Privacy Policy

Last revised: April 02, 2024

Mobii Digital Inc. (“Mobii” for brevity) put high regard and care about the right to privacy of our users. As such, this Privacy Policy shall describe how Mobii, and its affiliates, collect, use, process, and disclose personal information in relation to your use of the Mobii Platform, website, and our offline interactions in settings where we post this Privacy Policy

Contact information

We welcome any of your questions and comments about this privacy policy. If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at legal@mobii.ph.

Personal information we collect

We collect three categories of personal information - personal information you give us; personal information automatically collected from your use of the Services; and personal information from third-party sources. We collect personal information about you when you creat an account and use the Mobii Platform. Otherwise, we may not be able to provide all services requested. This information includes

Account data

When you register for an account with us, we require certain personal information to create your account, Such as your first name, last name, phone number, postal address, email address and password, date of birth, and profile photo,

Profile data

Additionally, Mobii may also ask you to provide additional profile information to use certain features of the platform which may include, driver’s license number, passport, or other government-issued ID, which includes its date of issuance and issuing country and/or state, profile photos, gender, preferred language/s, employer, city, school, and date of birth, a selfie when we verify your ID, bank account or payment account information. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.

If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity and for security purposes.

Vehicle data

We collect information you provide in relation to a vehicle such as vehicle registration and ownership details, vehicle insurance, vehicle listing details, vehicle identification number (VIN), availability dates, reviews, and uploaded trip photos.

Payment data

We collect your digital payment details, bank account or payment card numbers, and transaction information in connection with a potential or actual transaction, which may be processed and stored by one or more third party payment service providers or digital payments companies.

Identity verification data

In some instances, we may collect identity verification information such as a photograph or scanned copy of a driver’s license, passport, other government issued ID card, or payment card, social media account information, driver’s/motor vehicle record, insurance information, or other forms of identification information.

Communications

When you communicate with Mobii, including via phone, email, or chat, fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, import or manually enter address book contacts, provide your address and/or geolocation, share your experience with us, including health information, or use the platform to communicate with other users, we collect all of these information about your communication and any information you choose to provide.

Collection, Usage, Storage, and Transparency of Image Information

Collection of Image Information

Mobii may collect images from Users in the following circumstances:

  • Profile Picture: Users may choose to upload a profile picture to personalize their account. Vehicle Documentation: Users may be required to upload images of their driver's license, identification, or vehicle documents for verification purposes.
  • Damage Reporting: Users may submit images to report vehicle damages before or after their rental.
  • Other Related Photos to Complete the Car Rental Process: Users may be required to upload additional images, such as passport, credit card, and other related photos, to complete the car rental process.

Usage of Collected Images

Images collected by Mobii may be used for the following purposes:

  • Verification: Images of identification and vehicle documents are used to verify User identity and vehicle ownership.
  • Service Improvement: Images of vehicle damages aid in assessing and documenting the condition of vehicles for maintenance and improvement purposes.
  • Personalization: Profile pictures enhance the user experience by allowing Users to personalize their accounts.

Storage and Security

Mobii implements appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our App.

Transparency in Data Handling

Mobii is committed to transparency in how it handles user data, including information collected from or about a user, such as device information. We disclose the access, collection, use, handling, and sharing of user data from our app, and we limit the use of the data to policy-compliant purposes as disclosed herein.

Personal and Sensitive User Data

Mobii acknowledges that any handling of personal and sensitive user data is subject to additional requirements. We adhere to the following principles regarding personal and sensitive user data:

  • Mobii never publicly discloses any personal and sensitive user data related to financial or payment activities or any government identification numbers.
  • We ensure that personal and sensitive user data is handled securely and in accordance with applicable privacy and data protection laws.

Compliance with Applicable Laws

Mobii understands that the Google Play requirements outlined above are in addition to any requirements prescribed by applicable privacy and data protection laws. We are committed to complying with all relevant laws and regulations governing user data privacy and protection.

Personal information we collect from third-party sources

Third-party services

If you choose to log in to Mobii platform through a third-party site or service (e.g., Apple, Facebook, or Google), the third-party service may send us information such as your registration and profile information from that service. The information we may receive varies by service and is controlled by the relevant service. By associating an account managed by a third party with your Mobii account and authorizing Mobii to have access to this information, you agree that Mobii may collect, store, and use this information in accordance with this Privacy Policy. We are not responsible for how those third parties use and share your information. Please refer to the privacy policies of those third parties to understand how they use and share your personal information. Third-party in-vehicle devices. If your vehicle, or a vehicle you book through the Mobii platform, includes an in-vehicle device or system operated by a third-party service (including vehicle manufacturers) or installed by the host, and that host or service may record information about your use of the car. The host and/or third-party service will be solely responsible for its use of such information but may disclose such information to Mobii, which we will use in accordance with this Privacy Policy.

Background check services

To the extent permitted by applicable laws, Mobii may collect background information about you from public records, background check providers, or other screening services, including credit reports and information about criminal convictions or from sex offender registries. We may use your information, including your full name and date of birth, to obtain such reports. Other sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data, fraud detection information, or data from credit bureaus and other third-party data providers. We may combine the information about you that we receive from third-party sources with other information we have about you.

Customer (KYC) process utilizing Evith Technology Ltd.

Information We Collect

When you use our car rental app and undergo the KYC process, we collect and process the following types of personal information: KYC Data: This includes personal information such as your name, date of birth, address, and any other information required for identity verification. Identification Documents: We collect images or scans of government-issued identification documents such as passports, driver's licenses, national identification cards, or any other similar document.

Use of Evith Technology Ltd.

We utilize Evith Technology Ltd., a third-party service provider specializing in identity verification solutions, to assist in the KYC process. IDAnalyzer may process your personal information solely for the purpose of verifying your identity and ensuring compliance with legal and regulatory requirements.

How We Use Your Information

We use the collected KYC data and ID information for the following purposes: Identity Verification: We use this information to verify your identity and ensure that you meet the requirements for renting a car through our app. Compliance: We may use your information to comply with applicable laws, regulations, and regulatory guidance related to car rental services. Account Security: Your information may be used to protect the security of your account and prevent fraudulent activities. Improvement of Services: We may analyze aggregated and anonymized data to improve our car rental app and enhance the user experience.

Disclosure of Information

We may disclose your KYC data and ID information to third parties in the following circumstances: Service Providers: We may share your information with third-party service providers such as Evith Technology Ltd. who assist us in identity verification processes and compliance with legal and regulatory requirements. Legal Compliance: We may disclose your information as required by law, regulation, legal process, or governmental request. Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction.

Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction.

Retention of Information

We will retain your KYC data and ID information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Your Rights

You have certain rights regarding your personal information, including the right to access, correct, or delete your information. Please contact us using the information provided below to exercise your rights.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes to this Privacy Policy through our app or other appropriate channels.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at legal@mobii.ph. By using our car rental app and providing your KYC data and ID information, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

Personal information we automatically collect.

When you communicate with Mobii, including via phone, email, or chat, fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, import or manually enter address book contacts, provide your address and/or geolocation, share your experience with us, including health information, or use the platform to communicate with other users, we collect all of these information about your communication and any information you choose to provide.

Usage data

We collect information about your interactions with the platform, such as the pages or other content you view, your log-in history, your searches, bookings you have made, how long you spent on a page or screen, sites from which you link or browse to in the platform, navigation paths between pages or screens, information about your activity on a page or screen, access time, duration of access, and other actions on the platform.

Geolocation data and information

When you use certain features of the platform, we may collect information about your approximate or precise location (e.g., city/town associated with your IP address), such as when you opt in to use our location sharing feature, we may collect the precise location information of your mobile device or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.

Log Data and Device Information

We collect information about your computer or mobile device, such as its operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique device identifiers, or general location information such as city, state, or geographic area.

We also collect details about how you’ve used the Mobii Platform (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, and the pages you’ve viewed or engaged with before or after using the Mobii Platform. We may collect this information even if you haven’t created an Mobii account or logged in. Trip data. We collect transactional information related to the trips you take through the Mobii platform, including the date and time of your trip, amounts charged, and other related trip details.

Payment Transaction Information

This includes information om payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details.

Cookies and similar technology

When you access the Mobii platform, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, clear gifs, pixel tags, e-tags, “Flash cookies”, or other local storage provided by your browser or associated applications (collectively “Cookies”).

Personal information we collect from third-party sources.

Third-party services

If you choose to log in to Mobii platform through a third-party site or service (e.g., Apple, Facebook, or Google), the third-party service may send us information such as your registration and profile information from that service. The information we may receive varies by service and is controlled by the relevant service. By associating an account managed by a third party with your Mobii account and authorizing Mobii to have access to this information, you agree that Mobii may collect, store, and use this information in accordance with this Privacy Policy.

We are not responsible for how those third parties use and share your information. Please refer to the privacy policies of those third parties to understand how they use and share your personal information.

Third-party in-vehicle devices

If your vehicle, or a vehicle you book through the Mobii platform, includes an in-vehicle device or system operated by a third-party service (including vehicle manufacturers) or installed by the host, and that host or service may record information about your use of the car. The host and/or third-party service will be solely responsible for its use of such information but may disclose such information to Mobii, which we will use in accordance with this Privacy Policy.

Background check services

To the extent permitted by applicable laws, Mobii may collect background information about you from public records, background check providers, or other screening services, including credit reports and information about criminal convictions or from sex offender registries. We may use your information, including your full name and date of birth, to obtain such reports.

Other sources

To the extent permitted by applicable law, we may receive additional information about you, such as demographic data, fraud detection information, or data from credit bureaus and other third-party data providers. We may combine the information about you that we receive from third-party sources with other information we have about you.

How we use your personal information

We use, store, and process your personal information to provide and improve the services provided by Mobii and for security and safety purposes. To elaborate, we may use your information:

To Provide, Improve, and Develop the Mobii Platform. We may process this information to:

  • enable you to access and avail of services of Mobii Platform and make and receive payments,
  • enable you to communicate with other Mobii users,
  • process your request,
  • perform analytics, debug, and conduct research,
  • provide customer support, service, and training,
  • send you messages, updates, security alerts, support,administrative messages, reminders, technical notices, and account notifications, and information requested by you at any telephone number, by placing a voice call or through text (SMS) or email messaging
  • process, handle, or assess claims,
  • Facilitate your referral invitations
  • Send your requests for reviews, for fraud detection and prevention, and for any purpose you authorize at the time of collection
  • Administer referral programs, rewards, surveys, contests, or other promotional activities or sponsored events in which you participate
  • personalize and customize your experience based on your interactions with the Mobii Platform, your search and booking history, your profile information and preferences, and other content you submit, and
  • enable your use of our enterprise products and accommodation services.

If you provide us with your contacts’ information, such as your friends or co-travelers, we may process this information to: (i) facilitate your referral invitations, (ii) share your trip details and facilitate trip planning, (iii) detect and prevent fraud, and (iv) facilitate your requests or for any other purpose you authorize.

For research and development

We may use your personal information to analyze and improve the services of Mobii for purposes of developing new products and updating its services, including by studying our user demographics.

We may also create aggregated, de-identified, or other anonymous data from your personal information and make a personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the services and promote our business.

For marketing and advertising

We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing

We may send you Mobii-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications. Interest-based advertising. We may contract with third party advertising and social media companies to display ads on the Services and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data, online activity data, and/or geolocation data described above) over time across our Services and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you.

Furthermore, we may process this information obtained to send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms; personalize, measure, and improve our advertising; administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Airbnb or its thirdparty partners; analyzecharacteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you; invite you to events and relevant opportunities, and send, with your consent, promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

For the creation and maintenance of a secured, safe, and trusted environment:

We may process this information to:

  • detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activities,
  • study and combat discrimination consistent with our policies,
  • conduct fraud prevention, security investigations, and risk assessments,
  • verify or authenticate information provided by you,
  • conduct checks against databases and other information sources, including background checks,
  • enforce our agreements with third parties,
  • determine eligibility for certain types of bookings, such as instant or on the day booking,
  • comply with law, respond to legal requests, prevent harm, and protect our rights,
  • Verify your identity or authenticate information that you provide, including during account creation and password reset processes.
  • Resolve disputes, collect fees, and troubleshoot problems
  • Detect, prevent, and/or remedy fraud, abuse, security incidents, or other potentially harmful, prohibited, or illegal activities
  • Determine your likelihood of getting into an accident or of making an insurance claim.
  • Using information from your mobile or in-vehicle device to identify unsafe driving behavior, including speeding or harsh braking and acceleration, and to raise awareness regarding such behaviors
  • Detect, prevent, or remediate violations of and enforce our Terms of Service, Addendum, and other policies.
  • Manage and protect our information technology infrastructure
  • Conduct investigations and risk assessments
  • Conduct checks against databases and information sources (such as but not limited to public government databases)
  • Perform creditworthiness and solvency checks
  • assess or evaluate your interactions with the Mobii Platform and information obtained from third parties. In limited cases, automated processes, which analyze your account and activities on the Mobii platform as well as information in relation to activities on and off the platform that can be associated with you, could restrict or suspend your access to the Mobii Platform if such processes detect activity that may pose a safety or other risk to Mobii, our community, or third parties. To Provide Payment Services. Personal information is used to enable, or authorize third parties to use, Payment Services, such as to:
  • detect and prevent money laundering, fraud, abuse, and security incidents, as well as conduct risk assessments,
  • comply with legal and compliance obligations (such as antimoney laundering regulations andsanctions enforcement),
  • enforce payment terms and other payment policies, and
  • provide and improve Payment Services. To comply with law We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities. With your consent: In some cases, we may specifically ask for your consent to process your personal information. We may also use your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

How we disclose your personal information

We may share your information at your direction or with your consent.

Profiles, listings, and other public information

Your public listing page on the Services will always include some basic information, such as your user ID or name associated with your account, your public profile photo, and for hosts, the city where your car is located, your listing description, your calendar availability, transaction related information to allow our community to evaluate your reliability and responsiveness, and reviews or feedback about you. Your public listing page may also include aggregate demand information (such as number of page views over a period of time) and information about your cancellations. The Services may also display the approximate geographic pickup location of your vehicle.

The Services allow your public profile and public listing pages to be included in search engines, in which case your public profile and public listing pages may be indexed by search engines and may be published as search results.

Sharing between hosts and renters

Mobii enables car owners to offer and share their vehicles with other individuals. If you agree to a booking through the Mobii platform, we may provide your information to the other party in that transaction as reasonably necessary to facilitate the transaction.

For example, we may provide your mobile phone number to facilitate communication, your driver's license information to confirm license validity and for identity verification, or your photograph to facilitate identification. We will also share the address of the vehicle and, if applicable, the proposed delivery location with the other party. The other party may also send you text messages (such as to confirm pickup or delivery location).

Service providers

We may share information with vendors and service providers who support the operation of the Mobii platform and business and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, payment processing, email delivery, marketing, insurance, claims administration, vehicle recovery, roadside assistance, incident response, and customer support services). In some cases, the service provider may directly collect the information from you on our behalf. These service providers may use your personal information only as directed or authorized by us.

Third-party platforms and social media networks

If you have enabled features or functionality that connect the services offered by Mobii to a third-party platform or social media network, we may disclose to the third-party platform or social media network the personal information necessary to facilitate the connection or that you authorized us to share. We do not control the third party’s use of your personal information.

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Business transfers

We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution.

Responding to legal requests, preventing harm, and protecting our rights

We may disclose your personal information to courts, law enforcement, governmental or tax authorities, or third parties. We will make such disclosure to the extent we are required or permitted to do so by applicable law or where we consider such disclosure is reasonably necessary to comply with our legal obligations or legal process, to respond to claims asserted against us, and for safety and security purposes described above.

We may also disclose your information in response to valid legal requests relating to criminal investigations or alleged or suspected illegal activity or any other activity that may expose Mobii, you, or any other user, or to protect the rights, property, or personal safety of Mobii, our users, or others.We may also disclose your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

App Tracking Transparency

We are committed to protecting your privacy and ensuring transparency in our data collection practices. This Privacy Policy provision outlines our implementation of App Tracking Transparency (ATT), requiring us to obtain your permission before collecting data used to track your activity within Mobii.

App Tracking Transparency

Consent for Tracking

We value your control over your personal data. Mobii will explicitly request your permission before collecting data used to track your activity. This consent will be obtained using Apple's AppTrackingTransparency framework or any other similar framework that provides equivalent functionality.

Consent Request

The consent request will be presented clearly and prominently within the application, explaining the purpose and benefits of tracking, as well as any associated data sharing practices. You will have the option to grant or deny consent without any negative consequences or loss of functionality within the application.

Revoking Consent

You have the right to withdraw your consent for data tracking at any time. If you choose to revoke your consent, our mobile applications will no longer collect data used to track your activity. Please note that revoking consent may impact certain functionalities or personalized experiences within the application.

Data Collection Transparency

Types of Data Collected

Mobii will provide clear and concise explanations about the types of data collected for tracking purposes. This may include, but is not limited to, device identifiers, IP addresses, location information, and browsing behavior within the application.

Purpose of Collection

Mobii will clearly state the purpose of collecting data for tracking, which may include personalizing your experience, improving our products and services, and delivering relevant advertisements or offers.

Third-Party Data Sharing

Mobii will disclose any third-party data sharing practices involved in tracking your activity within the application. This may include sharing data with analytics providers, advertising networks, or other service providers. Such sharing will only occur with your explicit consent or as required by applicable laws and regulations.

Data Usage Limitation

Purpose Limitation

Data collected for tracking purposes will be used solely for the intended purpose disclosed to you during the consent process. We will not use this data for any unrelated purposes without your explicit consent.

Data Retention and Security

We will retain the collected data for the necessary period required to fulfill the disclosed purpose. After this period, we will securely delete or anonymize the data to protect it from unauthorized access, loss, or disclosure.

Your Rights and Control

Access, Rectification, and Deletion

You have the right to request access to your personal data collected through tracking, as well as the right to rectify any inaccuracies. Additionally, you may request the deletion of your data within the application, subject to any legal obligations and limitations under this Privacy Policy which we may have to retain certain information.

Your preferences and choices

Communication preferences

You can control the methods by which we may contact you about your account, your booking and listing activities, promotions, and announcements in the user settings within your Mobii account.

Correct, edit, and update information

You can review, correct, update, and edit certain information that has been previously provided to us by you at any time by logging in to your account and reviewing your account settings and profile. You can also access or request a correction of your information by contacting us through our customer support and platform specialist. For your protection, we may need to verify your identity before implementing your request.

Account closure

If you wish to close your account and request deletion of your personal information, please contact us through our customer support and platform specialist.

Please note that we may be unable to delete information needed to comply with applicable laws, detect or prevent fraud, collect any fees owed, resolve disputes, assist with or process claims, troubleshoot problems, assist with any audits and investigations, to enforce our Terms of Service, Addendum, and other policies, and take other actions reasonably necessary, permitted, or required by applicable law. There may also be residual information that will remain within our databases and other records, which will not be removed.

Upon deleting your account, all personal details and information provided to our app will be permanently removed from our active databases. However, for the sole purpose of preventing scams or identity theft, we may retain certain personal details or identification associated with your account. This retained information will be securely stored and protected. If you have any concerns or wish to access or rectify the retained details, please contact our support team or privacy officer.

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the services to you, if you do not provide this information when requested (or we later delete it at your request), we may not be able to provide you with the services provided by Mobii.

Third-party platforms and social media networks

If you choose to connect the Services to a third-party platform or social media network, such as by using the third party’s authentication service to log into your account on the Services, you may be able to control your settings through the third-party platform or social media network. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

Security

We employ a number of technical, physical, and organizational measures designed to protect information against unauthorized access, destruction, or alteration while it is under our control. However, no method of transmitting or storing information can be 100% secure and we cannot guarantee the security of your personal information.

Other important information

Cross border transfer

Mobii’s services are controlled and operated from the Philippines. Your personal information may be used, stored, and processed in any country where we have facilities or in which we engage service providers. These locations may be outside of your country of residence, and may have different and/or less protective data protection rules than those of your country. As a result, this information may be subject to access requests from governments, courts, regulatory agencies, security authorities, or law enforcement in those jurisdictions according to the laws in those jurisdictions.

Minors

The services of Mobii are not intended for users anyone under the age of 18 and we do not knowingly collect personal information from users under the age of 18. If a child under the age of 18 has already provided us with personal information, his or her parent or guardian may contact us to request that we delete it.

Third-party privacy practices

This Privacy Policy addresses only the use and disclosure of information collected by Mobii. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which our services link. The inclusion of a link on the services does not imply endorsement of the linked site or service by us or by our affiliates. If you disclose your information to others, or if you are directed to a third-party website, their privacy notices and practices will apply.

Changes to this privacy policy

We may change this Privacy Policy from time to time. Please take a look at the “Last revised” phrase at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services or as otherwise indicated. Your use of the Services following these changes means that you accept the revised Privacy Policy. If you don’t agree to these changes, you can contact us to close your account.