Revel Transit

PRIVACY POLICY

Revel Transit Inc.
Last Revised: August 3, 2023

Welcome to Revel!

Revel Transit Inc. (“Revel”, “Company”, “we”, or “our”) owns and operates a “Platform” that includes a website and social media pages (collectively “Website”) and an application, identified as Revel (“App” or “Revel App”) offering electric-powered mobility alternatives (as further defined below, the “Services”). Any individual (“User” or “you”) may access the Website and download the App. To use the Services, a User must be a “Member” as defined in the Moped Rental Agreement and/or Rideshare User Agreement (together the “Service Agreements”).

The purpose of this Privacy Policy is to describe Revel’s practices with respect to the personal information that is collected, used or processed in connection with the operation of the Platform. It also applies to information we may collect directly from you via phone or email communications to us, our Users or Members (collectively “Communications”). We may also collect information which is posted on interactive or public comment sites such as Revel’s Facebook, Instagram, TikTok, and Twitter pages.

This Privacy Policy is attached to, and made a part of, the Revel Terms of Use.

1. Your use of the Platform is governed by the following legal documents:

Terms Applying to Members

Use of the Platform as a Member is subject to this Privacy Policy, as well the legal terms which apply to your use of the Services (“Terms of Use” or “ToU”) and the Service Agreements. If you do not agree to these terms, please do not access or use any part of the Platform, and do not contact our employees or representatives.

Terms Applying to Users who are not Members

Users who are not Members can access all areas of the Website and download the Revel App without restrictions, but they cannot use the Services. You must become a Member to order our Services. If you do not agree to these terms, please do not access or use any part of the Platform, and do not contact our employees or representatives.

Changes

We may change, revise, or add to the Privacy Policy at any time in accordance with applicable laws.

We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and Application. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice of such change by email, in-application message, or other means. Your continued use of the Platform after we provide notice of any modification will mean that you have agreed to be bound by the Policy. This Policy is current as of the date last revised.

2. Definitions

In this document, terms that commence with a capital letter have the same definition as that which is provided in the ToU.

3. Scope

This policy applies to information we collect or receive from third parties:

On the Website, through the Revel Apps, or through use of the Services;
In email, text, social media, and other electronic messages, or Communications between a User and the Company;
In Contributions posted on interactive or public comments sites, such as the Revel pages on social media;
When a User interacts with our advertising and applications on third party websites and services, if those applications or advertising include links to our Platform; and
When a User interacts with our support personnel or other representatives in connection with the use of the Platform.

This policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to, or be accessible from, on, or through the Platform.

4. Children Under the Age of 13

The Platform is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use the Platform, and do not provide or post any information about yourself on or through any part of the Platform, make any purchases through the Website, or use any of the interactive or public comment features of the Platform.

If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us as set forth in the “How to Contact Us” section.

5. Information We Collect and How We Collect It

Information We Collect About You When You Visit Our Website

When you leave comments on the site, we may collect the data shown in the comments form, as well as your IP address and browser user agent string to assist us with SPAM detection. If you choose to sign up for free lessons, join a product waitlist, and/or create an avatar through our Website, we may also collect your email address, first and last names, phone number, and password and associate this information with your avatar. We may use this information to market our services to you. With the assistance of our service providers, we may share this information to provide Services to you. We do not sell this information to third parties.

Information Collected from Users

Users may elect to provide information to us, for example, when filling in a form, survey or questionnaire on our Platform, entering a contest or promotion sponsored by us, joining a product waitlist, or reporting a problem. In that case, we retain copies of the correspondence (including email addresses) and record the nature of the Communication and actions taken, so that we can respond adequately and follow-up as needed. When you call us for assistance with the Services, we may record your communications with our representatives to help us assist you and for quality assurance and employee training purposes.

Communications differ from “Contributions” (see below) in that they are intended to be kept confidential as between Revel and the User.

When a User places an order on our Platform, we collect the following information:

Identification and contact information: name, postal address, e-mail address and telephone number; and
Payment information: payment information of a credit or debit card, including name of the holder, card number, expiration date, CVV or similar code, and billing postal code.

Information Collected from Membership Application

If a User submits an application for Membership with respect to the Moped Service, we collect the following information:

Identification and contact information: name, e-mail address, telephone number, and a selfie (picture you take of yourself with your mobile phone when prompted to do so during the registration process to become a Member);
Driver’s license information: photograph of the front and back of your driver’s license;
Payment information: payment information of a credit or debit card, including name of the holder, card number, expiration date, CVV or similar code, and billing postal code; and
Login information: email and password.

If a User submits an application for Membership with respect to the Rideshare Service, we collect the following information:

Identification and contact information: name, e-mail address, and telephone number;
Payment information: payment information of a credit or debit card, including name of the holder, card number, expiration date, CVV or similar code, and billing postal code; and
Login information: email and password.

Military Discounts; Access Program; Other Discount Programs

If you are a retired or active member of the US armed forces (e.g., Reservist, National Guard, Navy, Air Force, Marine Corps or Coast Guard) you may be eligible to apply for a discount on our Services. We may collect your military ID numbers or other proof of active or retired military status for the purpose of validating your eligibility for this discount program. We may use a third-party service provider to validate and store your personal information.

Similarly, under our access program, we may offer discounts to individuals who are eligible or actively participating in any local, state or federally administered assistance program. In order to verify your eligibility for this program, we may collect additional personal information such as Medicaid/ Medicare Numbers, EBT cards, account numbers, benefit statements and energy bills. The verifying information we collect will vary depending on the type of assistance you receive.

Finally, we may collect other types of additional personal information to verify eligibility for other programs we may implement from time to time on a temporary or permanent basis to provide certain individuals with access to discounted or waived fees. The verifying information we collect will vary depending on the program you elect to apply for.

Booking Information and Subscription Information

With respect to the Moped Service, when a Member selects “Reserve Ride” within the App, or, with respect to the Rideshare Service, when a Member enters a drop-off destination, confirms a pick-up destination, or selects “Request Ride” within the App, we collect and record the booking information generated in connection with the booking. This “Booking Information” includes the time and date when the reservation was made and the location at which the Moped was reserved or Vehicle was requested (includes phone location and Moped/Vehicle location).

Helmet Use Confirmation

With respect to the Moped Service, after a Member selects “Start now” within the App, we ask for and collect pictures of the Member and, if applicable, the Member’s passenger, to confirm helmets are being worn. These “Helmet Selfies” are collected from the Member’s mobile phone.

Information Collected from or about a Member’s Use of a Moped

After a Member submits a Helmet Selfie and, if applicable, the Helmet Selfie of the passenger, we collect information about the use of the Moped, for a variety of reasons, including security of the rider(s), security of the Moped, information required by our insurance, fleet management, planning for support, and for monitoring the need for a battery swap. We may also share this information in a de-identified format to comply with applicable laws. This information is collected both from the Moped itself and from the rider’s mobile phone. This “Moped Ride Information” includes:

Route used and geolocation, provided by a GPS or similar technology installed on the Moped itself;
Trip information and driving data (e.g., ride distance, ride duration, ride speed, Moped lean angle, etc.);
Battery consumption;
Traffic or parking tickets, photos, and similar reports of moving violations;
Sensor data which includes status of kick-stand (up or down) and helmet case and seat latch (opened or closed); and
Location and success of attempts to Pause Ride and End Ride.

Information Collected from or about a Member’s Use of the Rideshare Service

After a Member makes a Reservation in connection with the Rideshare Service, we collect information about the Member’s Reservation, Ride, and the Vehicle in which the member travels for a variety of reasons, including security of the Member and other passengers, security of the Driver and Vehicle, information required by our insurance, fleet management, planning for support, and for monitoring the need for Vehicle maintenance.

Pick-up location, drop-off location, any changes made by Member to pick-up or drop-off locations;
Route used and geolocation of the Vehicle in which Member is riding;
Trip information and driving data for the Vehicle in which Member is riding (e.g., ride duration, speed, battery consumption, etc.); and
Interior and exterior dashcam video footage.

Information Collected from Use of the App

When a User uses the App, we may also collect:

Geolocation of the mobile device;
Information about the functionality of the App that the User uses;
The device unique ID (UID) or a sequence of characters that are unique to the User’s device; and
Information regarding App opens.

Information Collected from a Driver’s Use of the Driver App

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To use the Driver App, a Driver must sign in using their employee login credentials.

When a Driver uses the Driver App, we collect the following information:

Name;
Phone number; and
Geolocation of the mobile device.

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Contributions

You may provide Contributions to be published or displayed (“posted”) on public areas of the Platform or our social media pages. Your Contributions are posted and transmitted to others at your own risk. Although you may be able to set certain privacy settings for such information, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other Users of the Platform with whom you may choose to share your Contributions. Therefore, we cannot and do not guarantee that your Contributions will not be viewed by unauthorized persons.

Information we Collect through Automatic Data Collection Technologies

As a User navigates through, and interacts with, our Platform, we may use automatic data collection technologies to collect certain information about the User’s computer, tablet, mobile device, browsing actions, and patterns, including:

Information about the User’s computer and internet connection, including IP address, device type, device identification number, operating system, browser type (such as Firefox, Safari, Internet Explorer), internet service provider (ISP), and carrier;
For website Users, the referring site or exit pages, and broad geographic location (country, city); and
Details of the User’s visits to our Platform, including traffic data, pages accessed, links clicked, and the time and date of this access.

We may use these technologies to collect information about a User’s online activities over time and across third party websites or other online services (behavioral tracking). The information we collect automatically may be connected to an identified person (i.e., a Member) or an identifier (e.g., a cookie, phone identifier).

6. Cookies and Other Technologies; Third-Party Links

The technologies we use for automatic data collection include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see our “Choices” section.
Web Beacons. Pages of our Platform and segments of our Communications may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an email and record the popularity of certain Content or verify system and server integrity.

These technologies help us to improve our Platform and to deliver a better and more personalized service, which includes enabling us to:

Estimate our audience size and usage patterns;
Store information about Users’ preferences, allowing us to customize our Website according to a User’s interests;
Speed up searches; and
Recognize a User who returns to our Platform.

Third Party Use of Cookies and Other Tracking Technologies

Third parties may use technologies similar to those described above to collect information about Users’ use of our Platform. The information they collect may be associated with other information, including information about Users’ activities over time and across different websites and other online services. Third parties may use this information to provide each User with interest-based advertising.

We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Third Party Links

Our Site and Services may contain links or embedded content (e.g., videos, images, articles, etc.) which may link to third party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

7. How We Use Information

How We Use Information about Users

We use information that we collect about Users or that we receive from Users or third parties:

To present our Platform to each User;
To provide each User with information, services or products that the User requested from us;
To carry out our obligations and enforce our rights arising from any contracts entered into between us and a User;
To allow Users to participate in interactive features on our Platform;
To contact a User about our goods and services that may be of interest to the User, unless the User has opted-out of receiving such communications;
For any other purpose with the User’s prior consent; and
In the aggregate to create statistics about the use of our Platform.

How We Use Information About Members

In addition to the above, we use information that we collect about Members or that we receive from third parties about Members:

To provide a Member with notices about the Member’s account;
To make and confirm the Member’s booking;
To verify the driver’s license;
To verify safe driver criteria;
To verify eligibility to use certain accounts;
To process payments and refunds;
To check for fraud;
To connect with a Member in connection with a specific booking, for example, to confirm that the Member is near a Moped or, in connection with the Rideshare Service, at a pick-up location;
To service requests for wheelchair accessible vehicles in connection with the Rideshare Service
To assist with navigation assistance or itinerary planning;
To provide customer assistance;
To handle debt collection;
To resolve toll, traffic or parking violations;
To process any claims relating to accidents or injuries;
To provide roadside (or remote) assistance;
To locate a Moped that needs servicing or support;
To protect or defend the rights or well-being of our employees, customers or others;
To carry out our obligations and enforce our rights arising from any contracts entered into between the Member and us, including for billing and collection;
To notify Members about changes to the Platform, as applicable;
To allow each Member to participate in interactive features on our Platform.
For any other purpose with the Member’s prior consent; and
In the aggregate to create statistics about the use of our Services by Members, and to improve our Services.

How We Use Information About Drivers

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We use information that we collect about Drivers:

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To authenticate the identity of the Driver for approved use of the Driver app
To connect with a Member in connection with a specific booking, for example, in connection with the Rideshare Service, at a pick-up location;
To provide roadside or remote assistance in connection with the Rideshare Service; and
In aggregate to create statistics about the use of Services by Drivers and to improve our Services.

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8. To Whom We Disclose Information

To Whom We Disclose Information About Users

We may disclose information that we collect or receive from or about Users:

To contractors, service providers, and other third parties we use to support our business and operation, such as to verify driver’s license information, communicate with Users, help enhance the security of our online services, to distribute products purchased on our Website, to process information for safety, business analytics, customer service, marketing, distribution of surveys, and fraud prevention and to process information for credit and debit card transactions;
To social media providers when you access certain social media features through our Platform, we will share information with the social media provider (such as Facebook); that information will be governed by the social media provider’s privacy policy;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, or as part of bankruptcy, or similar proceeding, in which such information is among the assets transferred;
To third parties to market their products or services to you if you have not disabled the use of cookies by these parties through your browser. Data obtained through the short code program, as described in the SMS Terms, will not be shared with any third-parties for their marketing reasons/purposes For more information, see our “Section 9. Choices about How We Use or Disclose Your Information”;
To comply with any court order, law, or legal process, including to respond to any government, law enforcement or regulatory request;
To enforce or apply our Legal Terms;
To any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary or appropriate as a matter of law or regulation, to exercise, establish or protect the rights, property, or safety of Company, its customers, or others; and
When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected activities; this includes exchanging information with other companies and organizations or with law enforcement for the purposes of fraud protection and credit risk reduction.

To Whom We Disclose Information About Members

In addition to the above, we may disclose information that we collect or receive from or about Members:

To our service providers who make parking spaces available for Mopeds on their property or otherwise under their control;
To our insurance companies;
To third parties to enforce or apply our Service Agreements, or other agreements, including for billing and collection purposes;
To third parties who service requests for wheelchair accessible vehicles in connection with the Rideshare Service;
To researchers who study transportation;
To government, regulatory, and law enforcement agencies in the following circumstances:
As disclosed by those agencies if the disclosure is required or permitted by law;
To verify an applicant for Membership or a Member’s driver’s license;
To ensure that an applicant or a Member meets our safe driver criteria;
To take action against illegal activity or violation of our Legal Terms;
If we have a good faith belief that there is an emergency that poses a threat to the safety of the Member or another person; and
As otherwise permitted or required by law, or our permit or contract issued by a government agency or other entity allowing our operations in the relevant territory. In certain cases, we are required to provide such agencies or entities with comprehensive access to trip data, which may be anonymized or de-identified, and may become public record.

To Whom We Disclose Information about Drivers

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To Members, in connection with the Rideshare Service;
To third parties in order to provide towing or other roadside assistance services; and
As otherwise permitted or required by law, or our permit or contract issued by a government agency or other entity allowing our operations in the relevant territory. In certain cases, we are required to provide such agencies or entities with comprehensive access to trip data, which may be anonymized or de-identified, and may become public record.

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9. Choices About How We Use and Disclose Your Information

We strive to provide Users with choices regarding the personal information they provide to us. We have created mechanisms to provide Users with the following control over their information:

Promotional Offers

If we have sent you a promotional email, you may unsubscribe as indicated in the email. You mail also send us a return email asking to be omitted from future email distributions. This opt out does not apply to administrative communications that we make, such as communications regarding the status of your account or to respond to an inquiry that a User makes with respect to our Services.

Targeted Advertising

If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the opt-out pages of the Digital Advertising Alliance or the Network Advertising Initiative provided below.

Please note that some of these opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a User from receiving interest-based ads on that specific browser or device, but the User may still receive interest-based ads on other devices. You must perform the opt-out on each browser or device you use. In addition, some advertisers do not participate in these programs. In this case, you may need to visit their own website.

Digital Advertising Alliance:

http://www.aboutads.info/choices/

http://www.aboutads.info

http://www.aboutads.info/consumers

Network Advertising Initiative:

http://www.networkadvertising.org/choices/

http://www.networkadvertising.org

http://www.aboutads.info/consumers

Google:

To opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out at: https://tools.google.com/dlpage/gaoptout.

Adobe:

Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML 5. To delete or disable Flash Cookies, please visit:

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html, or

https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Accessing and Correcting Your Member Information:

Members can review and change their personal information by logging into the App and visiting their account profile page.

Members can also send us an email to the address provided in the “How to Contact Us” section to request access to, correct or delete any personal information that the Member has provided to us. We cannot delete a Member’s personal information except by also deleting the Member’s account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

10. Retention

We keep contact, payment and driver record information concerning a Member as long as the Member retains an account with Revel. If a Member requests the closure of the Member’s Account, we may retain that information in whole or in part because we have legal, auditing or account obligations or because it is in our archive system and cannot be separated from other information until the archive is updated.

11. Data Security

We have implemented measures to secure personal information in our custody from accidental loss and from unauthorized access, use, alteration, and disclosure.

Any payment transactions will be processed by Stripe and encrypted using SSL technology. Stripe’s privacy policy may be found at: https://stripe.com/us/privacy.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in interactive or public comment areas of the Platform. The information you share in public areas may be viewed by any User of the Platform.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect personal information, we cannot guarantee the security of personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

12. Users Located Outside the United States

If you reside outside the United States, and you choose to use the Platform, provide your information to us, or apply for Membership, your information will be transferred to, processed and maintained on servers or databases that may be located outside of the country or jurisdiction where you are located. The laws of such jurisdiction may not be as protective of your privacy and personal rights as the laws of the country where you reside.

We take reasonable steps to ensure that information about foreign Users is treated and protected similarly as if they were in the United States.

13. Rights of Users Located in California under the CCPA

The California Consumer Privacy Act of 2018 (“CCPA”), to the extent applicable, requires operators of websites or similar services to make certain disclosures to Users who reside in California regarding their rights, specifically:

California Consumer Privacy Act

This section of the Privacy Policy provides additional information solely for California residents, as may be required under the CCPA and, to the extent the CCPA is applicable, applies to their “personal information” as defined in the CCPA, whether collected online or offline. This section of the Privacy Policy, to the extent applicable, prevails over any conflicting provisions of this Privacy Policy with regard to Californians’ personal information.

“Personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. This and any other terms defined in the CCPA have the same meaning when used in this section.

Information We Collect and Disclose

We have collected (or not collected, if indicated below), the categories of personal information below from California residents within the last twelve (12) months. The list below indicates the categories of personal information we disclose for a business purpose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions with you.

Categories of personal information

Name, Contact Information and other Identifiers: Identifiers such as a real name, email address, and address, online identifier, unique device identifier, Internet Protocol (IP) address, account name, driver’s license number, or other similar identifiers.

Do we collect? YES