Privacy Policy - Moove

Published: 24 May 2022

1. Introduction

This privacy policy explains how we handle and use your personal information and your rights in relation to that information. Under data protection laws, Moove UK OPCO Limited is the controller of that information.

Moove UK OPCO Limited (we, our or us) are committed to protecting and respecting your privacy.

This Privacy Policy explains why and how we will use the personal information that we have obtained from you or others, with whom we share it and the rights you have in connection with the information we use. Please read the following carefully.

This policy describes the way we handle and use the personal information that we obtain from all the different interactions you may have with us as a business, including when you hire one of our vehicles, visit our social media pages, visit our website currently located at www.moove.io, or when you contact us.

Moove UK OPCO Limited is the ‘controller’ in relation to the activities described below. This means that Moove UK OPCO Limited decides why and how your personal information is used for these activities. Please see the section at the end of this policy for our contact and legal information.

Moove UK OPCO Limited and other Moove UK affiliate companies:

Moove UK Carco 1 Limited
Moove UK Carco 2 Limited
Moove UK Carco 3 Limited

will be ‘controllers’ in relation to the all drivers' data. References to Moove or "we" in this Privacy Policy in relation to driver data, shall refer to both Moove UK OPCO Limited and Moove UK affiliate companies. This means that Moove UK OPCO Limited and Moove UK affiliate companies decides why and how your drivers personal information is used.

This policy was last updated on the date that appears at the top of this page.

2. Personal information we may collect about you

We receive personal information about you that you give to us when you hire one of our vehicles, that we collect from your visits to our Site and social media pages, and that we obtain from other sources. We only collect personal information which we need and that is relevant for the purposes for which we intend to use it.

Information that you give during general business interactions:

We may collect the following information if you choose to give it to us when you interact with us, visit our Site or social media pages, or when exercising your legal rights.

your name, title, and contact details (email address, telephone number, postal address, social media handle);
your date of birth;
details of any customer accounts you hold with us, including any related memorable information;
any information provided in correspondence with us or sent in forms you submit to us as part of our order for one of our vehicle, or when using our Site or social media pages;
details of your order for one of our vehicles;
your marketing preferences;
your identification information when exercising the rights that you have in relation to our use of your personal information (see further Your rights in relation to your personal information below).

Information that you give/we collect about you as a customer:

When you sign up to hire one of our vehicles, we may collect the following information about you as part of the sign-up process.

your name, title and contact details (email address, telephone number, postal address);
your residence status;
any associated business names and your company registration number;
details of the nature of your licensed hire business;
details of your current PHV licence status;
details of your driving history, including information about any previous accidents, driving disqualifications, or refusals of insurance;
details of the vehicle which you are hiring from us, including make, model, VIN, licence plate details, year of manufacture, and location of storage;
your financial status, including (where applicable), documentary evidence of your income, and any references provided by third party credit reference agencies;
your payment card and/or bank account details.

Information we automatically collect when you visit our Site:

the internet protocol (IP) address of your device and details regarding the type of device and browser software you use to access the Site;
details of your use of our Site, namely traffic data, web logs and statistical data, including where and when you clicked on certain parts of our Site and details of the webpage from which you visited it;
details regarding when and how you consented to receive marketing communications from us (including the time and date you provided your consent) [:and
cookie, pixels and beacon identification information (for more information please see our Cookie Policy on our Site).

Information we collect when you visit our social media pages:

the information you post on those pages;
information regarding your interactions with the content we post; and
statistical information regarding all our followers’ activities (but from which we cannot identify you as we only have access to this information in aggregated form).

Information that you give/we collect about the driver/ vehicle:

your name, title and contact details (email address, telephone number, postal address);
geolocation of the vehicle;
registration number of the vehicle;
vehicle metrics such as speed, acceleration and deceleration, trip mileage and similar information collected by telematics devices and inward and forward-facing cameras which are fitted in the vehicle;
driver's licence, photo and identity documents; and
[data related to communication through the Moove apps.]

Information we collect from dashcam fitted on Moove vehicles

All of our vehicles are fitted with inward and outward-looking dashboard cameras. The Dashcams do not record audio. Please note, your image may also be picked up by the dashcam when you enter or exit the vehicle.
Driver behaviour (score, violations /event)
Video
Compliance and fatigue

3. Use of your personal information

We use your personal information for a variety of reasons. We rely on different legal justifications to use your personal information, depending on the purposes of our use and the risks to your privacy. You will only receive marketing communications from us if you have consented and can opt-out of receiving them at any time. We do not share your personal information with companies that would send their marketing to you.

We use your personal information in the following ways:

3.1 Where you have provided CONSENT

We may use your personal information to contact you via email or SMS (as you have indicated) with marketing information about our products and services (see Marketing for further details) where you have consented for us to do so.

We also process personal information we obtain from optional cookies that we set on our Site based on your consent. For more information, please review our Cookie Policy.

You may withdraw your consent for us to use your information in this way at any time. Please see Your rights over your personal information for further details.

3.2 Where necessary to comply with our LEGAL OBLIGATIONS

We will use your personal information to comply with our legal obligations, including:

to keep a record relating the exercise of any of your rights relating to our use of your personal information;
to handle and resolve any complaints we receive relating to the services we provide; and
to comply with any record-keeping requirements of our regulators.

3.3 Where necessary for us to pursue a LEGITIMATE INTEREST

We may use your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

Moove does not process personal data of users in Nigeria for the purposes of legitimate interest of Moove or other parties.

Uses necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

for analysis and insight conducted to inform our marketing strategies, and to enhance and your experience as a customer and hirer of one of our vehicles;
to tailor and personalise our marketing communications based on your attributes;
to supply your details to social media and other online platforms operated by other companies for them to contact you with our targeted advertising online, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
to identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy on our Site for more information).

Uses necessary for us to respond to market conditions, customer enquiries, and the needs of visitors to our Site and social media pages

to respond to correspondence which you send to us and fulfil the requests you make to us;
to analyse, evaluate and improve our products and services so that they are more useful and enjoyable (we will generally use data aggregated from records relating to many people so that it does not identify you personally);
to respond to correspondence which you send to us and fulfil the requests you make to us;
to undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer;
for product development purposes.

Uses necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

to administer our Site and our social media pages and for internal operations, including troubleshooting, testing, and statistical purposes;
for the prevention of fraud and other criminal activities;
to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
for network and information security in order for us to take steps to protect your information against loss or damage, theft, or unauthorised access;
for cookies that are essential for our Site to function properly. Please see our Cookie Policy for further information;
to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this in order to be able to comply with your request);
for the purposes of corporate restructure or reorganisation or sale of our business or assets;
to conduct background checks before you enter into an agreement to hire a vehicle from us for our protection;
for efficiency, accuracy or other improvements of our databases and systems (for example, by combining systems or consolidating records we hold about you);
to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
to inform you of updates to our terms and conditions and policies; and
for other general administration of your hire agreement with us, including managing your queries, complaints, or claims, and to send service messages to you.

Uses necessary for us to operate our business efficiently and effectively, including obtaining insurance, protecting our vehicle investments and promoting driver safety

to determine compliance with the legal requirements and the suitability of a driver;
to ensure compliance with Moove's insurance obligations (e.g. installing telematics device provided by insurer) or sharing telematics data with the insurer;
using Moove's telematics device and dashcam to capture data relating to accidents or unsafe driving to enable Moove to monitor vehicle depreciation, reduce risks and improve driver safety; and
access to vehicle location data to enable Moove to deter theft and aid recovery of stolen vehicles and to ensure vehicles are kept within contractually agreed territories;
recording vehicle mileage in order to administer the financial aspects of Moove's arrangements with drivers, which will vary by reference to mileage thresholds.

3.4 Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the performance of our CONTRACT

We will use your personal information where this is necessary for us to perform our contract with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that contract, for the following purposes:

to conduct background checks that are mandatory before you enter into an agreement to hire a vehicle from us;
to share information with our third-party providers to ensure we can supply your chosen vehicle package (for example, sharing your insurance and driving history with our third-party underwriters so that we can provide you with insurance (if requested)); and
to process your payment card or bank details when taking payment for your orders or when providing a refund.

3.5 Where our use of your personal information is in your VITAL INTERESTS

We will use your personal information to notify you of any product recall or other safety issues where this is in your vital interest.

4. Disclosure of your personal information by us

We only disclose your personal information outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal information, unless we are legally required to share that information. Any contractors or recipients that work for us will be obliged to follow our instructions. We do not sell your personal information to third parties.

We may disclose your information to our third-party service providers, agents and subcontractors (Suppliers) for the purposes of providing services to us or directly to you on our behalf, including the operation and maintenance of our Site and social media pages. Our Suppliers can be categorised as follows:

RECIPIENT / RELATIONSHIP TO US	INDUSTRY SECTOR (& SUB-SECTOR)
Advertising, PR, digital and creative agencies	Media (Advertising & PR)
Banks, payment processors and financial services providers	Finance (Banking & Payment Processing)
Cloud software system providers, including database, email and document management providers	IT (Cloud Services)
Customer care/services providers	Customer Services (Support)
Delivery and mailing services providers	Logistics (Delivery Service)
Facilities and technology service providers including scanning and data destruction providers	IT (Data Management)
Social media platforms	Media (Social Media)
Insurers and insurance brokers	Insurance (Underwriting & Broking)
Legal, security and other professional advisers and consultants	Professional Services (Legal & Accounting)
Local PHV licensing authorities	Local Authorities (Licensing)
Market and customer research providers	Media (Market Research)
Roadside assistance providers	Services (Roadside Assistance)
Vehicle repair service providers	Services (Repairs)
Website and data analytics platform providers	IT (Data Analytics)
Website and App developers	IT (Software Development)
Website hosting services providers	IT (Hosting)
Wifi and other communication service providers	IT (Telecommunications)
Telematics hardware and software providers	IT (Telematics)

When we use Suppliers, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information safe and secure.

We may disclose the personal information to other third parties as follows:

social media platforms with whom we work (see further Our use of social media below);
any third party who is restructuring, selling, or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, courts, tribunals, or regulators.

We may disclose the necessary driver information (such as name and contact number) to Paua Tech Limited (“Paua”), a third party who provides electric vehicle charging services. Paua is an independet controller of the driver information. All driver information used and processed by Paua, will be in accordance with the Paua Privacy Policy Paua Privacy Policy (31-10-21) (pauatech.com)

We may also receive driver information (including body worn camera footage) from our service provider recovery agents in the course of vehicle recovery.

5. Our use of social media

We use social media platforms in a variety of different ways, including by publishing pages through which you can interact with us and/or other users. Our legal relationship with each platform will vary with the particular way we are using that platform.

We use your personal information using social media platforms in a variety of ways, as follows.

Pages. We use your personal information when you post content or otherwise interact with us on our official pages on Facebook, LinkedIn, Twitter, and other social media platforms. We also use the Page Insights service for Facebook, LinkedIn, and Twitter to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content. Where those interactions are recorded and form part of the information, we access through the Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us;

Targeted advertising. We may sometimes use social media platforms (as well as search engines and third-party websites and other platforms) to deliver targeted advertising to you via those platforms unless you object. You may receive advertising because you have previously interacted with us (such as by visiting one of our websites) or because of your profile on a social media platform on which you have an account. You can find our more by consulting the help pages of the relevant social media platform.

6. Transfers of your personal information outside the Territory of Europe

Except in a limited number of cases, we do not transfer your personal information outside of Europe. Where we do, we take measures to protect your personal information.

Some of the information you provide to us may be transferred to countries outside your country of residence, the UK and European Economic Area (EEA). These countries may not have similar data protection laws to the UK and EEA. For example, if we transfer your personal information to The United Arab Emirates in order to enable us to provide you with the best overall vehicle hire package (for example, insurers and other service providers based overseas.

Where we transfer your information outside of the UK and EEA in this way, we take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected in the ways required by data protection law as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy or access to the relevant documents.

If you use our services whilst you are outside the UK and EEA, your information may be transferred outside the UK and EEA in order to provide you with those services.

7. Security of your personal information

We take the security of your personal information seriously and use a variety of measures based on good industry practice to keep it secure. Nonetheless, transmissions of data over the internet may not be completely secure, so please exercise caution when sharing data with us via email or through our Site. When accessing links to other websites, their privacy policies, not ours, will apply to your personal information.

We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful use, accidental loss, destruction, and damage. When we have provided (or you have chosen) certain security details for any accounts you have with us, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.

Our Site and social media pages may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites‚ so we encourage you to read their privacy policies. We are not responsible for the privacy policies and practices of other websites (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

In addition, where you link to our Site from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

We have employed necessary security measures and data minimization measures to limit and protect the data collected via our telematics devices. This includes, but is not limited to, ensuring that our service providers are unable to identify drivers from the data collected, strictly restricting employee access to data and requiring two-factor authentication for accessing systems that contain driver information.

8. The periods for which we retain your personal information

We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information for a very short period whilst for others we retain it for a period of 7 years after the information is no longer required for business reasons so that we can deal with any legal proceedings that could arise.

We retain your personal information for the following periods:

TYPE OF PERSONAL INFORMATION	WHEN DO WE RECEIVE YOUR PERSONAL INFORMATION?	HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION AFTER WE RECEIVE IT?
Details regarding when you have consented to receiving marketing from us	When you complete the relevant consent form	2 years from the date you complete the form.
Social media handles	When you follow our social media account or page	Until you stop following our social media account or page.
Location and frequency of your visits to our Site (if applicable)	When you create an account on our Site	5 years from the date you create an account.
Information included in any correspondence to our customer care team or via our apps or social media pages	When we receive the correspondence	1 year, but up to 10 years to bring, establish, or defend legal claims.
Details of your vehicle order(s)	When our systems record your order	6 years from the date our contractual relationship ends
Your driver’s and PHV licence details	When our systems record your order	6 years from the date our contractual relationship ends
Opinions /other information you give via customer surveys	When you submit any feedback form to us	2 years if you have completed a service/product feedback questionnaire, then archived. Up to 2 years for all other research
IP addresses and type of device	When you use our Site or any of our apps	1 month from the date of collection
Details of your use of our website, including cookies, pixel, and beacon information	When you visit our Site	Various periods - please see our Cookie Policy on our Site for details of individual expiry periods of cookies.
Telephone call recordings	From when your call is answered by our customer care team until the call ends (except when discussing financial information)	6 months
Driver telematics data		Up to 5 years from the date you collect a vehicle as part of your Moove contract, but up to 10 years if data is required to bring, establish, or defend legal or insurance claims relating to a driving incident.

The only exceptions to the periods mentioned above are where:

you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Your rights in relation to your personal information below);
you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Your rights in relation to your personal information below);
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
we archive the information, in which case we will delete it in accordance with our standard deletion cycle; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

9. Your rights in relation to your personal information

You have a number of rights in relation to your personal information under data protection laws. In relation to certain rights, we may ask you for information to verify your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 month after we have received this information or, where no such information is required, after we have received full details of your request.

You have the following rights, some of which may only apply in certain circumstances:

to be informed about the use of your personal information (this is what this privacy policy sets out to do);
to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
to object to our use of your personal information;
to withdraw your consent to our use of your personal information;
to restrict our use of your personal information;
to have your personal information erased;
to request access to your personal information and information about how we use it;
to electronically move, copy or transfer your personal information in a standard, machine-readable form; and
rights relating to automated decision making, including profiling.

To find out more about each of your rights and to exercise your right to lodge a complaint where you believe your personal information has or is being used in a way that does not comply with data regulations, visit:

United Kingdom
ICO website at www.ico.org.uk/your-data-matters/.

You have the right to lodge a complaint with the UK data protection regulator. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website at www.ico.org.uk/make-a-complaint/, where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
To exercise these rights, please contact us using the details at the end of this policy.

10. Changes to our Privacy Policy

We will email you with changes to this privacy policy if we hold a valid email address for you.

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our Site and/or by contacting you by email at the email address we hold on file for you. Any changes will take effect 7 days after we post the modified terms on our Site or after the date on which we notify you by email, as applicable. We recommend you regularly check our Site for changes and review this policy each time you visit our Site.

11. Contact and legal information

You can contact us with your queries in relation to this policy or for any other reason by post, email or by phone.

To contact us in relation to this policy, including to exercise any of your rights in relation to your personal information, please contact our Data Protection Officer Jonathan Agbeyegbe by post at 100 Avebury Boulevard, Milton Keynes MK9 1FH or by email at dpo-uk@moove.io.

For anything else, including general enquiries, please contact us by post at 100 Avebury Boulevard, Milton Keynes MK9 1FH or by phone using a number on our Site.

Moove UK Opco Limited, with Company Number is 14008700, and registered address is 100 Avebury Boulevard, Milton Keynes, United Kingdom, MK9 1FH

Moove UK Carco 1 Limited with Company Number is 13370893 and registered address is 100 Avebury Boulevard, Milton Keynes, United Kingdom, MK9 1FH

Moove UK Carco 2 Limited with Company Number is 14316677 and registered address is 100 Avebury Boulevard, Milton Keynes, United Kingdom, MK9 1FH

Moove UK Carco 3 Limited with Company number 14597524 and registered address is 100 Avebury Boulevard, Milton Keynes, United Kingdom, MK9 1FH