Privacy Policy - MUV

Privacy Policy

Our commitment to you

For us at MUV, our users’ privacy is a top priority. Your security is at the heart of the way we design the services and challenges you appreciate so that you can fully trust us and enjoy your gaming experience.

We value the trust you place in us when you provide us with your personal information, and we are well aware that this is not something to be taken lightly.

That’s why we strive to be transparent regarding the way we treat your data. Since we use many of the same online services as you, we know that privacy policies are often characterized by fragmentary information or unnecessarily complicated language.

We have chosen to adopt the exact opposite approach: we have written our privacy policy and the related documents in a simple, direct language, as we hope you will read them and fully understand their content.

Enjoy your reading,

The MUV legal team

“MUV – Mobility Urban Values”
Privacy Policy version 2.1 updated on 29 September 2020

Thank you for taking the time to read it.

We really appreciate your trust in us and we intend to keep that belief intact over time. This means making sure that you understand the information we collect, why we collect it, how it is used and your choices regarding your data. This policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy applies from September 29, 2020.

It is divided into sections; each section deals with a specific topic, so you can easily find the information you are interested in.

  1. Who we are
  2. Where this information applies
  3. Definitions
  4. Types of data we collect
  5. Use of Data
  6. Disclosure of Data
  7. Retention of Data
  8. Security of data
  9. Your rights
  10. Payments
  11. Links to other sites
  12. Protection of minors
  13. Changes to this privacy policy
  14. How to contact us

1 – Who we are

The company responsible for your information under this Privacy Policy, i.e. the data controller, is:

MUV S.r.l. S.B.

Legal representative: Salvatore Di Dio

via Belgio, 8

90146 Palermo

Italy

VAT number: 06837280822

Certified email: muv@pec.it
The contact details of the Data Protection Officer (DPO) are as follows: dpo@muvgame.com.

2 – Where this information applies

MUV S.r.l. S.B. (“us”, “we” or “our”) operates www.muvgame.com and MUV mobile application. For the sake of simplicity, in this policy, we refer to all of these as our “Service”.

Our Privacy Policy governs your visit to www.muvgame.com as well as MUV mobile application and explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“Agreement”).

3 – Definitions

SERVICE means the www.muvgame.com website and MUV mobile application operated by MUV S.r.l. S.B..

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

4 – Types of data we collect

We collect several different types of information for various purposes but always in order to provide and constantly improve our Service to you.

It goes without saying that in order to reward your sustainable travel and allow you to take part in tournaments and challenges we need some specific information, such as your location and your most frequent trips.

We also collect information generated during the use of our services, such as GPS data or your activities when you choose to track yourself with MUV, access logs or information from third parties, for instance when you access our services through a social account (Apple, Google, Facebook, Instagram, etc.). If you wish, you can find more detailed information below.

  1. Personal Data you give us 

While using our Service, particularly when you create an account, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Such information may include, but is not limited to:

  • Email address.
  • Name and Surname.
  • Phone number.
  • Cookies and Usage data.

We may use your Personal Data to send you newsletters, communications containing marketing or promotional materials and other information that may be of interest to you. You may choose at any time to opt-out of receiving any or all of these communications by clicking the unsubscribe link included in each message.

  1. Information you give us

When you use our services you choose to share certain information with us. This include:

  • When you complete your profile, you can also give us further information, such as your date of birth, gender, occupation, height or weight. You can also share some details about your mobility habits such as information about your bike, car or motorbike or even details about your use of public transport or mobility sharing services. Finally, you can upload your frequent trips indicating your departure point, arrival point, weekly frequency and the approximate times of your travels.
  • When you take part in surveys or surveys, in-app or via our website, you give us your opinions on our services, your answers to our questions and your experiences that you choose to share with us.
  • If you submit feedback on one of our services or gaming experience, we collect this information with the aim of improving MUV.
  • If you contact our customer support team, we collect the information you provide during the interaction. Sometimes, we monitor or record these interactions to ensure a high quality of service.
  • When you choose to participate in our challenges, tournaments or contests, we collect the information you use to enrol or participate.
  1. Information we receive from others

In addition to the information you give us directly, we receive information about you from others, including:

C.1 Social Media

You can use your social accounts (such as Apple, Facebook, Google or Instagram) to create and access your MUV account. By doing so you will avoid having to keep in mind yet another username and password and you will be able to share with us some information about your social profiles such as the list of your friends or your city of residence.

C.2 Other partners

We may receive information about you from our partners, i.e. when an electric car-sharing service interfaces with MUV and allows you to provide points for electric car trips, it may provide you with information about the duration of the journey, the route and the start and end times of the service.

Information that is collected by third parties and provided to us is not governed by our Privacy Policy but by that of such third parties, if any. If you have any doubts about the information practices of third parties, please read their Privacy Policy. We disclaim any responsibility for any practices, actions or policies of such third parties and for the content or privacy practices of such services.

  1. Information collected when you use our services

When you use our services, we passively collect certain information (not actively provided by you) through various technologies (e.g. the operating system of the device you are using), information about what features you have used, how you have used them and the devices you use to access our services (“Usage Data”). In particular:

D.1 Information about your use

We collect information related to your activity and the use of our services such as date and time of access, features you have used, searches, clicks, content shown to you, browsing habits, shares, number of people invited to MUV, friend request sent, etc..

D.2 Device information

We collect information from and about the devices used to access our services, including:

  • Hardware and software information such as device type (brand and model), operating system (type and version), device-specific settings and features, version and language, time zones.
  • Information on the device sensors such as accelerometers, gyroscopes and magnetic compasses.

D.3 Tracking information

Whenever you decide to track a sustainable trip with the MUV app you have to activate the tracking function by pressing the “PLAY” button (➤) and selecting the sustainable travel mode from the available ones. Only in this case, your movements will be tracked and we will collect some of your data, including:

  • Your location, which is identified using various technologies including GPS, WiFi, cellular networks, etc..
  • Your activity, as detected by the activity recognition services of your device.
  • Your health data such as minutes of activity, steps, calories and general activity, which is collected through synchronization with other applications or services, including Apple HealthKit and CareKit or Google FIT.
  • Your mobility choices and habits.

As you will understand, monitoring your location is one of the essential conditions for MUV services to work, but at the same time, we would like to emphasise that we only collect location data when you start the MUV app and simultaneously press the PLAY button, and until you press the STOP button.

If you shut down the app after pressing the start button (without pressing the stop one), we will only collect location data if you have authorized your operating system to do so. This will allow you to retrieve your route and points as soon as you reopen the app.

D.4 Game information

By playing MUV, both in the basic game dynamics and in those in which you decide to take part yourself, you will produce a set of data strictly related to the game such as:

  • Your nickname.
  • Your points, experience levels, roles, mobility indexes, coins, avatars, ranking positions, etc..
  • The trips tracked with MUV including all the information detected (coordinates, distances, times, selected mobility systems, etc.).
  • The challenges you have chosen to accept, those completed and the related performance.
  • The tournaments you have chosen to take part in, the teams selected and the related performances.
  1. Tracking Cookies Data

We use cookies and similar tracking technologies to monitor the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We also use other tracking technologies such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to notify when a cookie is being sent. However, if you do not accept cookies, you may not be able to use certain parts of our Service. Below are some examples of cookies we use:

  • Session Cookies: we use them to operate our Service.
  • Preference Cookies: we use them to remember your preferences and settings.
  • Security Cookies: we use them for security purposes.

Advertising Cookies: they are used to serve you with advertisements that may be relevant to you and your interests.

5 – Use of Data

The main reason we use your information is to provide our Service, constantly improving it. In addition, we use your information to help you ensure your security and to deliver game modes that may be of interest to you. 

In particular, we use your information to: 

  1. Provide and maintain our Service.
  2. Notify you about changes or updates to our Service.
  3. Allow you to register your account and then to manage it.
  4. Allow you to use the features of our Service, such as tracking your sustainable travel, participating in MUV competitions (challenges, tournaments, training, etc.), redeeming prizes and interacting with other users. 
  5. Develop new features and game modes of our Service.
  6. Carry out analysis aimed at improving our Service.
  7. Monitor the use of our Service.
  8. Detect, prevent and address technical issues.
  9. Provide you with technical assistance and support when you request it.
  10. Provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc..
  11. Send you promotional communications, invitations to challenges or tournaments, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or requested unless you have opted out of receiving such information.
  12. To conduct analyses aimed at assessing the mobility habits, attitudes or the propensity to change of an individual or a group of users, or to elaborate reports, graphs or plans or plans concerning mobility or sustainability.
  13. Provide you with personalised advice and recommendations to adopt more sustainable and safer mobility behaviours than your current ones, as well as set individual sustainability goals and help you achieve them.
  14. To elaborate and analyse, in an aggregated way by city, region or country, the social, economic and environmental impact produced by MUV and to provide such information to public bodies that request it in order to help them in designing more sustainable mobility solutions and policies.
  15. Make the data (previously aggregated and anonymized) available in open datasets that can be freely downloaded via the website www.muvgame.com.
  16. Fulfil our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and payments.
  17. Comply with any communications required by law or regulatory authorities.
  18. Take steps to prevent scams and fraud and to ensure that all uses comply with the Terms and Conditions of the Service.
  19. In any other way we may describe when you provide the information.
  20. For any other purpose always with your consent.

Please note that the provision of data for the purposes referred to in this paragraph 5 is necessary for the delivery of the services you requested: in case of refusal it will not be possible to complete the registration process and MUV S.r.l. S.B. will not be able to fulfil its contractual obligations.

Informed consent options

Consent n. 1 – Invitations to MUV Challenges and Tournaments

Receiving invitations to competitions, such as challenges or tournaments promoted by MUV or its partners or sponsors and winning the prizes awarded.

Consent n. 2 – Sponsorship Offers

Receiving personalized sponsorship offers from MUV’s partners and sponsors like a real athlete and be rewarded with prizes or discounts.

Consent n. 3 – Promotional communications

Receiving communications regarding updates, promotions or special offers concerning MUV or other related services. We promise to only send you a few messages from time to time.

6 – Disclosure of Data

As one of our objectives is creating a MUVement, a community of MUVers that shares the same values and aims to protect the environment, we share some of your information with other users.

We also share some information with service providers who support us in managing our Service, with partners who want to sponsor our competitions by offering prizes and discounts, with companies or entities that choose to make our Service available to their users and, in some cases, with legal authorities.

In particular, we may share your information: 

With other users

Your public profile information (i.e. nickname, avatar, community, experience level, role, sustainability indexes, points, coins) is visible to other MUV users.

Conversely, your private profile information (CO2 saved, general MUV performance statistics, trophies, calories burned) is only shared with your friends within MUV. In order to turn a MUV user into a friend, you must accept or send a friend request (as long as the selected user in turn accepts it).

With other service providers

We may employ third party companies or individuals (“Service Providers”) to help us offer our Service in an optimal manner, provide Service on our behalf, perform Service-related activities or assist us in analyzing how our Service is used. 

These third parties support us in various areas, including hosting and data management, analytics, customer support, marketing, advertising and security operations. They have access to your Personal Data only to perform these tasks on our behalf and are obliged not to disclose or use it for any other purpose. 

These are therefore subjects who must be identified and indicated as data processing partners, data controllers, data processors or system administrators, depending on the characteristics they assume (e.g. because they access databases or because they manage data storage activities, management of storage media, etc.).

Below is a list of the service providers that currently support us:

With our partners

We may also share information with partners who chose to engage some types of MUV users through a series of customised sponsorship campaigns and reward  the most sustainable ones with prizes and discounts. In this case, any sharing of your information with such partners is regulated by the competition-specific Terms and Conditions document, be it a challenge or a tournament, which you will be asked to read and accept before finalizing your registration.

We follow a rigorous verification process before involving any service provider or entering into a partnership with any partner.

With companies and other entities adopting MUV

In case a company, organization, university or school decides to adopt MUV as an internal tool to encourage safe and sustainable mobility among its users, it must subscribe to one of the available subscription plans. 

By subscribing to the Service, it will have the opportunity to create its own team and invite users to sign up, take part in specific competitions and measure the impact generated in terms of CO2 by all those who decide to join the aforementioned team. 

The entity in this case will assume the role of joint data controller only for the users who will join the team and in relation to the following types of data:

  • A. Personal Data you give us 
  • B. Information you give us
  • D. Information collected when you use our services – with reference only to subcategories:
    • D.3 Tracking information
    • D.4 Game information

Data that falls under category D, and that is collected during the use of the service, is shared with the entity from the moment the user agrees to become part of the team and for the time afterwards. If you decide to leave the team, this information will no longer be shared with the entity.

In addition, the above-mentioned types of data may be processed only for the purposes described in Article 5 of this policy in letters l), q) and t).

The joint data control for entities that decide to subscribe to MUV is therefore limited in relation to:

  • users, who are only those who are part of the entity and who decide independently to join the relevant team;
  • the types of data, which are limited to a subset of user data (personal data and information provided, tracking and gaming data collected during the use of the service);
  • the purposes of the processing, which are essentially limited to internal analysis and communication activities.

For business transactions

We may transfer your information if we are involved, in whole or in part, in a merger, sale, acquisition, disposal, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests from public authorities: (i) to comply with legal process, such as a court order, law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of criminal offences (subject in any event to applicable law); or (iii) to protect the safety of any person.

To enforce legal and negotiating rights

We can also share your Personal Data: (i) where disclosure could mitigate our liability in an actual or threatened lawsuit; (ii) if necessary to protect our legal and negotiating rights and the legal and negotiating rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent or take other action regarding illegal activities, suspected fraud or other unlawful acts.

Other Cases

Finally, we may disclose your information also: (i) to our subsidiaries and affiliates; (ii) to contractors, service providers and other third parties we use to support our business; (iii) to fulfill the purpose for which you provide it; (iv) for the purpose of including your company or entity logo on our website; (v) with your consent in any other cases.

7 – Retention of Data

We store and process your data mainly within the European Economic Area (EEA). However, in accordance with the Data Protection Agreement (DPA), your data may be transferred to countries outside the EEA, including storage in a database managed by sub-processor acting on behalf of the data controller (i.e. MUV S.r.l. S.B.). In this case, the management of the database and the processing of the data is linked to the purposes of the processing and are carried out with appropriate safeguards in line with the provisions of Chapter V of the GDPR. The updated list of data processors and sub-processors can be requested at any time from MUV S.r.l. S.B..

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain your Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to enhance security or to improve the functionality of our Service, or we are legally obligated to retain it for longer periods of time.

To protect the security of our users, we apply a security retention window of three months after your account is deleted. During this period, your account information will be retained, even if your account is no longer visible within the Service.

Specifically, we will delete personal information when you delete your account (after the security retention window), while we anonymize information registered through MUV, such as routes, points, CO2 saved, etc., and keep it for statistical or research purposes, such as calculating the total CO2 saved through our platform or monitoring the change in mobility habits of our users.

Subsequently, at the end of a two-year continuous inactivity interval, we will also permanently delete anonymous information, unless:

  • we are obliged to retain it in order to comply with applicable laws;
  • we are required to retain it to demonstrate our compliance with applicable law (for example, records of consents to our Terms and Conditions, Privacy Policy and other similar consents are retained for five years);
  • there is an outstanding issue, complaint or dispute requiring us to retain the relevant information until resolved; 
  • the information must be retained for our legitimate business interests, such as preventing fraud and improving user security (for example, information may need to be retained to prevent a user who has been banned for unsafe behaviour or security incidents from opening a new account).

8 – Security of Data

In accordance with Article 32 of the GDPR and the Personal Data Processing Agreement (DPA), the data controller, data processors and officers shall take technical, organizational and protective measures to ensure a level of security appropriate to the risk and prevent the loss of data, unlawful or incorrect use, unauthorized access to the user’s account, alteration, disclosure or destruction of Personal Data collected.

Specifically, we store your information in encrypted databases and we maintain the different data separate (i.e., your personal and travel-related data, for example, are stored in two different databases in order to increase security); in addition, all communications between the back-end and front-end of our Service (i.e., between our servers and the App) are carried out through the secure HTTPS protocol; finally, we do not show other MUV users your personal information such as your first name, last name, email address or your travels, but only your nickname and aggregated game data (e.g. number of points, routes travelled, CO2 saved, modal split or trophies won).

The controller and the joint data processors shall take measures to ensure that any natural person acting under their authority who has access to your personal data does not process it except in accordance with the instructions received from the joint data processors, unless they are required to do so by EU or Member State law.

We value your privacy and we do everything we can to protect your data. Unfortunately, however, no system is completely secure, so we cannot guarantee that any information you provide to us in relation to the data we collect through MUV will be immune from unauthorised access by third parties. We are not responsible for events beyond our direct control. 

In particular, your password is an important component of your security system and it is your responsibility to protect it properly. Do not share it with third parties and if you believe that your password or account has been compromised, change it immediately and contact us at help@muvgame.com.

We regularly monitor our systems for possible vulnerabilities and attacks and periodically review our information collection, storage and processing procedures to update our physical, technical and organizational security measures.

9 – Your rights

In accordance with Articles 13, paragraph 2, 15, 18, 19, 20 and 21 of the GDPR, you have the following rights:

  • Access: you can request access to your Personal Data in our possession;
  • Update: you can modify at any time the inaccurate Personal Data concerning you;
  • Delete: you can delete your account at any time;
  • Rectification: you have the right to have your information rectified if that information is inaccurate or incomplete;
  • Opposition and/or withdrawal of consent: you may object to the data processing or withdraw your consent to the processing of your personal data, including profiling, at any time and without giving any reason;
  • Limitation of data processing: you may also ask us to stop using your data, including for promotional and marketing purposes (bearing in mind, however, that in order to use the MUV Service it is necessary to use your data) or you may ask us to limit the processing of your data, allowing us to process them only for storage purposes;
  • Portability: you may receive your data in a structured, commonly used and automatically interpretable format and/or transmit it to another data controller. Upon request, we will send your data to us in a readable and comprehensible format;
  • Permissions from your device: smartphones and other mobile devices have authorization systems for specific types of data and for the management of notifications, such as access to the contact list or location services, as well as push notifications. You can change your device settings to allow or oppose the collection of the corresponding information or the display of notifications. Of course, if you do this, some services may lose full functionality or stop working;
  • Uninstall: it is possible to stop collecting all information from the MUV App by uninstalling it, i.e. following the standard uninstall procedure from the device.
  • Reports, complaints and claims: you can submit a complaint to a Data Protection Authority if you have any doubts about how we process your personal data, or file a judicial action if you believe your rights have been violated. As we will be happy to deal directly with any concerns or requests you may have, please contact us before reaching the authorities.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You can exercise your rights by sending a written request to legal@muvgame.com. We will provide you with the information or take the action you have requested within 30 days.

10 – Payments

We may provide paid products and/or services within our Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their Privacy Policy. These payment processors adhere to the Payment Card Industry Data Protection Standards (PCI-DSS) as managed by the PCI Security Standards Council. PCI-DSS requirements help ensure the secure handling of payment information.The only payment processor we currently work with is Paypal, whose Privacy Policy can be found at this link: https://www.paypal.com/it/webapps/mpp/ua/privacy-full.

11 – Links to other sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

12 – Protection of minors

We recognize the importance of protecting the privacy and safety of children. For this reason, we encourage parents and carers to play an active role in monitoring their children’s online activities and interests.

Our services are not intended for use by children under the age of 17 (“Child” or “Children”). We do not allow users under 17 years of age to access our platform and we do not knowingly collect personal information from anyone under 17 years of age. If you become aware that a Child has provided us with Personal Data, please contact us at help@muvgame.com. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

13 – Changes to this privacy policy

As we are always looking for new and innovative ways to improve your mobility habits and lifestyle, we may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or via app, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14 – Contact us

If you have any questions, doubts or concerns about this Privacy Policy, please contact us at legal@muvgame.com.

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