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LAST REVISED: May 29, 2019

Welcome to Revel!

Revel Transit, Inc. (“Revel”, “Company”, “we”, or “our”) owns and operates a “Platform” that includes a website, located at www.gorevel.com and social media pages (collectively “Website”), an application, identified as Revel (“App”), that facilitates the reservation, rental, support and invoicing of short term electric Moped rentals (“Service”). Any individual (“User” or “you”) may access the Website and download the App. To use the Service, a User must be a “Member” in good standing as described in the Rental Agreement.

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 or other interaction regarding the Platform or the Service that is exchanged via phone, text, emails, and the like between Revel and Users or Members (collectively “Communications”) and Contributions that are 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. Consent

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

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 all provisions of this Privacy Policy, as well as those set forth in the ToU and the Rental Agreement. 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 Service. Use of the Platform as a non-Member is subject to the Terms of Use, and the Privacy Policy except for the “Member Only Provisions” (which are identified as such in the Legal Terms).  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. Unless otherwise stated, all changes will be effective as set forth in the applicable notice of change, and will apply to all access to, and use of, the Platform thereafter.

You should visit this page from time to time to review the then-current Legal Terms because they are legally binding on you. Your continued use of the Platform after we provide notice of any modification will mean that you have agreed to be bound by those Terms. Your use of the Platform will be subject to the Legal Terms in effect at the time of use.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

2. Definitions

In this document, terms that commence with a capital letter have the same definition as that which is provided in the ToU, Section 3.

3. Scope

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

  • On the Website, through the App, 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 Facebook page;
  • 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;
  • When a User interacts with our support personnel or other representatives in connection with the use of the Platform.

It 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 Collected from Users

Users may elect to provide information to us, for example, when filling in a form or questionnaire on our Platform, entering a contest or promotion sponsored by us, 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.

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

Information Collected from Membership Application

If a User submits an application for Membership, we collect the following information:

  • Identification and contact information: name, postal address, 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 information, 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;
  • Login information: email and password.

Booking Information

When a Member selects “Reserve 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 (includes phone location and Moped location).

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

After a Member selects “Start Ride” within the App , 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. This information is collected both from the Moped itself and from the rider’s mobile phone. This “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 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)
  • Location of attempts to Pause Ride and End Ride

Information Collected from Use of the App

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

  • 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.
  • Information regarding App opens.

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 on our Platform, 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)
  • 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

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, including by enabling us to:

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

Third-Party Use of Cookies and Other Tracking Technologies

Some Content may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use technologies similar to those described above to collect information about Users use 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. They may use this information to provide each User with interest-based (behavioral) advertising or other targeted content.

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. For information about how you can opt out of receiving targeted advertising from many providers, see our “Choices” section.

7. How We Use Information

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

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 or services 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 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;
  • 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;
  • For fraud check;
  • To connect with a Member in connection with a specific booking, for example, to confirm that the Member is near the Moped;
  • 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 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;
  • In the aggregate to create statistics about the use of our Services by Members

8. To Whom We Disclose Information

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

To Whom We Disclose Information about Users 

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

  • To fulfill the purpose for which you provide it;
  • To contractors, service providers, and other third parties we use to support our business and operation, such as to help enhance the security of our online services, to process information for business analytics, customer service, marketing, distribution of surveys, and fraud prevention;
  • 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 opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see our “Choices” section;
  • To comply with any court order, law, or legal process, including to respond to any government 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;
  • 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 for the purposes of fraud protection and credit risk reduction;
  • For any other purpose disclosed by us when a User provides the information;
  • With the User’s consent.

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 those who process perform information for credit card processing;
  • To our insurance company;
  • To enforce or apply our Rental Agreement, or other agreements, including for billing and collection purposes.
  • 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
    • As otherwise permitted or required by law.

9. Choices About How We Use and Disclose Your Information

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

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:

Disclosure of Your Information for Third-Party Advertising

If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). You can also always opt-out by sending us an email stating your request as set forth in the “How to Contact Us” section.

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 to respond to an inquiry that a User makes with respect to our Service.

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

California requires operators of websites or similar services to make certain disclosures to Users who reside in California regarding their rights, specifically:

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 to 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

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 the address provided in the “How to Contact Us” section below, 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., 12 Cypress Avenue, Brooklyn, NY 11237
Email Address: [email protected]
Phone: 855-690-9180