GENERAL
Shift Live Ltd. (“We”, “Us”, “Our”) has developed a mobile application (the “App”), that collects data from your device in order to provide you with public transport information in addition to our website(s) and any additional websites owned and operated by Shift (the “Site”) and related transportation information services (collectively referred to as the “Service”). By providing personal information to us or by using the Service, you acknowledge that you have read and understand this Privacy Policy and consent to the terms specified in this privacy policy.

PURPOSE
This Privacy Policy describes how we collect, use and disclose your information and how this information can be accessed and deleted when necessary. By using The App and our Services, you accept the terms and conditions described in this Privacy Policy.

SCOPE
The App may contain links to websites, apps, products or services that are operated by third parties. This Privacy Policy does not extend to these third parties on which we have no control and for which we cannot be held liable. We encourage you to read about the privacy policies, procedures and practices of those third parties.

WHAT INFORMATION WE COLLECT FROM YOU
We collect and process information from your device in several ways in order to improve our Services as well the third parties’ services, including:

• Once you have given us your consent to track your location, we keep track of your location and movement, as well as your travel destination. The collection of location data only happens if you’ve granted the App access to your device’s location services.
• We may collect your preferences, including favorite routes, saved locations, and other personal customizations. We also may collect usage details each time you use the App, including the country of origin, the searches you make, the routes you interact with, the type of phone or OS you are using, etc.
• We collect your phone number. We may collect contact information. When purchasing some services directly from The App in supported cities, we may collect your name, phone number, zip/postal code, email address, physical address, payment information, and other elements necessary to complete a transaction.
• If you submit any personal information relating to another individual to us, you represent and undertake that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

HOW WE USE YOUR INFORMATION
We may use information collected from or provided by you for the following purposes:

• Provide you with our Service including relevant transport information;
• Understand your preferences so that we can customize the App for you, such as recommending personalized transport options;
• Restore your preferences if you log into your App account on a different device (if applicable);
• Securely transfer your usage details, payment information and user credentials to third parties including mobility operators to provide you access to their services;
• Develop and improve The App based on your feedback and interactions;
• Subject to your consent, keep you posted from time to time on latest announcements and additional information;

USERS’ OPTIONS
You can stop all collection of location data easily and at any time by disabling location services in your device’s settings or by uninstalling The App.

You are not required to indicate any preferences (including setting your home and work address) in order to use The App, nor are you required to create a The App account that records your email, since these are optional.

We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may opt out from:

• Receiving marketing communications from us: If you no longer want to receive marketing communications from us on a going forward basis, you may opt out of receiving them by contacting us via info@shiftlive.net In your request to us, please provide your name, identify the form(s) of marketing communications that you no longer wish to receive, and include the address(es) to which it/they are sent. For example, if you no longer wish to receive marketing e mails or direct mail from us, tell us that in your communication, and provide your name and e mail or postal address. In addition, you may opt out of receiving marketing e mails from us by following the unsubscribe instructions provided in any such message.
• Receiving reminders from us: If you no longer want to receive medical reminders from us on a going forward basis, you may opt out of receiving them by contacting us via info@shiftlive.net. In your response to us, please provide your name and the e mail address or phone number at which you receive reminders from us.
• Our sharing of your personal information with affiliates and third party partners: If you previously opted in to receiving marketing communications from our affiliates or third party partners, you may opt out of our sharing of your personal information with those parties for their direct marketing purposes on a going forward basis by contacting us via info@shiftlive.net In your communication to us, please state that we should no longer share your personal information with our affiliates and/or third party partners for their marketing purposes, and include your name and e mail address.
  We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your personal information from the databases of our affiliates with which we have already shared your information (i.e., as of the date that we implement your opt out request). Please also note that if you opt out of receiving marketing related messages from us, we may still send you important transactional and administrative messages, from which you cannot opt out.

If you would like to review, correct, update, restrict, or delete your personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us via info@shiftlive.net. We will respond to your request as soon as reasonably practicable and no later than the earlier of: (i) one month after receipt; or (ii) any other binding timeline per applicable law. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response, subject to applicable law.

DISCLOSURE TO THIRD PARTIES
We do not disclose your information to third parties without your explicit consent except for the following purposes:

• In case you request assistance with the use of The App, we might share such request, including your contact information, with a third party directly involved in the issue (i.e. if you inform us over email that certain the App schedules in the app are outdated, and we forward this message to the applicable the App agency).
• When you purchase or access services from a third party (e.g. a mobility operator) through our app, we will share the information required to ascertain your lawful use of those services (including tokenized payment information, relevant personally identifiable information, and any relevant location data). For example, if you purchase a public the App ticket, we may share the time and location where you purchased that ticket in order to ensure that no fraudulent tickets have been sold; or if you try to unlock shared vehicles, we may verify your location to ensure that you’re near the station before you unlock a bike.
• In case of a prospective business transaction, you agree that the App may disclose anonymous and aggregate information to another corporation in order for the parties to determine whether to proceed with such transaction. In case a business transaction is completed, you agree that any information may be transferred to the corporation that owns the App or the relevant part of it in order to carry its business. A “business transaction” includes, but is not limited to, a reorganization, merger, purchase, sale or other acquisition or disposition of a corporation or any of its assets.
• In case we are required to comply with applicable law and regulations and lawful requests or orders or if it is otherwise permitted by law (i.e., protect and defend our rights, situation that threatens life, health or safety, etc.).

We also may disclose anonymous and aggregate information to certain third parties for research, product development or other business purposes. For instance, we may share information with the App agencies to help them analyze and improve their services.

THIRD-PARTY SOFTWARE/SERVICE
While using The App, we may be using third party software and/or service for various needs, inter alia, in order to collect and/or process the information detailed herein (the “Third Party Service Provider”).

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 online service (including, without limitation, any application) that is available through this Service or to which this Service contains a link. The availability of, or inclusion of a link to, any such site or property on the Service does not imply endorsement of it by us or by our affiliates and we shall not bear any responsibility with respect thereto and/or with respect to their activities.

We may also provide additional the App-related services, including on-demand the App services, provided by our third party operational service partners (as they may evolve from time to time at our discretion). Such third party providers are subject to their respective terms of use and privacy policies.

SECURITY SAFEGUARDS
We are committed to securing your information and we take reasonable physical, organizational and technical measures to protect your information against unauthorized access, use, disclosure, modification or destruction.

These safeguards include, but are not limited to:

• Storage on secure servers;>
• Encryption of the communication channels;
• Limited access to employees and contractors on a “need-to-know” basis.

We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us.

CROSS BORDER TRANSFER
Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Service or by providing consent to us (where required by law), you agree that your information may be transferred to countries outside of your country of residence, including to the United States and Europe, which may provide for different data protection rules than in your country. Appropriate contractual and other measures are in place to protect personal information when it is transferred to our affiliates or third parties in other countries.

RETENTION PERIOD
We will retain your information as long as you use The App and for a reasonable time thereafter.

RIGHTS OF EUROPEAN DATA SUBJECTS
If you are in one of the EU/EEA countries, you may be entitled to certain rights under the General Data Protection Regulation (GDPR).

By using The App or communicating with us, you consent to the purposes for which we process your personal data. We may process your personal data if we have other lawful grounds to do so.

You have a right to:

• Withdraw consent to processing, where consent is the basis of processing.
• Access your personal data that we hold and how to process it, under certain conditions.
• Demand rectification of inaccurate personal data about you.
• Object to unlawful data processing under certain conditions.
• Require erasure of past data about you (your “right to be forgotten”) under certain conditions.
• Demand that we restrict processing of your personal data, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal data is inaccurate.
• Port personal data concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
• Complain to a data protection supervisory authority in your country.

UPDATE
We reserve the right to amend or change this Privacy Policy at any time without notice. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Service. Your use of the Service following these changes means that you accept the revised Privacy Policy. We recommend that you regularly review the Privacy Policy when you visit the Service.

CONTACT INFORMATION
If you have any questions or concerns about this Privacy Policy, please contact us by email at info@shiftlive.net