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Privacy Policy

MOJIO’S PRIVACY POLICY
Last updated: May 24, 2018
Moj.io Inc. (“Mojio”) respects your privacy and is committed to transparency in the protection, collection and use of your personal information. The Privacy Policy below tells you about your privacy rights and how the law protects you, and describes how we look after, collect and use your personal data, and the circumstances under which we may share this information.
This Privacy Policy applies to the privacy practices of: (a) our website located at www.moj.io (the “Mojio Website”); (b) our platform (including APIs required to access the platform) that provides connected-car services (the “Mojio Platform”); (c) our software development kit for development applications that interoperate with the Mojio Platform (the “Mojio SDK”); (d) any mobile device software provided by us to you through the Apple App Store or Google Play, including, but not limited to, our mobile application titled Mojio Cloak and Mojio Gauge (the “Mojio Mobile Applications”); and (e) the Mojio hardware device for the vehicle (the “Mojio Hardware Device”) (together with the Mojio Website, Mojio Platform, Mojio SDK and the Mojio Mobile Applications, the “Mojio Solution”).
Who We AreMojio is made up of different legal entities, with operations worldwide and offices in the US, Canada, Germany, and Bulgaria as follows: Moj.io Inc., a Canadian Company (Parent); Mojio USA Inc., a Delaware limited company (Sub); Mojio EOOD, a Bulgarian company (Sub); and Mojio GmbH, a German company (Sub) (the “Mojio Group”). This privacy notice is issued on behalf of the Mojio Group so when we mention “Mojio”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Mojio Group responsible for processing your data. Mojio, a Canadian registered company, is the controller and responsible for this website.
Collection of InformationMojio provides a connected-car service that allows you to gain access to information on the use and operation of your vehicle in order to enhance your driving experience and improve your vehicle performance. The Mojio Solution is enabled by the Mojio Hardware Device which plugs into your vehicle and connects with the Mojio SDK, the Mojio Applications and the Mojio Website. By using the Mojio Hardware Device, the Mojio SDK, the Mojio Applications and / or the Mojio Website, Mojio may collect the following types of information:
Account Information:To access and use certain features of the Mojio Solution (e.g. the Mojio SDK), you may need to register for a My Mojio Account (the “Account”) through the available Mojio Solution interfaces, namely, the Mojio Website or the Mojio Applications. During the registration process, you may be asked to provide us with your full name, address, telephone number, email address, photograph and the Mojio Hardware Device number (or IMEI). You may also be asked to choose a username, password and security questions.
In registering for an Account (or after registration), you can choose to provide your social media login information and password through platforms such as Facebook. If you do so, you authorize us to access certain social media account information (consistent with your social media privacy settings), including but not limited to your profile information, full name, username, email address and full physical address. All such information is provided directly by the social media platform, whose use of your personal information will be subject to its own privacy policy and terms of use.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you fail to provide personal data when we need to collect personal data for registration, by law, or under our Terms of Use
 or a contract we have with you, we may not be able to register your Account, or provide you with the Mojio Solution, or perform the contract we have or are trying to enter into with you.
Information from the Mojio Hardware Device
We collect and use the information described below about the vehicle in which you installed the Mojio Hardware Device. We receive some of this information via a mobile service provider. See section 3(b) “Mobile Services Providers” for further information on how the Mojio Hardware Device interacts with a mobile network.
Vehicle Related InformationWe collect information about your vehicle’s operation to provide you with feedback on your driving habits. For example, we collect data on hard braking, hard acceleration, and speed. Using this information, we provide you with insight into your driving style that can help you save on gas and vehicle wear and tear. We require your vehicle type and vehicle identification number so that we can provide you with tailored feedback.
Vehicle Location InformationWe collect information on the location of your vehicle, including your trip route and the parked location of your vehicle. Trip routes allow you to review a particular route that you have driven, the fuel cost associated with that route, and the length of time the particular route takes to drive.
If you access the Platform by mobile device, you may be asked to share your geo-location in order to make use of our geo-location services. You may also be asked to provide us with access to your device’s contact book and phone number in order to use some of the features of the Mojio Solution, e.g. to communicate the location of your vehicle to your contacts.
Payment Processing InformationWhen you pay for the Mojio Solution, you will be disclosing your payment information to Stripe Payments Canada Ltd., whose use of your personal information will be subject to its own Privacy Policy
 and Terms of Service. We do not have access to any payment processing information or any financial information such as credit card numbers.
Information We Collect Automatically When You Visit Our Website or Use Our ApplicationsWhen you install one of the Mojio Applications or use a computer, tablet, smart phone or other device to access the Mojio Website, we may use automatic means to collect information about the device and how you use it. This information may include the type of device, your operating system, your browser (for example, whether you used Internet Explorer, Firefox, Safari, Chrome or another browser), your internet service provider, your domain name, your internet protocol (IP) address, your device identifier (or UDID), the date and time that you accessed our service, the website that referred you to the Mojio Website, the web pages you requested, the date and time of those requests and your physical location. See section 7 “Cookies and Other Tracking Technologies” for further information.
Aggregated DataWe also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Mojio Solution feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Information We Do Not CollectWe do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Use of InformationWe will only use your personal data when the law allows us to. Most commonly, we use the information described above to:
provide the Mojio Solution to you;
fix, maintain, enhance and modify the Mojio Solution;
communicate with you (e.g. in response to your inquiries or comments);
comply with legal and regulatory requirements;
promote our products and services;
provide you with offers by our business partners that might interest you in accordance with your consent; and
for other purposes in accordance with your consent.
Please note that we may use information for any purpose if we anonymize it so that it no longer will be able to identify you or your vehicle, process your personal data for more than one legal basis depending on the specific purpose for which we are using your data and access your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
In addition, we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. For example, we may use your personal, usage, and aggregated data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive communications from us if you have requested information from us and, in each case, you have not opted out of receiving such communications. You can ask us or third parties to stop sending you communications at any time by contacting us as set forth below. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service provided to you.
Disclosure of InformationWe require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Accordingly, we may transfer or disclose information as follows:
Service Providers ArrangementsYour information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes.
Mobile Services ProvidersFor you to be able to access certain features using the Mojio Hardware Device, the Mojio Hardware Device needs to be connected to a mobile network through a mobile service provider (such as Telus, T-Mobile USA, AT&T or Deutsche Telekom). When the Mojio Hardware Device is connected to a mobile network, the Mojio Hardware Device shares your information with the mobile service provider for the purposes of providing you with certain features of the Mojio Solution. The information will be shared in accordance with the mobile service provider’s privacy policy and terms of use.
Legal and ComplianceWe and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization (e.g. law enforcement) for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable European, Canadian, US or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of BusinessPersonal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Mojio or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Anonymized DataInformation that is anonymized so that it will not be able to identify you may be shared with or sold to third parties.
International TransfersWe share your personal data within the Mojio Group. This will at times, involve transferring your data outside the European Economic Area (EEA). Specifically, your information may be stored and processed by us, our affiliates and our third party service providers in Canada, the United States, or other jurisdictions that may not have data protection or other laws that are as protective as in your country of residence. In the event that personal information is transferred to Canada, the United States, or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. By using the Mojio Solution, you consent to the transfer, processing and storage of your personal information in countries outside of your country of residence, including Canada, the United States, as described in this Privacy Policy.
Many of our external third parties partners and service provides are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. To ensure that your personal data is protected when transferred outside the EEA, we enter into data transfer agreements incorporating the EU’s standard contractual clauses.
Whenever we transfer your personal data to external third parties based outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer EU data subjects personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Safeguarding and Retention of Personal InformationWe will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data and in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
Access to Personal InformationYou have the right to access, update and correct inaccuracies, request erasure, object to processing, request restriction, or request portability or transfer of your personal information in our control, subject to certain exceptions prescribed by law. Specifically, you also have the right to object to the processing of your personal data for direct marketing purposes. You may request access, updating and corrections of inaccuracies in personal information we have in our control or object to the use of your personal information for direct marketing purposes by emailing or writing to us at the contact information set out below. You may also withdraw your consent to process or request to erase your personal data. However, this will not affect the lawfulness of any processing carried out before your withdraw or erasure. If you withdraw your consent or erase your personal information, we may not be able to provide the Mojio Solution or certain products or services to you. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Cookies and Other Tracking TechnologiesWe use cookies and other tracking technologies for the following purposes: (i) to operate the Mojio Website (so-called “strictly necessary cookies”, which are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website); (ii) to provide you with offers that may interest you (including on third-party websites) (so-called “targeting cookies or advertising cookies”, which collect information about your browsing habits and are used to deliver adverts more relevant to you and your interests); (iii) to personalize the content we present you on the Mojio Website (so called “functionality cookies”, which allow the Website to remember choices you make and provide enhanced, more personal features), (iv) to understand how the Mojio Solution function and are used and to provide or improve the Mojio Solution (so-called “performance or analytical cookies”, which are used to collect information about your use of the Mojio Solution). Some cookies exist only during a particular session and some are persistent over multiple sessions over time.
You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Mojio Website, you may not be able to take advantage of all of the features on the Mojio Website. If you want to delete any cookies that may already be on your computer or device, please refer to the instructions for your file management software to locate the file or directory that stores cookies.
We also use in-app tracking technologies to understand how the Mojio Solution function and are used. You can stop all collection of data generated by the use of the Mojio Applications by uninstalling the Mojio Applications.
Do Not TrackMost web browsers include a “do not track” setting. However, there is a lack of certainty or consistency with respect to what impact that setting should have on the information collected or on a user’s browsing experience. Accordingly, and consistently with respect to the operation of many websites, if you enable that setting, it will not change what information is exchanged with your computer, or how that information is used, when you visit the Mojio Website.
Third Party WebsitesThe Mojio Website may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our service and go to another site. During this process, another entity may collect personal information from you. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Updates to the Privacy PolicyWe may update this Privacy Policy to reflect changes to our privacy practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on this page and, where appropriate, notified to you by email, and all changes will be effective upon such posting or, where appropriate, notification by email, or at another specified time. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact UsMojio welcomes your comments and questions regarding this Privacy Policy and the protection, collection and use of your personal information. To respond to your request, we may ask you for your full name, email address and phone number.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions or requests, please contact the DPO using the details set out below.
By email: privacy@moj.io
By post: Privacy Officer
11th Floor, 808 West Hastings Street
Vancouver, BC Canada V6C 2X4
You also have the right to make a complaint at any time to your respective supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.