Policy Regarding the General Regulation on
Last updated: January 2025
Article 1 -Preamble
This Privacy Policy applies to:
1. the Moove website (flymoove.com),
2. its main application (app.flymoove.com),
3. as well as custom applications operated by enterprise customers under aSaaS/white label contract (e.g., app.flymoove.com/company=ACME).
In this context, Moove can act:
- as a data controller when it collects andprocesses personal data directly for its own purposes (management of the site,administration of the platform, direct commercial relationship with itscustomers),
- as a processor when it provides the SaaS solutionto corporate customers, who themselves act as data controllers vis-à-vis theirown users and passengers.
In this case, Moove processes the data only inaccordance with the contractual instructions of these companies.
The purpose of this Privacy Policy is to exposeusers to:
1. how their personal data is collected and processed,
2. the rights they have in relation to their data,
3. the identity and responsibilities of the actors involved in theprocessing (Moove and/or client companies),
4. any recipients of such data,
5. the applicable policy on cookies and trackers.
This policy supplements the Legal Notice and theGeneral Terms and Conditions of Use applicable to the services concerned.
Article 2 -General principles for data collection and processing
In accordance with the provisions of Article 5 ofEuropean Regulation 2016/679, the collection and processing of website users'data complies with the following principles:
● Lawfulness,fairness and transparency: data is only collected and processed with theconsent of the user who owns the data. Each time personal data is collected,the user will be informed that their data is being collected, and for whatpurposes their data is being collected;
● Limited purposes: the collection and processing of data is carried out tomeet one or more objectives determined in these general terms and conditions ofuse;
● Minimizationof data collection and processing: only the data necessary for the proper execution ofthe objectives pursued by the site are collected;
● Data retention limited in time: data is kept for a limited period of time, ofwhich the user is informed;
● Integrity and confidentiality of the data collected and processed: the datacontroller undertakes to guarantee the integrity and confidentiality of thedata collected to the extent of its means.
In order to be lawful, and in accordance with therequirements of Article 6 of European Regulation 2016/679, the collection andprocessing of personal data only takes place if at least one of the followingconditions is verified:
● Theuser has expressly consented to the processing;
● Theprocessing is necessary for the proper performance of a contract;
● Theprocessing complies with a legal obligation;
● Theprocessing is justified by a necessity related to the protection of the vitalinterests of the data subject or of another natural person;
● Theprocessing may be explained by a necessity related to the performance of a taskcarried out in the public interest or which falls within the exercise ofofficial authority;
● Theprocessing and collection of personal data is necessary for the purposes of thelegitimate and private interests pursued by the controller or by a third party.
Moove collects and processes the data of its Users:
● bycollecting and respecting the necessary consent that any User may revoke at anytime, via a written request by email to Moove customer service;
● tofulfil its legal obligations;
● Inthe interest of the public and in particular to offer a personalized,innovative and secure online biography writing service.
● Forits legitimate interests, in particular with regard to the provision of aservice for the practice of biography accessible to all, unless these interestsare overridden by the interests or fundamental rights and freedoms of Usersrequiring the protection of their personal data
Article 3 -Personal data collected and processed in the context of browsing the site
A. Datacollected and processed and method of collection
a. Thepersonal data collected on the following
Data for customers: email, first name, last name,phone number, company. This data is collected when a user registers for theapplication, via a dedicated form clearly indicating to the user that he or sheis registering for the Moove application or a white label application.
The data controller will keep all the datacollected in its computer systems on the site and under reasonable securityconditions for a period of 3 years from the end of the commercial relationshipbetween the user and Moove.
Data for prospects: email, phone, company,exchanges with Moove teams. This data is collected when the user performs oneof the following operations on the website: (1) the user subscribes to thewebsite's newsletter, (2) the user requests to be called back for information,(3) the user communicates with Moove (email, chat).
In the case of a visit to the website, if the useraccepts cookies, login information will be transmitted to third-party servicesfor analysis purposes: trackers of advertising networks/social networks (GoogleAds), site activity tracker (Hotjar), session tracking (Google Analytics).
Data for accompanying persons mentioned by users("Passengers") via the app: first name, last name, gender, date andplace of birth, passport. This data is collected when a user who subscribes tothe solution communicates data for a flight on the Moove app. The user whotransmits the data undertakes to clearly communicate with the user the factthat he/she collects and transmits personal data to Moove, with the consent ofthe accompanying person. The data controller will keep all the data collectedin its computer systems on the site and under reasonable security conditionsfor a period of 3 years after the end of the contractual relationship betweenMoove and the user who transmitted the data.
The data controller will keep all the datacollected in its computer systems on the site and under reasonable securityconditions for a period of 3 years from the last visit to the site.
b. Thecollection and processing of data shall serve the following purposes
● Customerrelationship management: facilitate the handling of the service, follow-up ofinteractions with the customer, allow the purchase of the service
● Communication with prospects in order to facilitate the marketing of the Mooveservice;
● Useof Moove charter and flight operations management software service
B. Disclosure of data to third parties
With regard to the www.flymoove.com website, some of the personal data collected maybe passed on to third parties acting as operators/service providers. Alsoconcerned are: the emailing services used by the publisher, digital analysistools (Google Analytics), and the players involved in aircraft operations. Someof these suppliers/providers may be located outside the European Union. Theyare Privacy Shield certified.
Regarding the app.flymoove.com application and theassociated SaaS solution, no personal data collected for flight operations istransmitted to any third party, and is only processed by the applicationpublisher or the client companies of the white label application.
C. Data hosting
The Moove Site is hosted by: Squarespace, whoseregistered office is located at Squarespace, 225 Varick Street, 12th Floor, NewYork, NY 10014
The app.flymoove.com app is hosted by: Google CloudPlatform, Region Europe West Zone 1, Belgium
Article 4 -Data Controller and Data Protection Officer
A. Thedata controller
The data controller for personal data is ArthurIngles, President of the company. He can be contacted in the followingways:
● arthur.ingles@flymoove.com
The data controller is responsible for determiningthe purposes and means of the processing of personal data.
B. Obligations of the data controller
The Data Controller undertakes to protect thepersonal data collected, not to transmit them to third parties without the userhaving been informed and to respect the purposes for which such data werecollected.
In addition, the Data Controller undertakes tonotify the User in the event of rectification or deletion of the data, unlessthis would entail disproportionate formalities, costs and steps for the User.
In the event that the integrity, confidentiality orsecurity of the User's personal data is compromised, the Data Controllerundertakes to inform the User by any means.
C. The Data Protection Officer
In addition, the user is informed that thefollowing person has been appointed Data Protection Officer: Antoine Awaida,Chief Executive Officer & CTO
The role of the Data Protection Officer is toensure the proper implementation of national and supranational provisionsrelating to the collection and processing of personal data. He is sometimescalled DPO (for Data Protection Officer).
The Data Protection Officer can be reached asfollows:
● antoine.awaida@flymoove.com
Article 5 -User rights
In accordance with the regulations on theprocessing of personal data, the user has the rights listed below.
In order for the data controller to grant therequest, the user is required to provide the data controller with their firstand last name as well as their e-mail address.
The Data Controller undertakes to respond to theUser's request as soon as possible.
A. Presentation of the user's rights in relation to data collection and processing
a. Right of access, rectification and right to erasure
The user may access, update, modify or request thedeletion of the data concerning him/her, by following the procedure set outbelow:
● Theuser may contact the Moove (info@flymoove.com) teams in order to request theprovision, updating, modification or deletion of his personal data collected bythe site.
b.Right to data portability
The user has the right to request the portabilityof his or her personal data, held by the site, to another site or between twoapplications, by complying with the following procedure:
● Send an email to info@flymoove.com
c. Rightto restriction and objection to data processing
The user has the right to request the limitation orto oppose the processing of their data by the website, without the websitebeing able to refuse, unless it can demonstrate the existence of legitimate andcompelling reasons, which may prevail over the interests and rights andfreedoms of the user.
In order to request the limitation of theprocessing of their data or to object to the processing of their data, the usermust follow the following procedure:
● Send an email to info@flymoove.com
d.Right not to be subject to a decision basedsolely on an automated process
In accordance with the provisions of Regulation2016/679, the user has the right not to be subject to a decision basedexclusively on an automated process if the decision produces legal effectsconcerning him/her, or similarly significantly affects him/her.
e. Right to determine the fate of data after death
Il est rappelé à l'utilisateur qu'il peut organiserquel doit être le devenir de ses données collectées et traitées s'il décède,conformément à la loi n°2016-1321 du 7 octobre 2016.
c. Rightto restriction and objection to data processing
The user has the right to request the limitation orto oppose the processing of their data by the website, without the websitebeing able to refuse, unless it can demonstrate the existence of legitimate andcompelling reasons, which may prevail over the interests and rights andfreedoms of the user.
In order to request the limitation of theprocessing of their data or to object to the processing of their data, the usermust follow the following procedure:
● Send an email to info@flymoove.com
d.Right not to be subject to a decision basedsolely on an automated process
In accordance with the provisions of Regulation2016/679, the user has the right not to be subject to a decision basedexclusively on an automated process if the decision produces legal effectsconcerning him/her, or similarly significantly affects him/her.
e. Right to determine the fate of data after death
Article 6 -Conditions for modifying the privacy policy
This Privacy Policy can be consulted at any time atthe address indicated below:
● https://www.flymoove.com
The publisher of the site reserves the right tomodify it in order to guarantee its compliance with the law in force.
Therefore, the user is invited to come and consultthis privacy policy regularly in order to stay informed of the latest changesthat will be made to it.
The user is informed that this privacy policy waslast updated on: 01/01/2025.
Article 7 -Acceptance by the user of the privacy policy
By browsing the website or application, the usercertifies that they have read and understood this privacy policy and acceptsits conditions, in particular with regard to the collection and processing oftheir personal data.
For thecompany,
Arthur Ingles
President,Moove
