This policy applies to the United States and privacy rights of users in the United States. This policy is not meant to supersede any local, state, federal, or international privacy laws including, but not limited to, the General Data Protection Regulation (GDPR).

Introduction

Vay GmbH (hereinafter referred to as "the Company", “we”, or “us”) is committed to protecting the privacy and security of your personal information. This Privacy Policy is designed to help you understand how we collect, use, and disclose information when you use our services, including our website, mobile application, and any other platform or service offered by us (collectively, the "Services"). We are dedicated to complying with local, state, and federal laws and regulations regarding data protection, including the laws of Nevada and the United States.

1. Information We Collect

We may collect the following types of information from you:

A. Personal Information

• Contact Information: This includes your name, email address, phone number, and mailing address.
• Account Information: If you create an account with us, we may collect your username, password, and other account-related details.
• Payment Information: If you make purchases through our Services, we may collect your payment card information. See Sec. ____ for more information on Payments.
• Location Information: We may collect your device's location information with your consent. User-Generated Content: We may collect information you provide when you interact with our Services, such as reviews, comments, or other content you submit.
• Communication Information: We may collect information from your communications with us, such as customer support requests, emails, or chat logs.
• Your voice and/or personal image may be captured by the Vay Vehicle's onboard & exterior facing audio and visual recording system. These devices are not operational while a User is in control of the vehicle, but handovers to and from teledrivers are recorded (audio and visual) for training and quality assurance purposes. These images and recordings will not be shared externally or for any other purpose outside of training and quality assurance. Exemptions of this policy include law enforcement legal process and court orders.

B. Automatically Collected Information

• Usage Information: We collect information about how you use our Services, including your interactions with our website, mobile application, and advertisements.
• Device Information: We may collect device-specific information, such as your device's hardware model, operating system, and unique identifiers.
• Log Data: We automatically log certain information when you use our Services, including your IP address, browser type, referring/exit pages, and pages viewed.

2. How We Use Your Information

We may use your information for the following purposes:

• To provide, maintain, and improve our Services.
• To process transactions and send transaction notifications.
• To respond to your requests, comments, or questions.
• To send you marketing and promotional communications, where permitted by law.
• To detect, investigate, and prevent fraudulent or illegal activities.
• To comply with legal obligations and protect our rights.

3. Disclosure of Your Information

We may share your information with the following entities:

• Service Providers: We may disclose your information to third-party service providers who assist us in providing and maintaining our Services. These service providers may have access to your personal information but are obligated to use it solely to perform services on our behalf and in accordance with our instructions.
• Legal Compliance: We may share information to comply with legal obligations, respond to legal requests, and protect our rights, privacy, safety, or property.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of our assets, your information may be transferred to the acquiring entity.
• Third-Party Payment Processors:
  • We use third-party payment processor Stripe, Inc. to handle payment transactions on our behalf. When you make a payment through our Services, your payment card information, such as your credit card number, expiration date, and CVV code, is collected and processed directly by these third-party payment processors. We do not store or have access to your full payment card information.
  • Our third-party payment processors are carefully selected and are compliant with industry security standards, such as Payment Card Industry Data Security Standard (PCI DSS), to ensure the security and protection of your payment information. We recommend reviewing the privacy policies and security measures of our payment processors for more information about how they handle your payment information.
  • Please note that while we take reasonable steps to protect your payment information, the security of data transmitted over the internet or stored electronically cannot be guaranteed to be 100% secure. You are responsible for taking appropriate steps to protect your payment card information, such as safeguarding your login credentials and using secure internet connections when making payments.

By using our Services, you acknowledge and consent to the sharing of your information as described in this Privacy Policy, including the sharing of payment information with our third-party payment processors for payment processing purposes. If you have any concerns about the handling of your payment information, please contact us using the information provided in Section 8 of this Privacy Policy.

4. Your Choices

You have the following choices regarding your information:

• You can access and update your account information by contacting Vay at [email protected]
• You can opt out of marketing communications by following the instructions provided in those communications or contacting us at [email protected]
• You can disable location services on your device or deny location permissions in our mobile app. As a note, disabling location services completely will render most of the functions of the application unavailable.
• You can delete your account by contacting us.

5. Security

We take reasonable measures to protect your information, but no data transmission or storage can be guaranteed to be 100% secure. Please take appropriate steps to protect your personal information.

6. Children's Privacy

Our Services are not intended for individuals under the age of 21. If we become aware that we have collected personal information from children (those age 17 and under) without parental consent, we will take steps to delete the information. Users agree upon signup that they are age 21 or over. Users may not make accounts for or use information of individuals under the age of 21.

7. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The date of the last update will be prominently displayed. Your continued use of our Services after any changes indicates your acceptance of the revised policy.

8. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at: [email protected]

9. Additional Nevada Privacy Rights

If you are a Nevada resident, you have the right to request certain information about our data practices in accordance with Nevada law. To exercise these rights, please contact us using the contact information provided in Section 8.

10. Additional U.S. Federal Privacy Rights

As a U.S. resident, you may have additional privacy rights under federal law. For more information about these rights, please refer to applicable federal laws and regulations.

By using our Services, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use our Services.