Privacy Statement

At MOIA AMERICA LLC (“MOIA,” “we,” “our,” or “us”), we value your privacy. This Privacy Statement describes how we process personal information (i.e., information that identifies or is reasonably linked to a specific individual). 

This Privacy Statement applies to personal information (we collect through our websites, social media, when you use a MOIA mobile application (which may include mobile applications that we develop or white label for customers) or other online interactions and communications such as email (collectively, our “Digital Properties”); ride in our MOIA vehicles; participate in an in-person event; or through other online and offline interactions (collectively, the “Services”).

This Privacy Statement does not apply to information about our current/former personnel, job applicants, or others who interact with us for employment-related purposes. It also does not apply to information we process to provide services to business customers as a data “processor” or “service provider.” In those cases, we do not control our partners’ privacy practices and encourage you to review such partners’ privacy disclosures, which apply instead of this Privacy Statement. 

Table of Contents

1. From What Sources Do We Collect Information?
2. What Information Do We Collect?
3. How Do We Use Your Information?
4. To Whom Do We Disclose Your Information?
5. Cookies
6. Security and Retention
7. Changes to this Privacy Statement
8. Supplemental State Privacy Disclosures
9. Contact Us

1. From What Sources Do We Collect Personal Information?

We may collect certain information from or about you from the following sources:

1. Directly from you, such as when you contact us, create an account, provide us with feedback on our mobile applications, or complete forms on our Digital Properties.
2. Automated data collection. We may automatically collect information about you and your device, such as through cookies, pixels, tags, scripts, server-side tools, software development kits in our mobile applications (“SDKs”), and similar technologies (collectively, “Cookies”) when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
3. MOIA vehicles, such as through internal cameras and microphones, as well as external cameras, microphones, LiDAR, and radar.
4. Third-party sources, such as business partners with whom we provide autonomous ride services and other business partners.

2. What Information Do We Collect?

We may collect the following information depending on how you interact with us:

1. Identifiers, such as your name, email address, telephone number, account name, and device identifiers (such as IP address and cookie IDs).
2. Records about you, such as your feedback on rides.
3. Demographic information, such as age.
4. Professional or employment-related information, such as job sector, organization, or other professional information (about individuals who interact with us in a business-to-business context).
5. Geolocation data, such as your approximate location based on your IP address.
6. Commercial information, such as records of and information about your trips and details about your trip history.
7. Internet or other electronic network activity information, such as information about how you interact with our vehicles and Digital Properties and information about your mobile device.
8. Sensory data, such as video and audio recorded by cameras on the interiors and exteriors of our vehicles.
9. Inferences drawn from any of the information we collect about you.
10. Sensitive Personal Information, including:
    1. Precise geolocation, such as requested pickup and drop-off location and actual pickup and drop-off location.
    2. Account log-in information.

We may combine information that we receive from the sources described in this Privacy Statement and use or disclose it for the purposes identified below.

3. How Do We Use Your Personal Information?

We use your personal information for the following purposes:

1. To provide you with the Services, such as to administer and provide rides in our vehicles; make our mobile applications available to you; create and manage user accounts; provide customer support; communicate with you about our Services; and authenticate users of our Services.
2. For our own internal business purposes, such as to evaluate the usage, performance, and safety of our vehicles and Services; maintain internal records; auditing; debugging; and quality assurance.
3. For our internal research and product improvement purposes, such as to improve our vehicles and their autonomous driving capabilities; improve our mobile applications and other Digital Properties; improve our ride delivery platform and other backend services; diagnose, repair, and track service, safety, and quality issues across our Services; and design new products and services.
4. For marketing, such as marketing our products and services and exploring potential partnerships (for individuals we interact with in a business-to-business context). For example, we may send you promotional materials, newsletters, surveys, questionnaires, or information about events or webinars. You can unsubscribe from marketing via the link in marketing emails, by responding “STOP” to the text message, or by contacting us using the information in Section 9 (Contact Us) below.
5. For legal, safety or security reasons, such as to comply with legal requirements; investigate incidents; respond to claims; exercise or defend legal claims; protect the safety, property, or rights of MOIA, the Volkswagen Group family of companies, our customers and users, and other third parties; or to prevent and detect fraud or misuse of the MOIA vehicles or Services.
6. In connection with a corporate transaction, such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.

We may use personal information to develop and improve algorithms, artificial intelligence, or machine learning tools and models in connection with all the above processing activities. We may also use anonymized, de-identified, or aggregated information for any purpose permitted by law. To the extent that we de-identify information, we will not attempt to re-identify it except in compliance with applicable law.

4. To Whom Do We Disclose Your Personal Information?

We may disclose your personal information to the following recipients:

1. Within the Volkswagen Group family of companies. We may disclose your information to Volkswagen Group parents, corporate affiliates, subsidiaries, business units, and other companies that share common ownership. 
2. Our service providers. We may disclose your information to service providers that work on our behalf to help provide you with the Services, such as analytics providers, providers of focus group and user testing services, data and web hosting providers, marketing support providers, software service providers, companies that provide business support services, and IT providers.
3. Ride-sharing partners. We may disclose your information to companies that we partner with to deliver ride-sharing services, such as ride-sharing platform providers, mobility services, and business customers to whom we provide ride-sharing services. We do not control the practices of our ride-sharing partners and you should consult their privacy notices for questions about their privacy practices.
4. Other third parties, such as companies that help us develop autonomous vehicle technologies and Cookie providers. We do not control the practices of such third parties and you should consult their privacy notices for questions about their privacy practices.
5. Others for legal, security or safety purposes. We may disclose your information to third parties, law enforcement, or other government agencies to comply with law or legal requirements; demonstrate our commitment to safety; enforce or apply our policies and other agreements or those of the Volkswagen Group family of companies; or protect the rights, property, or safety of us, the Volkswagen Group family of companies, our customers and users, or other third parties.
6. To other companies in connection with a corporate transaction. We may disclose your information if some or all of our assets are acquired by another company, including through a sale in connection with bankruptcy, in which case we will disclose the information we hold to that company. 

5. Cookies

Our Digital Properties and authorized third parties use Cookies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about:

• The types of Cookies we use
• The purposes for which we use these Cookies
• The types of information we collect using these technologies
• How we disclose or make information available to others
• Choices you may have regarding these technologies

A.       Types of Cookies

We and the third parties that we authorize may use:

• Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit our Digital Properties.
• Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier. In addition to the uses described below, these technologies provide information about interactions with our Digital Properties (including communications such as email we may send to you). In contrast to cookies, which are stored on a user's device hard drive, pixels, web beacons, and tags are embedded invisibly on our Digital Properties.
• Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
• Embedded scripts and SDKs, which allow us to build and integrate custom experiences on our Digital Properties. Embedded scripts are temporarily downloaded onto your device from our web server, or from a third party with which we work, and are active only while you are connected to our Digital Properties and are deleted or deactivated thereafter.
• Server-side technologies, which collect and process information about you and your interactions with our Digital Properties on our servers and transmit that data to third parties (such as through an API connection).

We may use both first-party Cookies, which are set by us, and third-party Cookies, which are set by other parties. Some of the Cookies we use may last solely for your browsing session and are deleted when you close your browser, while others are persistent and stored after you close your browser.

B.       Purposes for Using Cookies

We and authorized third parties use these technologies for purposes including:

• Strictly Necessary, such as determining when you are signed in, determining when your account has been inactive, and for troubleshooting and security purposes (including preventing fraud and malicious behavior);
• Functionality/Personalization, such as remembering preferences and pages you have viewed in order to enhance and personalize your experience when you visit our Digital Properties; and
• Performance/Analytics, such as analyzing how our websites are used to understand which pages within our Digital Properties are most popular and how users move around them. For example, we use Google Analytics to help us improve the user experience. Google Analytics may use Cookies to perform its services. To learn how Google Analytics collects and processes data, please visit https://policies.google.com/technologies/partner-sites.

C.      Types of Data Collected

These Cookies collect data about you and your device listed above in Section 2 (What Information Do We Collect?). Examples of common data elements include your IP address, location (both approximate and precise), cookie ID, device ID, click ID, operating system, device type, device settings and other device information, browser used, browser history, search history, pages viewed, search queries, login information, information entered into webforms, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).

D.      Disclosures of Data

We may disclose information to third parties or allow third parties to directly collect information using these Cookies on our Digital Properties, such as providers of services integrated into our Digital Properties, companies that provide analytics, security providers, and others that help us operate our business and Digital Properties.

E.       Your Choices

You may have control over how we use Cookies. Please be aware that if you disable the use of Cookies, the functionality of our Digital Properties may be negatively impacted, and certain areas or features may not display or work correctly. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your Cookies, you may need to repeat this process for each computer, device, or browser.

• Browser Settings. If you want to disable the use of certain specific Cookies or remove them from your device, you can disable or delete them using your browser settings. Please be aware that not all Cookies can be disabled or deleted through browser settings. Please refer to your browser’s Help instructions to learn more about how to manage Cookies, or use the following links for instructions for commonly used browsers: Apple Safari; Google Chrome; Microsoft Edge; and Mozilla Firefox.
• Do Not Track. Some web browsers may include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your preference to not have data about your online browsing activities monitored and collected over time and across websites. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As a result, we do not currently respond to DNT browser signals or similar mechanisms.

6. Security and Retention

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.

Your information will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your information to provide you with the services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety, and security of our Services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as to demonstrate our business practices and contractual obligations or provide you with information about our products and services in case of interest. 

7. Changes to this Privacy Statement

From time to time, we may update this Privacy Statement by updating this page and by displaying the date of the last update at the top of the page. We encourage you to periodically check this page to learn about the information we collect, use, and disclose.

8. Supplemental State Privacy Disclosures

This section provides additional information on how we process personal information and privacy rights that may be available to you. It only applies to residents of certain states (such as California).

You may have certain rights, subject to legal limitations, regarding the collection, use, and disclosure of your personal information. You can submit a request by emailing us at privacy@moiaamerica.com.

1.        Right to Delete. You may have the right to request that we delete personal information we maintain about you. 

2.        Right to Correct. You may have the right to request that we correct inaccurate personal information we maintain about you.

3.        Right to Know. You may have the right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting or disclosing the personal information, and to whom we have disclosed your personal information and why. You may also request that we provide you the specific pieces of personal information that we have about you.

We do not “sell” or “share” personal information or disclose information for targeted advertising, as such terms are defined under applicable law.

In accordance with applicable law, we will not discriminate or retaliate against you for exercising your privacy rights.

Verification: Upon receiving your Right to Know, Right to Delete, or Right to Correct request, we will verify your identity. We may request additional information to verify your identity, such as your name, email address, state of residence, and account information. We may also use other verification methods as the circumstances dictate. We may deny your Right to Know, Right to Delete, or Right to Correct request if we cannot verify your identity.

Authorized Agents: Authorized agents may submit requests on your behalf by emailing privacy@moiaamerica.com. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable law. For requests that we verify, we may ask you directly to verify your identity or confirm that you provided the agent permission to submit the request.

Appeals: If we do not grant your request, you may have the right to appeal. To submit an appeal, contact us at privacy@moiaamerica.com.

Sensitive Personal Data: We only use and disclose Sensitive Personal Data for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.

9. Contact Us

Should you have other questions or concerns about this Privacy Statement, please email us at: privacy@moiaamerica.com.

And by mail at:
Office of General Counsel
Volkswagen Group of America
Attn: Privacy Office
1950 Opportunity Way
Reston, VA 22191