Revel Transit Inc.
Last Revised: August 13, 2020
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 www.shop.gorevel.com, and social media pages (collectively “Website”), and 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.
1. Your use of the Platform is governed by the following legal documents:
Terms Applying to Members
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. 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.
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.
In this document, terms that commence with a capital letter have the same definition as that which is provided in the ToU.
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 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, and create an avatar through our Website, we may also collect your email address, first and last names, phone number, 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 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. When you call us for assistance with the Service, 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, 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’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.
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.
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).
Helmet Use Confirmation
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 “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 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.
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:
- 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 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 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 (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.
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, 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 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 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 Rental Agreement, or other agreements, including for billing and collection purposes;
- To researchers who study transportation; and
- 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.
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:
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 Service.
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:
Network Advertising Initiative:
Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML 5. To delete or disable Flash Cookies, please visit:
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.
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.
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
“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 chart also lists 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
Do we collect?
Do we disclose for a business purpose?
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.
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.
Protected Classifications: Characteristics of protected classifications under California or federal law such as sex or age.
Purchase History and Tendencies: Commercial information including records of moped reservations and rentals.
Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including faceprint
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.
Geolocation Data: Precise geographic location information about a particular individual or device.
Audio, Video and other Electronic Data: Photographs.
We obtain the categories of personal information in the chart listed above from the following categories of sources:
- Directly from you, including when you register or subscribe for accounts or features on the Website or the App, make a reservation or rental, and complete surveys;
- Through the Website, including through cookies, our servers, the App, and other automated technologies;
- From third parties, including our marketing partners; and
- From public records, including state departments managing driver’s licenses.
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 Service, 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:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting and selling their personal information;
- categories of third parties/with whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose;
- categories of personal information collected; and
- categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
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:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. This includes Communications allowing us to address any follow-up questions or issues, as well as payment information preserving our ability to charge you for fines or fees you might owe in accordance with our Rental Agreement.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. This includes any information indicating or relating to possible illegal activities, fraudulent, fake or stolen driver’s license, payment information or other User data, possible User or Member impersonation, account sharing, and the like.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation, including to respond to any government, law enforcement or regulatory request, and any data sharing obligations toward municipalities or other government agencies.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it. This includes retaining for insurance, claims processing, compliance and potential litigation purposes, and sharing with our insurance providers: (1) information related to your use of a Moped or the Platform, which use may have been related to an accident or injury; (2) information relating to your identification, driver’s license and driving history; (3) and contact information allowing us to communicate with you about those instances.
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 [email protected] or calling us at 855-690-9180.
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.
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.
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 [email protected], 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
Mailing Address: Revel Transit Inc., 68 3rd Street, Brooklyn, NY 11231, Attention: Legal
Email Address: [email protected]