PRIVACY POLICY
Revel Transit Inc.
Last Revised: July 19, 2021
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, Rideshare User Agreement, and/or eBike Subscription 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, 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:
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:
Information Collected from Membership Application
If a User submits an application for Membership with respect to the Moped Service, we collect the following information:
If a User submits an application for Membership with respect to the Rideshare Service, we collect the following information:
If a User submits an application for Membership with respect to the eBike Service, we collect the following information:
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).
With respect to the eBike Service, when a Member subscribes to the eBike Service within the App, we collect and record the subscribing information provided by the Member in connection with the subscription. This “Subscription Information” includes the date and time the subscription was made, the location of delivery for the eBike and Supplemental Equipment, and any special instructions a Member may provide.
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:
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.
Information Collected from or about a Member’s Use of an eBike
After a Member returns an eBike or submits an eBike for repair, we collect information about the use of the eBike, for a variety of reasons, including security of the rider, security of the eVike, information required by our insurance, fleet management, planning for support, and for monitoring the need to further maintain, repair, or replace the eBike or Supplemental Equipment. We may also share this information in a de-identified format to comply with applicable laws. This information is collected from the eBike itself. This “eBike Use Information” includes:
Information Collected from Use of the App
When a User uses the App, we may also collect:
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:
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:
These technologies help us to improve our Platform and to deliver a better and more personalized service, which includes enabling us to:
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:
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:
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 Whom We Disclose Information About Members
In addition to the above, we may disclose information that we collect or receive from or about Members:
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/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
Do we disclose for a business purpose? YES
Customer Records: Paper and electronic customer records containing personal information, such as name, address, credit card number, debit card number, telephone number, driver’s license or identification card copy and number.
Do we collect? YES
Do we disclose for a business purpose? YES
Protected Classifications: Characteristics of protected classifications under California or federal law such as sex or age.
Do we collect? YES
Do we disclose for a business purpose? YES
Purchase History and Tendencies: Commercial information including records of use of the Services.
Do we collect? YES
Do we disclose for a business purpose? YES
Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including faceprint
Do we collect? YES
Do we disclose for a business purpose? YES
Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any Revel Websites, applications or other online services.
Do we collect? YES
Do we disclose for a business purpose? YES
Geolocation Data: Precise geographic location information about a particular individual or device.
Do we collect? YES
Do we disclose for a business purpose? YES
Audio, Video and other Electronic Data: Photographs.
Do we collect? YES
Do we disclose for a business purpose? YES
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use and/or disclose the personal information identified in the chart above to provide and improve our Platform and Services, to communicate with you, for our own marketing and promotional purposes.
Your Rights and Choices
The CCPA, to the extent applicable, provides California residents with specific rights regarding their personal information. This section describes your CCPA rights, to the extent applicable, and explains how to exercise those rights, at no-charge.
Requests to Know
Under the CCPA (to the extent applicable), California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about you in the prior 12 months and to have this information delivered to you, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.
Under the CCPA (to the extent applicable), California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
California residents may make Requests to Know up to twice every 12 months.
Requests to Delete
Under the CCPA (to the extent applicable), you have the right to request that we delete any of your personal information that we collected from you, unless an exception applies. We may deny your deletion request or retain certain information if retaining the information is necessary for us or our service provider(s) to:
Do Not Sell My Personal Information
Under the CCPA (to the extent applicable) you have the right to opt-out of sale of your personal information to third parties. Revel does not sell your personal information as we understand that term to be defined by the CCPA and its implementing regulations.
Exercising Access, Deletion, and Do Not Sell Rights
To exercise the access, and deletion rights described above, to the extent applicable, please submit a request to us by emailing us at support@gorevel.com or calling us at 855-690-9180.
Authorized Agent
You may designate an Authorized Agent to exercise on your behalf the access, and deletion rights, described above. In order to allow you to verify the authenticity of your designation of the Authorized Agent, you will be required to provide a written and signed statement granting the Authorized Agent permission to make the relevant request, as well as a copy of your driver’s license for us to match against our records and verify your identity.
Non-Discrimination
We do not discriminate against you for exercising your rights or offer you financial incentives related to the use of your personal information.
Shine the Light
Under California law, a business that has an established business relationship with an individual, and has, within the immediately preceding calendar year, disclosed specified information that is primarily used for personal, family or household purposes to third party for the third party’s direct marketing purposes, must disclose to its California Users, upon request, the identity of any such third party, along with the type of information disclosed. You can contact us as provided in the “How to Contact Us” section. Please note that under California law, businesses are only required to respond to a User’s request once during any calendar year.
California Minors
Under the CCPA (to the extent applicable), if you are a California resident under the age of 18 and you have provided information or content online, you may request that we remove content or information that you posted on the Website or stored on our servers by (a) submitting a request in writing to support@gorevel.com, and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.
Complaints to California Department of Consumer Affairs
Under California Civil Code Section 1789.3, California Users are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
14. How to Contact Us
All feedback, comments, questions, complaints, requests, and other communications about this Privacy Policy and our privacy practices, should be directed as follows:
Mailing Address: Revel Transit Inc., 68 3rd Street, Brooklyn, Suite 45, NY 11231, Attention: Legal
Email Address: support@gorevel.com
Phone: 855-690-9180