Last Updated: 20 December 2021

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA“) and is a supplement to Moovit’s Privacy Policy (“Privacy Policy”). Capitalized terms used but not defined in this Notice will have the meanings ascribed to them in our Privacy Policy. The terms “personal information”, “business purpose”, “commercial purpose”, “sale” and “service provider” as used in this Notice have the meanings ascribed to them in the CCPA. This Notice may be modified by us at any time and from time to time; the date of the most recent changes or revisions will appear on this page. If there is any conflict or inconsistency between the terms of this Notice and the Privacy Policy, the terms of this Notice will prevail with respect to California Consumers.

1.  PERSONAL INFORMATION WE COLLECT AND SHARE

We may collect, use and disclose your personal information (“PI“) as required or permitted by applicable law. We collect the following categories of PI from the corresponding sources and for the corresponding purposes set forth in the table below. The table also includes information as to categories of third parties with whom PI is shared and the business and commercial purposes for selling (as broadly defined in the CCPA) PI to third parties.

CATEGORY OF PI	SOURCES OF PI	BUSINESS OR COMMERCIAL PURPOSES FOR PI COLLECTION	CATEGORIES OF THIRD PARTIES WITH WHOM PI MAY BE SHARED	BUSINESS AND OPERATIONAL PURPOSES FOR SHARING TO THIRD PARTIES	COMMERCIAL PURPOSES FOR SELLING TO THIRD PARTIES
1. Identifiers which may include: IP Address Name Billing/Shipping Address Email Address User ID	Your device You Moovit internal systems Vendors Marketing partners	Processing/ Managing Transactions Security Debugging Performing our Services Research and Development Quality Assurance Marketing	Marketing Partners Vendors and service providers Law enforcement or other third parties in connection with legal requests	Processing/ Managing Transactions Security Debugging Performing our Services Quality Assurance Marketing	Advertising
2. Personal Records which may include: Name Address Email Address Phone Number	You	Processing/ Managing Transactions Security Performing our Services Quality Assurance Marketing	Marketing Partners Vendors and service providers Law enforcement or other third parties in connection with legal requests	Processing/ Managing Transactions Performing our Services Marketing	Advertising
3. User Account Details / Commercial Information which may include: User’s click path Product information accessed Purchasing or consuming histories or tendencies	Your device You Moovit internal systems	Processing/ Managing Transactions Security Debugging Performing our Services Research and Development Quality Assurance Marketing	Marketing Partners Advertising Partners Vendors and service providers Law enforcement or other third parties in connection with legal requests	Processing/ Managing Transactions Security Debugging Quality Assurance Marketing	Advertising
5. Internet Usage Information which may include: User’s click path Visitor status (new/returning) Browsing history Search history Cookie history	Your device Moovit internal systems	Processing/ Managing Transactions Security Debugging Performing our Services Quality Assurance Marketing	Marketing Partners Advertising Partners Vendors and service providers Law enforcement or other third parties in connection with legal requests	Processing/ Managing Transactions Security Debugging Quality Assurance Marketing	Advertising
6. Geolocation Data which may include: Geolocation data Route and travel data	Your device You	Security Debugging Performing our Services Marketing	Marketing Partners Advertising Partners Vendors and service providers Law enforcement or other third parties in connection with legal requests	Processing/ Managing Transactions Security Debugging Marketing	Advertising

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI, and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information.

We may collect, use and disclose your PI for commercial purposes such as for interest-based advertising and sharing PI in a manner that is deemed a sale under the CCPA. Subject to restrictions and obligations of the CCPA, our advertising partners (including those that facilitate interest-based and other direct advertising and marketing), and/or other third parties may also use your PI independently.

Our vendors and service providers may themselves process PI for business purposes or operational purposes permissible under the CCPA, including processing to detect data security incidents, protecting against fraudulent or illegal activity, creation of datasets of aggregate consumer information and deidentified information, or appointing subprocessors.

If you instruct us to share your PI we may do so based on such instruction, and such sharing is not considered under the CCPA a sale of your PI. Also, sharing PI amongst the Moovit group of entities that operate the Services provided to you is not considered a sale of your PI under the CCPA.
Notwithstanding anything to the contrary in our Privacy Policy, we typically restrict use of your PI that is shared with our vendors and service providers for our business purposes, or we treat such disclosures as sales of your PI subject to your Do Not Sell rights.

While there is not yet a consensus, data practices of third-party cookies and tracking technologies associated with the Services may constitute a “sale” of your PI as defined by the CCPA. Please review the “Cookies & Similar Technologies” section of our Privacy Policy for more information about cookies and other tracking technologies and your choices regarding certain kinds of online interest-based advertising.

2.  YOUR CALIFORNIA CONSUMER RIGHTS

We provide California Consumers the privacy rights under the CCPA as described in this Section 2. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification process (“Verifiable Consumer Request“). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.

To make a request according to your rights to know or to request deletion of your PI as set forth below, please contact us at privacy@moovit.com and respond to any follow up inquiries we may make. We will take steps to verify your identity before complying with the request to protect your privacy and security. We will send you an email to the email address that you provide to us, and you must take action as described in the email. This will enable us to verify that the person who made the request controls and has access to the user account associated with the request. We will be unable to fulfill your request if we cannot verify your identity. We reserve the right to modify our verification procedures and may request additional information from you as needed or as required by applicable law.

Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave such PI to us for another purpose.

We will make commercially reasonable efforts to identify PI that we collect, process, store, disclose and otherwise use and to respond to your CCPA privacy rights requests. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that your request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we charge you for responding to your request.

Your CCPA privacy rights are as follows:

A. The Right to Know:

a. Information Rights — You have the right to send us a request, no more than twice in a 12-month period, for any of the following for the period that is 12 months prior to the request date: the categories of PI we have collected about you; the categories of sources from which we collected your PI; the business or commercial purposes for collecting or selling your PI; the categories of third parties with whom we shared your PI; the specific pieces of PI we have collected about you; a list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred; a list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain the categories of your PI we have sold and the categories of third parties to which we sold PI.

b. Obtaining Copies of PI — You have the right to make or obtain a transportable copy, no more than twice in a 12-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.

Please note that PI is retained by us for various time periods and we do not have any obligation to retain it longer than we need it just to be able to respond to your requests, so we may not be able to fully respond to what might be relevant going back 12 months prior to your request.

B. Deletion: Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you.

You may alternatively exercise more limited control of your PI by opting out of receiving further commercial emails by clicking “Unsubscribe” or “Manage my email preferences” in any email from Moovit. Please note that if you opt out of receiving further commercial emails, you may still receive transactional emails.

C. Do Not Sell: You have the right to opt out of the sale of your PI by clicking the “DNSMI” button (found under the Setting Menu) or by contacting us at privacy@moovit.com. You will be able to: Opt out of the sale of your PI maintained by Moovit, including, for purposes of interest-based advertising.
Please note that opting out of the sale of your PI for purposes of interest-based advertising does not mean that you will stop seeing ads on the Services or that you will no longer see interest-based ads. You may still see ads on the Services that are tailored to your interests based on PI that (i) is not sold by Moovit, (ii) was sold to other digital advertising companies ninety (90) days or more before you opted out of sales of your PI for purposes of interest-based advertising, or (iii) is sold by sources from which you have not opted out.

For more information about cookies and other tracking technologies used on the Services and your choices regarding certain kinds of online interest-based advertising, please see the “Cookies & Similar Technologies” section of our Privacy Policy.

Please note: we do not knowingly sell the PI of Consumers we know are under the age of 16 unless we receive an opt-in from the Consumer who is at least 13 but under 16, or from the parent or guardian of a Consumer younger than 13. Consumers who opt-in to PI sales may opt-out at any time by following the Do Not Sell instructions above. If you think we may have unknowingly collected PI for sale belonging to yourself or to your child under the age of 13, or if you are at least 13 but under 16, exercising the opt-out will stop our selling of the PI. We may sell PI of Consumers who are 16 or older where such PI was collected by us before they turned 16.

D. Non-Discrimination: We will not discriminate against you in a manner prohibited by the CCPA because you choose to exercise your CCPA rights.

E. Ours and Others’ Rights: Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

3.  YOUR CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes. If applicable, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the calendar year immediately prior to the year in which the request is made. To make such a request, please send an email message to us at privacy@moovit.com. Any such request must include “Shine the Light California Privacy Rights Request” on the subject line and in the body of your message and must attest to the fact that you are a California resident and include your name, street address, city, state, and ZIP code and other sufficient information for us to determine this law applies to you. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. Note that we are only required to respond to one request per customer each year.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.