If you have any questions, contact us at privacy@moovit.com. If you wish to control or change your privacy settings, please contact us at support@moovit.com. If you do not agree to the terms of the updated Privacy Policy, you may opt out of specific features or choose to stop using our services.

 

MOOVIT PRIVACY POLICY
Moovit App Global Ltd. (“Moovit”, “we”, “our” or “us”) provides its customers and users (“User(s)” or “you”) with a mobile application platform and to the extent applicable web services providing public transit information and enabling Users to plan and optimize public transportation trips (the “Services”). Moovit is committed to your privacy. This Privacy Policy is intended to inform you of our collection, use, disclosure, retention, and protection of your personal information when using our Services.

Our Services include our downloadable mobile application(s) branded FlexiRide (the “App”), and related websites owned and operated by Moovit or its affiliates (the “Site(s)”) and related public transportation information and additional services. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at https://moovit.com/legal/flexiride-privacy-policy/ which this Privacy Policy is incorporated thereto by reference (together, the “Terms”).

Please read this Privacy Policy carefully before accessing and using our Services. By Accessing or using our service you are accepting the practices described in this Privacy Policy. If you disagree with any term provided herein, you may not access or use the Services.

Please note: you are not obligated by law to provide us with any personal information.

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
First – what is personal information?

Personal information is information about a person, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or information relating to an identified or identifiable natural person which may be of a private or sensitive nature. Under certain applicable laws identification of an individual also includes any information which associates an individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.

Personal information does not include information that has been anonymized or aggregated so that it can no longer identify or be used to identify a specific natural person.

Next – what and when do we collect personal information?

We collect personal information from you and from any devices (including mobile devices) you use when you install or have the App installed (or pre-installed) on your device, or when you use or access our Services, register for an account with us, provide us with information such as your favourites and travel habits, provide us information on a web form, run searches on our Services, update or add information to your account, or through correspondence you conduct with us.

More specifically we collect and use the following categories and types of information:

Personal information we collect automatically when you use our Services:

Information collected when installing the App

When you install the App (or have the App installed or pre-installed) on your mobile device, Moovit will set up a user account associated with that mobile device and create a User ID for you. This is a unique identifier generated by us in accordance with this Privacy Policy, which is necessary in order for us to provide you with our Services. After installation of the App, we will collect and use the User ID, together with certain other information including Metro area and certain device information which may include your device ID or other unique identifier, advertising ID, unique device token, device type, operating system (including version and settings), as well as your device screen resolution and keyboard language, all in accordance with this Privacy Policy. We may link this information with the account created in connection with your mobile device and User ID.

Usage Information
We receive information from you when you access and use our Services, as follows: your IP address, tokens of social networks you choose to connect to your account (as described below), information regarding your clicks, views and engagement with the Services, information concerning your traffic to and from the Services, your referral URL, our communications with you, your public transit historical searches on the Services, information about your use and your interaction with our Services, including the duration of such use; and your in-app settings;.

Geo-Location Information and other Sensors data

Moovit automatically collects location information such as your geolocation and your route and travel information (for example, routes and times of travel from one destination to another) in order to provide you with our Services. When using the App, we collect detailed location, including GPS signals and other device sensor data such as gyro/oscilloscope, sent by your mobile device on which the Service is installed and activated.

Moovit uses this location and sensor information to provide you with the Service andto create a detailed location history of your public transit trips.

PLEASE NOTE THAT MOOVIT COLLECTS YOUR LOCATION DATA IN THE BACKGROUND EVEN WHEN YOU ARE NOT USING THE APP TO PERSONALIZE THE SERVICES AND MAXIMIZE YOUR USER EXPERIENCE AND TO DEVELOP AND ENHANCE OUR PUBLIC TRANSIT INFORMATION SERVICES. YOU MAY CHOOSE TO DISABLE AND OPT-OUT FROM THIS BACKGROUND COLLECTION OF DATA UNDER THE APP’S PRIVACY SETTINGS SCREEN.

Automatic Collection
We may perform some of the automatic collection described above through use (to the extent applicable) software development kits (or SDKs), application program interfaces (or APIs), unique identifiers, and similar technologies which allow us and analytics partners to collect information about the pages and screens you view, the links you click, and other actions you take when using our Services.

Please take into consideration that certain portions of such above mentioned information may also be collected from your device or software, when the Services are running in the background, i.e. when they have been launched but are not
actively used.

Please keep in mind that most mobile devices and operating systems allow you to control or disable the use of certain collectable information including location services by applications, in the device’s settings menu.

Personal information you give us when you use our Services:
Generally, this category refers to any information, data or content you actively and voluntarily create, upload, or provide to us through our Services.

Account Information.
You may choose to set up a registered Moovit User Account in connection with your use of the Services. When setting up your Moovit registered User Account, you may actively share with us certain personal information, such as your email address. Another way to create an Account is through connecting and using your existing social media profiles to the App, as further detailed below.

Note – while our Services are available to all Users, whether or not they set up a registered Moovit User Account, we note that setting up such an account may allow you to enjoy certain features in the App that are only available to registered Moovit Users.

If you choose to use the Services without setting up a registered Account, Moovit will still link all of your information with a User ID generated for you, which is necessary in order for us to provide you with the core features of our Services.

If you have previously had an account in FlexiRide by Ventura, by accessing the service via the current App you hereby grant Moovit the access to your user account data in Ventura. Your user profile and all associated data, such as past rides, favorites, and other information will be migrated to the App for a seamless user experience.

Actively Provided Points of Interests (POI) Data

In addition, you may choose to upload specific destinations and POIs such as your home address, work address or other favourite destinations and POIs in order to personalize the Service. Moovit also collects information regarding public transportation lines, stations and/or routes you may have saved or searched for via the Services, including your most-used travel and public transit routes and stations for purposes of providing the Service, enhancing your user experience and personalizing the Service.

Additional Content you Choose to Share with us when using the Services

You may choose to upload to the Service User Content, such as images, photos, text, reviews and reports of data gaps or errors, and other types of content which you actively choose to provide. We also collect your responses to surveys we may send you on our behalf or on behalf of our partners.

Personal information collected from other sources:

Third Parties
We may also collect personal information concerning you from third parties who have assured us that they have either obtained your consent for the provision of such information or that you have freely and publicly provided such information yourself.

Social Media you elected to connect to your account

We allow you to share information with social platforms or use social platforms to create your Moovit Account. These social platforms give us automatic access to certain personal information retained by these social networks about you. This includes your Facebook Access Token, Google Sign-In Token, advertiser ID and information from your public profile, which may include your name, gender, profile picture, age group and residency. You control the personal information you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the personal information retained by the respective social platforms about you.

Information we derive

We may derive information or draw inferences about you based on the information we collect. For example, we may infer your location based on your IP address, or we may make inferences about your preferences and activities you may enjoy based on, among other things, your past location searches and other usage of the App.

Special Uses of our Services
You may elect to use certain specific aspects of our Services which are subject to specific terms of use and additional privacy practices including the requirement for specific additional information:

Ticketing Service Users

In some cities, Moovit may offer you the possibility of in-app purchasing of public transit tickets. If you elect to purchase public transit tickets through the Moovit App, you will be subject to additional terms and conditions as provided in the Moovit Ticketing Terms of Service and Moovit Ticketing Privacy Notice (the “Ticketing Service”).

In order to offer you with the in-app Ticketing Service, Moovit may partner with third party providers who offer online public transit ticketing services (“Ticketing Partners”). At your express direction we will share certain personal information about you (such as your Device ID, User ID, location) with these Ticketing Partners. To use the in-app Ticketing Service, you will also be subject to the terms of use and privacy policies of the applicable third-party Ticketing Partners, as well as those of the applicable public transportation agency providing you with the public transit itself.

Transportation on Demand (TOD) Users

In some cities, Moovit may offer you the possibility of using transportation-on- demand services. If you elect to use such on-demand services through the Moovit

App, you will be subject to additional terms and conditions as provided in the TOD Terms of Service and TOD Privacy Notice (the “TOD Services”). In order to provide you with the TOD Services, Moovit may partner with third-party transport operators who offer on-demand transportation services (“TOD Operators”). At your express direction, we will share certain personal information about you with these TOD Operators. To use the TOD Services, you will also be subject to the terms of carriage and privacy policies of the applicable TOD Operators.

2. WHO IS THE DATA CONTROLLER OF YOUR PERSONAL INFORMATION?
Moovit App. Global, LTD are the data controllers of the Personal Information collected in connection with the use of Moovit’s services.

3. HOW WE USE YOUR INFORMATION
Legal basis for use – We collect, process and use your information for the purposes described in this Privacy Policy based on at least one of the following legal grounds:

When Performing this Agreement: We collect and process your personal information in order to provide you with the Services, following your acceptance of these Terms, and to maintain and deliver our Services to you. For example, we collect your location information in order to provide you with recommended public transport means and routes to your desired destination.

With your consent: We ask for your agreement to process your personal information for additional specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to provide you with personalized content through the use of tracking technologies.

Legitimate interests: We process your personal information for our, and/or our third party partners legitimate interests, while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services; protecting against harm to the rights, property or safety of our properties, our users or the public as required or permitted by law; for the development and enhancement of our Services; to develop new features for our Users; to personalize the Services in order to deliver better user experience; for enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws, regulations, guidelines, industry standards and contractual requirements, legal processes, subpoena or governmental requests, as well as our Terms of Service.

Purpose of Use
We may use information that we collect about you for the following purposes:
• to provide you with and to operate the Services, including for aggregation, statistical and research purposes and to create and use aggregated anonymous data which is necessary to maintain, develop and improve Moovit’s services, including to determine navigation and routes, connect riders, and, at times, calculate costs of trips.
• in order to determine and ascertain User Accounts, verify User identity and enable Users, if relevant, to transfer or receive payments, which may include calculation of the costs for such services.
• to track your trips and aid you with navigation
• to process your payment for various features, such as ticketing.
• to personalize the Services and the content provided to you, to customize your user experience with the Services, to communicate with Users about their trips, including transport recommendations based on your preferences and to enable you to retrieve your information.
• to develop, improve and customize the Services, the experience of other Users and the offerings available through the Services.
• to be able to contact Users for the purpose of providing them with technical assistance and support, to handle requests and complaints, and to collect feedback in connection with our performance of the Services and in connection with public transportation needs.
• to send you updates, notices, announcements, and additional information related to the Services, such as changes in public transportation services or closures.
• to be able to reply to User online queries in connection with performance of the Services.
• to customize and improve the Service’s accuracy and interface.
• to comply with any governmental agencies’ legal requests or court orders, and/or with any applicable law, rule or regulation, such as reporting an abusive user or fulfilling tax regulation obligations with regard to promotions and which require the use of User data.
• to use the information to create statistical, aggregated or anonymous data which may be used at our discretion for any purpose.

We may also use the data we collect to market our services to our Users. This includes sending Users communications about Moovit services, features, promotions, sweepstakes, studies, surveys, news, updates and events. We may also send communications to our Users to provide promotional information and participation in the promotions, as well as information regarding offers, discounts and promotions related to our services.

We may also use the information we collect to send Users communications about products and services offered by our partners, but we do not sell your email address, name, or other identifying information to, or share such information with, such partners or others for purposes of their own direct marketing or advertising, except as set forth in this Privacy Policy.

4. TO WHOM WE SHARE PERSONAL INFORMATION
We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:

Service Providers/Data Processors
We may perform some of the automatic collection described above through use of (to the extent applicable) cookies, web beacons, unique identifiers and similar technologies which allow us to collect information about the pages and screens you view, the links you click, and other actions you take when using our Services.

Moovit has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (such as AWS), data and cyber security services, payment processors (to the extent applicable), fraud detection and prevention services, data analytics services, App analytics tools including session replay records for usability and functionality monitoring and analysis, services for measuring our Services attribution and the efficacy of our publication and marketing efforts (such as Appsflyer), e-mail distribution and monitoring services, and our business, legal and financial advisors. These service providers may receive or otherwise have access to our Users’ personal information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.

Third Party Services

Moovit may offer you the option to link Moovit to third party services that may be useful to you, such as ride hailing services. Where Moovit detects that an integration may be available (either because a third party service attempts to link to Moovit, Moovit detects an installed service on the device which has an integration option or you request a particular integration), Moovit will ask for confirmation to connect the accounts. If you choose to connect the accounts, Moovit will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts. Moovit is not responsible for the third party service’s use of such data. You can disconnect Moovit and the third party service at any time and Moovit will cease sharing data with that service from the point of disconnection onwards.

Cross Border Data Transfers
We may need to transfer your personal information to countries where we and/or our service providers operate, for instance to the United States of America and other jurisdictions. Such countries may be different from the country in which your information originated and where data protection laws may not be equivalent to, or offer the same protection as, those in your country. By using our Services, you agree to any such transfers. In order to protect your information when being transferred across borders, we put in place agreements with our service providers to ensure a level of privacy consistent with the terms of this Privacy Policy.

With regards to the collection, use of and retention of your personal information which is transferred from the European Economic Area (“EEA”) to the United States or other jurisdictions, Moovit ensures it maintains compliance with all applicable laws in respect of such transfers and uses standard contract clauses approved by the European Commission or other suitable safeguards in our data protection agreements with the relevant service provider to manage such data transfers and protect the privacy and security of your information.

Governmental/Law Enforcement Agencies and Legal Requests or Duties

We may disclose or otherwise allow access to your personal information pursuant to a legal request, such as a subpoena, search warrant or court order, or otherwise in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud or other wrongdoing.

Protecting Rights and Safety

We may share your personal information with others, with or without notice to you, if we have a good faith belief that this will help protect the rights, property or personal safety of Moovit, any of our Users or any member of the general public.

Moovit Subsidiaries and Affiliated Companies

We may share personal information internally within our family of companies for the purposes described in this Privacy Policy. In addition, should Moovit or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of their assets, your personal information may be shared with the parties involved in such event.

For the avoidance of doubt, Moovit may share your personal information in additional manners, pursuant to your explicit approval. Additionally, we may transfer, share or otherwise use anonymized, aggregated or non-personal information in our sole discretion and without the need for further approval.

5. WHERE DO WE STORE USER’S PERSONAL INFORMATION
Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in Israel, a country offering an adequate level of protection in accordance with European Commission Decision 2011/61/EU (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061) of 31 January 2011 for the management of the App platform, in Ireland, and, as necessary, in secured cloud storage provided by our third party service providers.

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our third party service providers that store or process your personal information on our behalf are each committed to keeping your information protected and secured pursuant to this Privacy Policy and prevailing industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

You hereby accept the place of storage and the transfer of information as described above.

6. SECURITY
We take great care in implementing and maintaining the security of Moovit’s Services and our User’s personal information. Moovit employs industry-standard procedures and policies to ensure the security of its Users’ personal information and to prevent unauthorized access, disclosure or alteration of any such information. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres and information access authorization controls. We cannot, however, guarantee that unauthorized access will never occur.

7. COMMUNICATIONS FROM MOOVIT

Service Messages

Moovit may contact you with information regarding our Services or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, including changes to these Terms, transactions performed, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages.

Promotional and Surveys Messages

In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new related services and special opportunities or promotions we think you will find valuable and may also contact you in connection with surveys we conduct with respect to our services or in connection with general public transportation issues, either on our own behalf or on behalf of our partners. We may contact you through e-mail, push notifications, through notices on the Services themselves or through any other contact methods available to us, including with the help of our service providers.

Accordingly, we shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, web chat, marketing calls and similar forms of communication, with your prior written consent.

If you wish not to receive such promotional messages or calls, you may notify Moovit at any time by e-mailing us at support@moovit.com, or by following the “unsubscribe” or “stop” instructions contained in the promotional communications you receive. As for messages we send through push notifications, you may opt-out of receiving such notification by changing your device or App settings.

8. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
If you are an European Union (“EU”), EEA, UK or Switzerland based individual and to the extent entitled under the applicable law of your jurisdiction, you may contact us to exercise your right to access your personal information, to request that we make corrections to your personal information that you have stored with us, to object to any form of processing, or to have such personal information deleted or exported to you or a third party of your choice in a portable copy. To exercise any of the above rights, please send us an e-mail to privacy@moovit.com, or submit your request to our EU representative described in Section 12 below with a courtesy copy to Moovit App Global Ltd., 2 Ilan Ramon St., Ness Ziona, Israel, and we will respond within a reasonable timeframe and in accordance with applicable laws and regulations.

In certain circumstances, you may request that the processing of your data be restricted, in which case Moovit will only keep it for the exercise or defense of legal claims.

We also remind you that, as a User, you may oppose the processing of your data for promotional or advertising purposes at any time.

Furthermore, you have the right to withdraw your consent at any time; however please note that such withdrawal will not affect the lawfulness of the processing based on your consent prior to its withdrawal.

To exercise the rights regarding data protection noted above, or revoke the consents previously given, you may write to Moovit Global App., 2 Ilan Ramon Street, Ness Ziona, IL, or send an email to Moovit at support@moovit.com, indicating “Data Protection” as a reference.

9. HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION
We will retain your personal information for as long as you maintain an Account with us or as otherwise necessary to provide you the Services. We will also retain your personal information as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements and/or to protect our legitimate interests.

Where we no longer need to process your personal information for the purposes set out in this Privacy Policy or following your request to delete your personal information, we will delete or anonymize your personal information from our systems.

10. MINORS

To use our Services, you must be over the age of sixteen (16). Moovit does not knowingly collect personal information from individuals under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of sixteen (16) are not using the Services.

11.CHANGES TO THE PRIVACY POLICY
The terms of this Privacy Policy will govern the use of the Services and any information collected therein. Moovit reserves the right to change this Privacy Policy at any time. We encourage you to re-visit this page frequently to stay informed about your rights and choices. In the event of any substantial change of this Privacy Policy we will provide you with reasonable prior notice via any of the communication means available to us, or by posting a prominent notice of the change on the Site. After this notice period, all amendments to this Privacy Policy shall be deemed accepted and shall become effective. Except if and as stated otherwise, our most current Privacy Policy shall apply to all personal information described in such Privacy Policy.

12. CONTACT US; DATA PROTECTION OFFICER; EU REPRESENTATIVE
If you have any questions about this Privacy Policy or Moovit’s privacy practices, please contact us at privacy@moovit.com

Moovit has appointed a Data Protection Officer for monitoring and advising on its ongoing privacy compliance and to serve as a point of contact on privacy matters for data subjects and supervisory authorities. To contact Moovit’s Data Protection Officer, please email us at privacy@moovit.com.