version 2.2 updated on January 2022
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 Data, 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 notices are often characterized by fragmentary information or unnecessarily complicated language.
We have chosen to adopt the exact opposite approach: we have written our privacy notice 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
Thank you for taking the time to read this Privacy Notice.
We truly 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 which choices you have regarding the use of your data. This Privacy Notice describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.
This Privacy Notice applies from January 3, 2022.
It is divided into several sections; each section deals with a specific topic, so you can easily find the information you are interested in.
SERVICE means the use of www.muvgame.com (our Website) and the MUV mobile application (our App) both operated by MUV S.r.l. S.B.
PERSONAL DATA means any information relating to an identified or identifiable natural person (Data Subject, also referred to as “you” or “your”).
USAGE DATA is the type of Personal Data that is automatically collected, either generated through using our Service, or through the Service infrastructure (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 how any personal data is or is to be, processed. For this Privacy Notice, we are a Data Controller of your Personal Data.
DATA PROCESSORS (also known as our service providers) means any natural or legal person who processes the data on our behalf. We may use the services of various service providers to process your Personal Data more effectively.
PROCESSING means any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
PROFILING means any form of automated processing of personal data to evaluate certain personal aspects relating to a natural person; in particular to analyse or predict aspects concerning that natural person’s health, personal preferences, interests, reliability, behaviour, location or movements.
PSEUDOANONYMISATION means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
MUV S.r.l. S.B. (“us”, “we” or “our”) operates www.muvgame.com (our Website) and MUV mobile application (our App), collectively referred to as our “Services“.
Our Privacy Notice explains how we process, safeguard and disclose information that results from your use of our Services.
We use your data to provide and improve our Services. Unless otherwise defined in this Privacy Notice, the terms used in this Privacy Notice have the same meanings as in our Terms and Conditions (“Terms”).
As the Data Controller, we may process your Personal Data within various contexts. We may process your Personal Data if you use our App (“Users”), and we can process your Personal Data in a general context, e.g. via our Website and social media accounts (“General”).
A: Users
Personal Data:
If you create an account on MUV:
Personalia:
Your first and last name, nickname, email address.
Mobility Data:
Your mobility habits (optional), means of transport you own or use (optional), time of average movement per day (optional), frequent trips e.g. home-to-work or home-to-school travel (optional).
Health Data:
Date of birth (optional), gender (optional), height (optional), weight (optional).
Please note: if you register via your social media account, we also receive your name, profile photo, and other data you disclosed on the relevant social media account.
We use data to:
– Register your account;
– Enable you to access your account;
– Allow you to participate in the game, and use all features of our Services;
Create game results (i.e. sustainability performance based on your means of transport, Personalia, Mobility Data and Health Data);
– Give you access to your personal overview of your game results.
Legal Ground(s):
We may process this data because this is necessary to perform our contract with you (i.e. give you access to an account, including all services related thereto).
We may process Personal Data that you have optionally provided to us because we have your consent to do so.
We may process your Mobility Data and Health Data because we have your explicit consent to process this Personal Data.
Personal Data:
If you use our Services (i.e. start tracking your trips and use all related features thereto):
Mobility Data:
Location data, data on travel time and duration and means of transport used.
Activity data, as detected by the activity recognition services of your device.
Health Data:
Minutes of activity, daily steps (optional), calories and general activity.
Please note: this data is collected through synchronization with other applications or services, including Apple HealthKit and CareKit or Google FIT.
Game Data:
Your points, experience levels, roles, mobility indexes, coins, avatars, ranking positions, 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.
Your community and your eventual sponsors.
Data on your sustainability performance based on your Personalia, Mobility Data and Health Data) and Personal Data you provide through chat functions within the App.
Usage data:
Information on your 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 requests sent, etc.
Information on your device, such as device type (brand and model), operating system (type and version), time zone and language.
We use data to:
– Facilitate the game (i.e. publish game results to you and your friends in order to compete against each other);
– Analyse mobility habits to provide you with personalised advice and an overview of your game results;
– Provide you with rewards;
– Allow you to interact and/or invite other users;
– Take steps to prevent scams and fraud and to ensure that all uses comply with the Terms and Conditions of the Services.
Legal Ground(s):
We may process this data because this is necessary to perform our contract with you (i.e. give you access to an account, including all services related thereto).
We may process your Mobility Data and Health Data because we have your explicit consent to process this Personal Data.
We may process Usage Data because we have a legitimate interest to gain insight into the use of our Services (incl. technical issues) in order to provide and improve our Services.
Personal Data:
If you consent to receive promotional messages within the App:
Personalia
Game Data
Purchase history
We use data to:
– Invite you to promoted competitions;
– Send you personalized offers of our sponsors;
– Send you updates and/or promotional messages with regard to our Services.
Legal Ground(s):
We may process this Personal Data because we have your consent to do so.
Personal Data:
If you subscribe to our paid services or those offered by one of our partners:
Invoice and payment details (e.g. contact details, bank account number, BIC, amount and time of transaction, payment method and applicable taxes).
We use data to:
– Send you invoices;
– Process and administer payments;
– Pay you a refund and/or additional compensation (if there is reason to do so);
– Include in our (financial) administration to comply with tax legislation.
Legal Ground(s):
We may process this Personal Data because we need this Personal Data to perform our contract with you.
We are also legally obligated to process and/or share (some of) this data for/with the national tax authorities.
Personal Data:
If you provide us feedback through the dedicated feature in App or by contacting our customer support team:
Personalia
Personal Data you provide through the feedback feature in App or during the interaction with our support team
We use data to:
– Further develop and improve our Services, such as improving our game features and personal dashboard.
Legal Ground(s):
We may process this data because we have a legitimate interest to contact and assist you based on your comment or question and to improve our Services as a result of the questions and feedback we receive.
Personal Data:
If you take part in surveys, in-app or via our website:
Personalia
Opinions on our services, answers to our questions and experiences that you choose to share with us.
We use data to:
– 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.
– 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 concerning mobility or sustainability.
Legal Ground(s):
We may process this data because we have a legitimate interest to contact and assist you based on your comment or question and to improve our Services as a result of the questions and feedback we receive.
Please note the following with regard to Mobility data:
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.
B: General
Personal Data:
Technical information:
Information on your device type, session date and time, IP address and browser type.
We use data to:
– Communicate in the same language of the browser;
– Adapt our Website to the used device;
– Enable you to use our Website;
– Detect, prevent and address technical issues.
Legal Ground(s):
We may process this data because we have a legitimate interest to do so, i.e. to provide you with a good functioning Website and improve our Website and Services for our users.
Personal Data:
If you contact us via our Website:
Your name, surname, email address and the content of the correspondence between you and MUV.
We use data to:
– Answer your questions and/or handle any complaints;
– Improve our Services as a result of questions and feedback from clients.
Legal Ground(s):
We may process this data because we have a legitimate interest to contact and assist you based on your comment or question and to improve our Services as a result of the questions and feedback we receive.
Personal Data:
If you opt to receive our newsletter via our Website:
E-mail address, name, surname.
We use this data to:
– Send you our updates and keep you informed on promotional campaigns and all our (future) Services.
Legal Ground(s):
We may process this data if you gave us your permission to do so (by subscribing via our Website).
We may send our customers – who subscribed to Services or purchased Products – newsletters because we have a legitimate interest to do so.
In every newsletter, there is a link via which you can unsubscribe.
Personal Data:
Via our social media pages:
Information of visitors who leave a comment or otherwise post something on our social media pages, including the personal data within these comments and/or posts.
We use this data to:
– Contact the visitors in reply to their post and/or comment via our social media pages;
– Process the feedback left on our social media pages.
We may process this Personal Data, because we have a legitimate interest to process this data and because the visitors voluntarily made public such information.
Our social media pages are also controlled by the social medium itself. Please check their own privacy policies, to see how each social medium handles Personal Data:
Instagram: Privacy Policy
Facebook: Privacy Policy
LinkedIn: Privacy Policy
Twitter: Privacy Policy
In addition to the information you give us directly, we receive information about you from others, including:
You can use your social accounts (such as Apple, Facebook or Google) 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.
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 Notice 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 Notice. We disclaim any responsibility for any practices, actions or policies of such third parties and the content or privacy practices of such services.
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 Services. Below are some examples of cookies we use:
Advertising Cookies: they are used to serve you with advertisements that may be relevant to you and your interests.
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, etc.) 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. 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 optimally offer our Service, provide Service on our behalf, perform Service-related activities or assist us in analysing 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 competitions or 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 our payment providers
We may provide paid products and/or services within our Services. 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 Notice. 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.
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 processes, 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 fulfil the purpose for which you provide it; (iv) to include your company or entity logo on our website; (v) with your consent in any other cases.
We store and process your data mainly within the European Economic Area (EEA). However, following the Data Protection Agreement (DPA), your data may be transferred to countries outside the EEA, including storage in a database managed by a 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 for up to 12 months after your last use of the Services. 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, except when this data is used to enhance security or improve our Service’s functionality, or we are legally obligated to retain it for longer periods.
To protect the security of our users, we appTo protect the security of our users, we apply a data retention window of 30 days from account deletion. During this period, your account information will be retained, even if your account is no longer visible within the Service.
Specifically, we will delete your Personal Data 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 24-month continuous inactivity interval, we will also permanently delete anonymous information, unless:
Following Article 32 of the GDPR and the Personal Data Processing Agreement (DPA) that MUV concludes with its service providers, 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 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 Data such as your first name, last name, email address or your travels, but only your nickname and aggregated game data (e.g. the number of points, routes travelled, CO2 saved, modal split or trophies won).
The controller and the joint data controllers/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 compliance 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 concerning 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.
Following Articles 13, paragraph 2, 15, 18, 19, 20 and 21 of the GDPR, you have the following rights:
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be 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.
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 Notice of every site you visit.
We have no control over and assume no responsibility for any third-party sites or services’ content, privacy policies, or practices.
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 16 (“child” or “children”). We do not allow users under 16 years of age to access our platform and we do not knowingly collect Personal Data from anyone under 16 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.
As we are always looking for new and innovative ways to improve your mobility habits and lifestyle, we may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page.
We will notify you by email and/or through the app before any changes become effective and will update the effective date at the top of this Privacy Notice.
You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page.
If you have any questions, doubts or concerns about this Privacy Policy, please contact us at legal@muvgame.com.