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Privacy Notice of Move Platform

Effective date: 15th August 2023

1. Overview

This notice applies to users of Move's services, including users of Move's apps, websites, features, or other services.

This notice describes how Move and its affiliates collect and use personal data. This notice specifically applies to Riders, Drivers and any other cooperatorsrelated to our platform using our services.

All those subject to this notice are referred to as “users” in this notice.


2. The Data We collect

2.1 Data provided by users. 

User profile: We collect data when users create or update their Move accounts. This may include their name, email, phone number, login name and password, address, profile picture, driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers, emergency contact information, user settings, and evidence of health or fitness to provide services using Move apps. We may use the photos submitted by users to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”

Payment information: We collect payment information when users use bank cards (including debit cards and credit cards) to fulfill payments, whether proactive or automatic, paying charges for Move services. The payment information we collect includes but not limited to account balance information, transaction information, banking information (including related payment verification information), bank card number, bank name, bank reserve mobile phone number, credit card number, card holder’s name, the amount to be paid, and any such information in related to payment on Move platform. When you open your Move Wallet as your payment method, we will collect those informations aforementioned.

Background check and identity verification: We collect background check and identity verification information for drivers. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Move's behalf.

User content: We collect the information users submit when they contact Move customer support, provide ratings or compliments for other users or restaurant partners. This may include feedback, photographs or other recordings collected by users.

2.2 Data created during use of our services. 

Location data (driver): Move collects this data when the Move app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. Move collects driver location data, and links location data collected during a trip with their rider’s account, even if the rider has not enabled us to collect location data from their device. This enables us to offer services to the rider like receipt generation and customer support.

Location data (riders): We collect precise or approximate location data from riders’ mobile devices if they enable us to do so. Move collects this data from the time a ride is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to improve pick-up locations, enable safety features, and prevent and detect fraud.

Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.

Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

Communications data: We enable users to communicate with each other and Move through Move's mobile apps and websites. Move may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

2.3 Data from other sources. 

1) User feedback, such as ratings, feedback, or compliments.

2) Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.

3) Move account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. 

4) Users or others providing information in connection with claims or disputes.

5) Move business partners through which users create or access their Move account, such as payment providers, credit card banks, social media services, third party security cooperator or apps or websites that use Move's APIs or whose APIs Move uses.

6) Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.

7) Insurance, vehicle, or financial services providers for drivers.

8) Publicly available sources.

9) Marketing service providers.

10) Move may combine the data collected from these sources with other data in its possession.


3. How we use personal data

Move uses the data it collects for purposes including:

3.1 Providing services and features. Move uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to: Create and update users’ accounts; Verify drivers’ identity, background history, and eligibility to work; Enable transportation, deliveries, and other services; Offer, process, or facilitate payments for our services; Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services; Track and share the progress of rides or deliveries; Enable features that allow users to share information with other people, such as when riders submit a compliment about a driver, refer a friend to Move, split fares; Enable features to personalize users’ Move accounts, such as creating bookmarks for favorite places, and to enable quick access to previous destinations. Enable Accessibility features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing drivers to alert their riders of their disabilities, allow only text messages from riders, and enable receipt of flashing trip request notifications instead of sound notifications on their mobile device; Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

We will carry out security linkage with third-party professional teams by identifying and sharing specific security data to realize the function of one-click alarm and quick alarm.

3.2 Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

Screening riders, drivers before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or riders.

Using data from drivers’ devices to help identify unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. 

3.3 Customer support. Move uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to: Direct questions to the appropriate customer support person; Investigate and address user concerns; Monitor and improve our customer support responses and processes.

3.4 Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

3.5 Enabling communications between users. For example, a driver may message or call a rider to confirm a pickup location, a rider may contact a driver to retrieve a lost item.

3.6 Marketing. Move may use the data we collect to market our services to our users. This includes sending users communications about Move services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of Move's services, and user preferences and settings.

3.7 Non-marketing communications. Move may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Move or its partners.

3.8 Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Move's services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.


4. Cookies and third-party technologies

Move and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Move uses cookies and similar technologies for purposes such as:

1) Authenticating users;

2) Remembering user preferences and settings;

3) Determining the popularity of content;

4) Delivering and measuring the effectiveness of advertising campaigns;

5) Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services;

6) We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.


5. Data sharing and disclosure

Some of Move's products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Move may share the data we collect:

5.1 With other users. This includes sharing: Riders’ first name, rating, and pickup and/or dropoff locations with drivers;Riders’ first name with other riders in a carpool trip;Riders in carpool trips may also see the dropoff location of the other riders; For those who participate in Move's referral program, we share certain personal data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

5.2 At the user’s request. This includes sharing data with: Other people at the user’s request; Move business partners. 

5.3 With the general public: Questions or comments from users submitted through public forums such as Move blogs and Move social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

5.4 With the Move account owner: If a user requests transportation or places an order using an account owned by another party, we may share their order or trip information, including real-time location data, with the owner of that account. 

5.5 With Move subsidiaries and affiliates: We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

5.6 With Move service providers and business partners: Move provides data to vendors, consultants, marketing partners, research firms, payment providers, cooperation banks, third-party security guarantee institutions and other service providers or business partners. We also provide users’ information to banks cooperated with us for fraud monitoring, prevention or prohibition of illegal activities.

5.7 For legal reasons or in the event of a dispute: Move may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

5.8 With consent: Move may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.


6. Data retention and deletion

Move retains user data for as long as necessary for the purposes described above.

Move retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data.


7. Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Move's legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

7.1 To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

1) User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, orders, and accounts; and enable users to make payments or receive earnings;

2) Background trip information, which is used to verify an applicant’s eligibility to be a driver ;

3) Driver person location data, which we use to track trips and assist with navigation;

4) Usage data, which is necessary to maintain, optimize, and enhance Move's services, including to determine incentives, connect riders and drivers, and calculate costs of trips and driver earnings;

5) Transaction information;

6) Information relating to customer support.

7.2 For purposes of the legitimate interests of Move or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of Move's apps. We also use usage data to prevent matching of riders and drivers for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other users).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Move's Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

7.4 To fulfill Move's legal obligations

For example, Move is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’ trips and deliveries, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

Move may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. Move may also share information with public health authorities where required or permitted by law. 

7.4 With consent

Move may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.


8. Updates to this notice

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Move apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

After such notice, use of our services by users will be understood as consent to the updates to the extent permitted by law.

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