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

Nova Mobilitat Compartida S.L. with registered office in Palma de Mallorca, calle Sol 28, nº 3B, CIF number B16576613, registered in the Mercantile Register of Palma de Mallorca in Volume 2380, Folio 64, Section 9, Page 84210, Entry 1, (hereinafter, "Muvon" or "we") is responsible for the processing of personal data belonging to you (hereinafter, the "User(s)" or "you"). Your personal data refers to any information which allows us to identify you, either directly or indirectly, and which is collected through this website or through our mobile applications.

2. What type of personal data is collected?

2.1. Usage data

Browsing Muvon's sites and applications (as well as the use of any third-party applications integrated and/or available therein) involves the communication to Muvon of usage data, which is acquired implicitly during the user's browsing via the Internet communications protocol (hereinafter "Usage Data").

Usage Data includes, among others, the IP addresses or domain names of the devices used by 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 in response, the numerical code indicating the status of the server's response (successful, error, etc. ), the country of origin, the characteristics of the browser and operating system used by the User, the various details of time per visit (for example, the time spent on each page within Muvon) and details about the path followed within Muvon with particular reference to the sequence of pages visited, and other parameters about the operating system of the device and/or the user's computer environment.

Usage data is not collected for the purpose of identifying the User. However, you should note that identification may be possible through further processing and association, as well as with information held by third parties.

2.2. Data communicated by the User

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

Whenever a field is described as "optional" or "non-mandatory" or is not marked with the "*" symbol, this means that the User is free not to communicate the requested data and that the User may continue with the registration despite the absence of this information. The data collected by Muvon for registration are: first name, surname(s), gender, date of birth, driving licence, mobile phone number and address. In order to subscribe to the newsletter, Users will be asked to provide their e-mail address.

The User's personal data will be processed with the User's prior, free and informed consent and solely for the purposes described in this privacy policy.

The explicit, optional and voluntary sharing 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 data communicated, in order to satisfy the request for contact. 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 data?

Through our website and mobile applications, Muvon offers you vehicle rental services by the hour. To this end, Muvon processes 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 processing is necessary to identify you and to prepare and facilitate your future car rental bookings with Muvon. The personal data provided for the registration of your account refers to the personal data that you must provide to activate your account and access our car rental services (this includes, among others: your full name, address, age, driving licence, telephone number, a portrait photo of yourself, and a screenshot of your identity card and driving licence).

If during registration, the user chooses to validate their driver's licence via the Muvon app, the images of the driver's licence together with their portrait that they have created will be collected and processed for the purpose of validating the driver's licence. Wherever possible, the driver's licence data will be read electronically from the driver's licence 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 on the user's driving licence (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 proof that the driver's licence verification has been carried out correctly, and for the period strictly necessary for compliance with the legal obligations to which Muvon is subject.

b) The processing of your reservation:

to confirm your vehicle loan reservation;

to modify or cancel your car loan reservation;

iii. to contact you in relation to your booking (e.g. to provide you with information about your booking, to send you a reminder prior to your arrival and departure, to respond to your questions or suggestions);

to manage your car loan booking (delivery and return of the vehicle);

to manage your invoices;

to manage the payment of arrears;

vii. to manage possible claims;

viii. to manage the recovery of any damage to Muvon vehicles;

to manage your insurance.

to manage access to certain car parks.

The aforementioned processing purposes are necessary for the booking and fulfilment of the terms and conditions of the vehicle loan agreement entered into with Muvon (hereinafter the "Vehicle Loan Agreement").

c) Payment purposes:

This processing is necessary for the performance of the Vehicle Loan Agreement, which is entered into between you and Muvon. For the duration of our business relationship with you, Muvon will retain 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 manner through the Eccocar software platform and in-vehicle technology. As a result, Muvon's fleet is equipped with devices that have internet connectivity.

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

monitor the status, performance and functionalities of Muvon vehicles. For example, this allows Muvon to verify whether the vehicle's battery level is adequate or not, etc. Such information is intended to ensure that each vehicle is in good working order and that it is available for Users' bookings.

to identify possible breaches of the Vehicle Loan Agreement (e.g. to ensure that the User (i) has returned the Vehicle with sufficient charge level, (iii) has returned the Vehicle in the dedicated parking space, etc.).

This processing, 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 Muvon's vehicle loan fleet.

Muvon has installed the geolocation systems to verify the presence of the rented vehicle in the correct exit car park at the start of the rental and to verify the presence of the rented vehicle in the correct return car park at the end of the rental. Such geolocation systems allow Muvon to ensure that the Vehicles are located in their designated area and that they are available for booking.

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

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

Locating the Vehicle in the event of theft or suspected theft;

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

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

This processing, intended to protect the integrity of Muvon's fleet, is based on Muvon's "legitimate interest" and is necessary for the performance of the Vehicle Loan Agreement between you and Muvon.

f) Improving your browsing experience:

The User's Usage Data is processed solely to enable the User's navigation of Muvon's sites and applications from an operational and technical point of view and to improve the User's browsing experience. Based on this Usage Data, Muvon will be able to adapt its website to ensure easier and faster navigation. For example, Usage Data allows us to ensure that the Muvon website is the most relevant to you, depending on your language and country of origin.

g) Improving Muvon's services based on:

customer surveys you have completed;

recording your vehicle loan history to suggest pre-selected options to you when you seek a new booking.

This processing, which aims to better understand the needs of Muvon members and to provide you with personalised features to enhance your experience with Muvon products/services, is based on Muvon's "legitimate interest".

h) Promotional and marketing activities, subject to consent, namely:

sending emails and text messages for special promotions/offers, as well as personalised advertisements and promotions targeted to your specific interest in Muvon's products/services;

the sending of Muvon newsletters;

iii. sending you emails about a booking that you did not complete or sending you a summary of a booking enquiry;

the management of your loyalty programme;

the organisation of promotional competitions/sweepstakes;

the management and updating of Muvon's customer/prospect database.

Direct marketing processing, i.e. any commercial message from Muvon for the purpose of promoting Muvon's services, is subject to your express consent.

As an exception:

- If you are already a Muvon customer and the message refers to similar services you have already purchased, the underlying processing will not be based on your consent but on Muvon's "legitimate interest"; and

- The sending of transactional emails (relating, for example, to the updating of the Car Loan Terms and Conditions, confirmation of your booking, etc.) are necessary for the performance of the Contract between you and Muvon.

i) Statistical purposes:

This processing is for the purpose of carrying out anonymous and aggregated statistical analyses on customer usage data.

j) Management of fines:

This processing is for the purpose of:

transfer to the relevant competent authority responsible for the processing of fines the identity of the driver who has committed a traffic offence;

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

This processing is mandatory by law.

k) The management and updating of a watch list of clients presenting certain contractual risks on the basis of :

payment incidents which have given rise to legal proceedings;

accidents with vehicles or repeated damage caused by Muvon's customer;

iii. accidents or damage caused voluntarily by Muvon's client;

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

This processing, which aims to reduce Muvon's risk exposure in the execution of the Vehicle Loan Agreement, is based on Muvon's "legitimate interest".

l) Processing of personal data for law enforcement purposes:

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

In addition, your personal data may be processed for the purpose of complying with the duties and obligations set out in applicable laws and regulations. The User declares that he/she is aware that Muvon may be obliged to disclose personal data at the request of the competent public authorities.

For your complete information, Muvon carries out certain processing of your personal information through "cookies" and other trackers collected each time you visit the Muvon website. This processing is governed by Muvon's Cookie Policy, which we encourage you to review. You can accept or reject these cookies and other trackers by following the instructions provided in the Muvon Cookie Policy.

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

4.1 Categories of recipients

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

(a) authorised personnel of Muvon and entities of the same group for the purposes described in this privacy policy;

b) Muvon's sub-providers, which are third party service providers that collect data to assist Muvon in providing its products/services to you.

Eccocar Vehicle, user and reservation management.

Amazon Web Services Data storage.

Google Cloud Platform

Branch Monitor platform usage, prevent and correct errors. Statistics and user analysis.

Sentry

Rollbar

Sendgrid Sending email notifications.

Stripe Payment processing.

c) with respect to information processed for the payment of fines, to the relevant competent authority - in the country where the User made the booking - which 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 Data communicated is limited to what is strictly necessary for the provision of our services. The communication of such Data will be limited to what is necessary for Muvon to fulfil its contractual and legal obligations. Whenever Your Personal Data is shared with a third party, Muvon will only do so following the conclusion of a contract with the third party in which the third party undertakes to protect all Personal Data using appropriate security measures and not to use such Personal Data for purposes other than those indicated above.

4.2 International transfers

As necessary or useful to provide you with Muvon's products/services, Muvon will - for the purposes set out herein - transfer your personal data outside the EU to third parties, as indicated in Annex 2.

Depending on the case, some recipients may be in countries that have been recognised by the European Commission as ensuring an adequate level of protection or in countries that have not been recognised as ensuring an adequate level of protection. In either case, Muvon has put in place adequate security measures to protect your personal data in accordance with EU Regulation No. 2016/679 (the "General Data Protection Regulation").

5. How long does Muvon keep your personal data?

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

Purpose Retention period

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

Your vehicle loan reservation;

For the duration of the business relationship.

However, please note that:

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

- information which may prove a right or which must be retained in accordance with a legal requirement (such as invoices or proof of transactions) may be subject to an interim archiving policy for a period of time not exceeding the time necessary for the purposes for which it is retained, in accordance with applicable legal provisions.

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

However, such information that may prove a payment is subject to an interim archiving 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 be used if the transaction is disputed.

Muvon vehicle monitoring through the use of in-vehicle connected devices 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.

Enhancement of your browsing experience and Muvon services based on your preferences Up to 9 months from the end of your business relationship with Muvon.

Promotional and marketing activities For Muvon's customers, up to 3 years from the end of the commercial 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 made by you.

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

Cookies Please check Muvon's Cookie Policy.

Payment of fines For the time necessary to identify the driver (or potential driver) responsible for the offence giving rise to the fine, which may not exceed 45 days after receipt of the fine. However, the relevant information may be retained for a longer period of up to 12 months after receipt of the fine, subject to an interim archiving policy.

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

The management and updating of a watch list of customers who present certain contractual risks, namely:

i. payment incidents that have given rise to legal proceedings

ii. accidents involving vehicles or repeated damage caused by Muvon's customer

iii. accidents or damage caused voluntarily

3 years from the occurrence of the relevant event

iv. use of Muvon vehicles in violation of the Vehicle Loan Terms and Conditions 5 years from the occurrence of this event.

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

You may view and/or update your personal profile at any time, which includes member registration and driver information, through the "My Profile" section accessible on the Muvon app. You can change your password, update or correct your phone number, address and driving licence information and update your payment methods.

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

(a) right of "access": the right to obtain confirmation of whether or not Muvon is processing your personal data and, where applicable, to access such personal data and to obtain further information about the characteristics of its processing;

b) the right of "rectification": the right to obtain the rectification of inaccurate personal data or, taking into account the purposes of the processing, the right to have incomplete personal data completed, including by means of an additional statement;

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

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

e) the right to "object": at any time, a right to object to the processing of your personal data to prevent further processing by Muvon:

where your data is processed for direct marketing purposes;

when your personal data are processed on the basis of Muvon's legitimate interest. In this case, your request will be answered only if you provide Muvon with a description of the particular situation that legitimates your request and unless Muvon can demonstrate overriding legitimate grounds in light of your particular situation.

f) right to "withdraw your consent": where the processing of your personal data is based on your consent, a right to withdraw your consent to the processing of your personal data at any time and to prevent Muvon from further processing of your personal data;

g) the right to "data portability": where 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 an Excel spreadsheet and to transmit such data to a third party.

If you wish to exercise any of these rights, please contact us via the email address for your country, as indicated below in section 8. In addition, in Muvon's marketing and promotional emails 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.

Under Article 77 of EU Regulation No. 2016/679, you may lodge a complaint about the processing of your personal data with the data protection authority in your country if you believe 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 and the app.

In particular, Muvon uses appropriate physical, technical and organisational security measures to prevent unauthorised or unlawful processing, accidental loss, destruction or damage to your personal data.

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

Any credit card transactions you make through Muvon's websites are made through our PCI DSS compliant payment service providers, which guarantee the safety and security of your payment methods and transactions.

8. Who should you contact if you have any questions about the processing of your personal data?

Depending on the purpose of your query

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

b) To exercise your rights (access, rectification, erasure, 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 9 February 2021. In the event of changes to this privacy policy by Muvon, Muvon will identify such changes on this website.

Where a change affects processing carried out on the basis of your consent, Muvon will contact you to obtain a new consent.

[1] If (i) you contest the accuracy of the personal data, (ii) the processing is shown to be unlawful and you object to the erasure of the personal data, but would like to request the restriction of its use, (iii) Muvon no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims.

[2] Or any other commonly used machine-readable format.

[3] The country in which you have your habitual residence, your place of work or the place of the alleged infringement.