exceed the time required for the purposes for those that are conserved, in accordance with the applicable legal provisions.

Payment

The only information that Muvon can access with respect to your payment method is the expiration date of the card and the name of the cardholder.

However, such information that may prove a payment is subject to an intermediate filing policy for a period of 13 months after the actual payment of a credit card and 15 months in the case of a deferred debit card, to use if the transaction is questioned.

Monitoring of Muvon vehicles through the use of devices connected to vehicles

Up to 9 months from the end of your business relationship with Muvon.

Monitoring of Muvon vehicles based on geolocation systems

Up to 9 months from the end of your business relationship with Muvon.

Improve your browsing experience and Muvon services depending on your preferences

Up to 9 months from the end of your business relationship with Muvon.

Promotional and marketing activities

For Muvon customers, up to 3 years from the end of the business relationship with Muvon.

For potential customers – who are not Muvon customers – up to 3 years from the collection of your personal information OR from the last request for information you made.

Statistical analysis

Up to 9 months from the end of your business relationship with Muvon.

C ookies

Please check the Muvon Cookies Policy.

Payment of fines

For the time necessary to identify the driver (or potential driver) responsible for the violation that led to the fine, which can not exceed 45 days after the receipt of the fine. However, the relevant information may be retained for a longer period of up to 12 months after the receipt of the fine, subject to an intermediate filing policy.

Requests from the competent authority dealing with the processing of fines in the country where the reservation was made will be deleted once Muvon has processed the requests.

The management and updating of a watch list of clients that present certain contractual risks, namely:

i. payment incidents that have led to legal proceedings

ii. accidents with vehicles or repeated damage caused by the customer of Muvon

iii. accidents or damages caused voluntarily

3 years from the event of the relevant event

iv. the use of Muvon vehicles in violation of the Vehicle Loan Terms and Conditions

5 years from the event of this event

6. What rights can you exercise with respect to the processing of your personal data?

You can view and / or update your personal profile at any time, which includes member registration, driver information and information about rental preferences, through the “My profile” section accessible on the Muvon website. You can change your password, update or correct your phone number, address and information about your driving license and update your car rental and travel preferences, including payment methods.

According to EU Regulation No. 2016/679 (the “General Data Protection Regulation”), you can also benefit from the following rights:

a) “access” right: the right to obtain confirmation of whether or not Muvon is treating your personal data and, where appropriate, to access said personal data and obtain more information about the characteristics of its treatment;

b) right to “rectification”: right to obtain the correction of inaccurate personal data or, taking into account the purposes of the processing, the right to complete personal data that are incomplete, including by means of an additional declaration;

c) right to “deletion” (or the so-called “right to be forgotten”): the right to obtain the deletion of personal data in certain circumstances;

d) right to “restriction”: right to obtain processing restrictions under certain circumstances. In the event that the processing of your personal data is restricted, such data may only be processed later with your consent (except for storage purposes) and you will be informed before the processing restriction is lifted;

e) right to «oppose»: at any time, a right to object to the processing of your personal data to prevent Muvon from continuing with such treatment:

i. when your data is processed for direct marketing purposes;

ii. when your personal data is processed based on the legitimate interest of Muvon.In this case, your request will be answered only if you provide Muvon with a description of the particular situation that legitimizes your request and unless Muvon can demonstrate predominant legitimate reasons in light of your particular situation.

f) right to “withdraw your consent”: when the processing of your personal data is based on your consent, a right to withdraw your consent for the processing of your personal data at any time and to prevent Muvon from continuing to carry out such treatment ;

g) right to “data portability”: in the case that the processing of your personal data is based on your consent and by automated means, the right to receive the personal data you have provided to Muvon, in a sheet of calculation of Excel and to transmit said data to a third party.

If you wish to exercise any of these rights, please contact us through the email address corresponding to your country, as indicated below in section 8. In addition, in promotional emails and Muvon marketing and other communications, Muvon also includes instructions on how to unsubscribe.

To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.

According to Article 77 of EU Regulation No. 2016/679, you can file a complaint about the processing of your personal data with the body that regulates data protection in your country if you consider that the processing of your personal data infringes EU Regulation No. 2016/679.

7. How does Muvon protect your personal data?

Muvon is committed to protecting the information it collects through this website.

In particular, Muvon uses the appropriate physical, technical and organizational security measures to avoid unauthorized or illegal treatment, accidental loss, destruction or damage to your personal data.

Muvon systems are configured with data encryption, or encryption technologies, and with industry-standard firewalls. When you send personal information to a Muvon website over the Internet, your data will be protected by SSL ( Secure Sockets Layer) encryption / decryption to ensure secure transmission.

Any credit card transactions that you make through the Muvon websites are made through our payment service providers that comply with the PCI DSS standard, which guarantee the security and protection of your payment methods and transactions.

8. Who to contact in case of doubt about the processing of your personal data?

Depending on the purpose of your query:

a) For any general inquiry about the processing of personal data carried out by Muvon, please contact contacto@muvon.es.

b) To exercise their rights (access, rectification, deletion, restriction, etc.):

admin@muvon.es

c) For legal notifications: Nova Mobilitat Compartida SLNE, Carrer Sol 28 3B 07001 Palma de Mallorca (Illes Balears) Spain.

9. Changes to this Privacy Policy

This privacy policy was published on January 23, 2019. In the case of changes to this privacy policy by Muvon, Muvon will identify such changes on this website.

When a change affects a treatment performed on the basis of your consent, Muvon will contact you to obtain a new consent.


[1] If (i) you challenge the accuracy of the personal data, (ii) it is proven that the processing is illegal and opposes the deletion of personal data, but would like to request the restriction of your use, (iii) Muvon You no longer need personal data for the purposes of processing, but you require them for the establishment, exercise or defense of legal claims. [2] Or any other commonly used and machine-readable format. [3] The country in which you have your habitual residence, your place of work or the place of the alleged infringement.

© 2019 Muvon – All rights reserved.