pursuant to Regulation (EU) 2016/679 (GDPR), D.Lgs. 196/2003 (Privacy Code), Directive 2002/58/EC (ePrivacy) and D.Lgs. 70/2003 (Electronic Commerce)
1. Data Controller
The Data Controller for personal data processing is: MoveChat — Pietro Gasparini 📍 Location: Italy 📧 Email: support@movechat.app 🌐 Web: https://movechat.app The Controller is committed to protecting the privacy and personal data of Users in full compliance with: • Regulation (EU) 2016/679 (GDPR) • D.Lgs. 196/2003 (Privacy Code) as amended by D.Lgs. 101/2018 • Directive 2002/58/EC (ePrivacy Directive) • D.Lgs. 70/2003 (Implementation of Direttiva 2000/31/CE on electronic commerce) • Regulation (EU) 2022/2065 (Digital Services Act) and all other applicable data protection legislation.
2. Principles of Data Processing
Personal data processing is carried out in accordance with the following principles (Article 5 GDPR): • LAWFULNESS, FAIRNESS AND TRANSPARENCY: data is processed lawfully, fairly, and transparently • PURPOSE LIMITATION: data is collected for specified, explicit, and legitimate purposes • DATA MINIMIZATION: only strictly necessary data is collected • ACCURACY: data is accurate and kept up to date • STORAGE LIMITATION: data is retained only for as long as necessary • INTEGRITY AND CONFIDENTIALITY: data is processed with appropriate security measures MoveChat adopts a "Privacy by Design" and "Privacy by Default" approach, integrating data protection from the design stage of its systems.
3. Purposes and Legal Basis of Data Processing
Personal data is processed EXCLUSIVELY for the following purposes: PURPOSES AND CORRESPONDING LEGAL BASES: 1. SERVICE PROVISION - Registration and account management - Platform operation - Communication between Users Legal basis: performance of a contract (Article 6.1.b GDPR) 2. USER SAFETY AND PROTECTION - Collection of Companions' self-declarations - Prevention of fraud and abuse - Management of reports Legal basis: legitimate interest (Article 6.1.f GDPR) 3. LEGAL OBLIGATIONS - Compliance with legal obligations - Response to requests from authorities Legal basis: legal obligation (Article 6.1.c GDPR) PURPOSES FOR WHICH WE DO NOT PROCESS DATA: • Commercial or behavioral profiling • Direct marketing or advertising • Sale or transfer to third parties • Market analysis or research • Automated decision-making with legal effects
4. Data Collected
MoveChat collects only the data strictly necessary, in accordance with the principle of data minimization. 4.1 MANDATORY DATA UPON REGISTRATION: • First name (the surname is neither requested nor collected) • Email address, to be confirmed with a code we send you: without that confirmation you cannot publish, cannot contact anyone and cannot become a Companion • Password (stored in encrypted form, not accessible even to us) • Date of birth (for age verification) • Phone number, never visible to other Users: we keep a non-reversible fingerprint of it, which prevents duplicate accounts, and a copy sealed with a public key, reopenable only with the private key kept outside our systems in the event of a breach of the Terms or a request from a judicial authority • Nickname (optional — if not provided, the name will be displayed) We ask for nothing else. In particular we do NOT ask for an identity document: it is not needed to register, nor for any feature of the Platform. Gender is optional and is indicated, if desired, after registration. 4.2 VOLUNTARY PROFILE CONTENT: Users may freely enrich their profile with additional information, which will be publicly visible to other Users. This content is entirely optional and can be removed at any time: • Profile photo • Descriptive tags (personality, music preferences, travel habits) • Driver preferences and extras • Links to social profiles (Instagram, Facebook, X/Twitter, TikTok, LinkedIn) 4.3 VEHICLE DATA (drivers only): To offer rides, drivers provide their vehicle details: • Make, model, type, colour, licence plate • Year of registration • Number of available seats • Vehicle photo (optional) 4.4 DATA GENERATED THROUGH USE OF THE SERVICE: • Ratings and reviews received from other Users • Departure and destination locations of published trips (entered manually by the User) 4.5 DATA NOT COLLECTED — MoveChat does NOT collect or store: • Continuous location tracking or the route travelled • Location read in the background, while the app is closed • Chat message content • Identity documents: we do not ask for them, we do not receive them and we do not store them • Selfies, verification photos or document scans • Biometric data (fingerprints, facial recognition) • Banking, credit card, or payment data • Health or medical data • Sexual orientation, political opinions, religious beliefs • Genetic data 4.5-bis WHEN AND HOW WE USE GPS: The Platform's map shows the cities Users type in manually. The device's GPS is used in two cases only, both tied to a trip in progress: • Location shared in chat: only when you press “share location”, and only for as long as you keep it on. It is end-to-end encrypted with your counterpart's key: MoveChat cannot read it. The encrypted data is deleted from our servers after ten minutes. • Ride start and end points: two positions only, with nothing in between — not the route. They are sealed with a public key: MoveChat cannot read them, and only the matching private key, held outside our systems, can open them. Purpose: establishing the facts after an accident, a breach of the Terms, or a request from a judicial authority. Legal basis: Art. 6(1)(f) GDPR, legitimate interest in establishing, exercising or defending legal claims. Retention: until you delete your account, and beyond that only if a report or measure concerning you is already open at the time of deletion (Art. 17(3)(e) GDPR). GPS is never read while the app is closed, and there is no continuous tracking of your route. 4.6 THIRD-PARTY SERVICES: To operate the app, certain data may be transmitted to the following services: • Google Places: location searches are sent to Google to return results. Google's Privacy Policy applies (https://policies.google.com/privacy). • Cloudflare (R2 and Workers): photos uploaded by users (profile and vehicle) are stored in a Cloudflare R2 bucket controlled by the Controller and served by our own Cloudflare Workers service. Cloudflare acts as a data processor (https://www.cloudflare.com/privacypolicy/). Each image URL contains a random identifier and does not reveal which account it belongs to; anyone who knows the URL can view the image, because photos must be visible to other users. When you delete your account, your images are deleted from the bucket. • ImgBB (only for photos uploaded before 25 October 2026): those images are hosted on ImgBB (https://imgbb.com), Privacy Policy at https://imgbb.com/privacy, and are publicly accessible via direct URL. ImgBB provides no automated deletion facility: those images are NOT removed when you delete your account. If you want one of them gone, write to us: the only route is a manual request to ImgBB, and we will file it. • Geoapify: address searches and route calculations are sent to Geoapify (https://www.geoapify.com/privacy-policy). It receives the search text and coordinates, not your identity. • SpacetimeDB: the application backend is managed through SpacetimeDB Maincloud, a service provided by Clockwork Labs Inc. User data is processed on Clockwork Labs infrastructure in accordance with their Privacy Policy available at https://clockworklabs.io/privacy. Servers are located according to Clockwork Labs specifications. For third-party services without a formal Data Processing Agreement (DPA), the Data Controller has informed users of their presence and the related data processing in this privacy notice, in compliance with Art. 13 and 14 GDPR.
5. What We Do Not Know - Full Transparency
By design and technical choice, MoveChat DOES NOT know and CANNOT know: CONTENT OF COMMUNICATIONS: • Messages exchanged between Users • Topics discussed in chats • Agreements made between Users • Phone numbers, addresses, or other data exchanged USER ACTIVITY: • Whether Users actually meet in person • What Users do outside the Platform • How frequently they use the Platform for real-life interactions FINANCIAL MATTERS: • Whether money is exchanged between Users • The amount of any financial contributions • The methods of any payments MoveChat is EXCLUSIVELY a communication platform. Once two Users begin chatting, everything that happens is exclusively between them. We DO NOT monitor. We DO NOT track. We DO NOT record. We provide only the technological tool for communication.
6. Chats and Messages - End-to-End Encryption
The server receives exclusively encrypted messages (NaCl/Curve25519 nonce + ciphertext). Plaintext content is never transmitted to or stored on the servers. Private keys remain exclusively on the user's device and are never sent to the server. Encrypted messages are automatically deleted when the associated trip expires. WHAT WE DO NOT DO - TECHNICAL GUARANTEE: • The server NEVER receives plaintext content: the send_message reducer rejects any payload missing a nonce and ciphertext • Decryption keys are generated and stored EXCLUSIVELY on the user's device • The Controller has NO technical means of reading the content of messages • Encrypted messages are automatically deleted when the associated trip expires (cascade delete of all related Message, ChatRoom, and Notification records) HOW CHATS WORK TECHNICALLY: Messages are encrypted on the sender's device with the recipient's public key, travel encrypted through our systems, and are decrypted only on the recipient's device. Copies of chats can be stored exclusively locally on the users' devices. LOCAL STORAGE (optional): • Only the User may choose to keep chat history on their own device • Storage occurs ONLY on the User's local device • MoveChat DOES NOT have access to locally saved messages • The user can save a companion to favorites to contact them again in the future (favorites are also stored only locally) This architecture ensures that: • Not even MoveChat can know what Users say to each other (technical impossibility) • In the event of legal requests, we have no chat data to provide • The privacy of conversations is technically guaranteed by E2E encryption
7. Zero Knowledge Architecture
MoveChat adopts a Zero Knowledge architecture based on NaCl/Curve25519 cryptography (ECDH + XSalsa20-Poly1305). The server receives exclusively encrypted messages in the form of a (nonce + ciphertext) pair. Plaintext content never passes through the servers. Private keys remain exclusively on the user's device, encrypted at rest (AES-GCM), and are never sent to the server. Encrypted messages are automatically deleted when the associated trip expires. TECHNICAL IMPLICATIONS: • The Controller does not have the technical ability to read, intercept, or recover the content of communications between Users • In the event of requests from Judicial Authorities, the Controller can provide exclusively connection metadata (timestamps, user IDs) but NOT the content of conversations • Deletion of messages from the User's device is definitive and irreversible LEGAL CLASSIFICATION: This architecture is consistent with MoveChat's classification as an information society service within the meaning of Direttiva 2000/31/CE and D.Lgs. 70/2003, as the operator exclusively provides the technical communication infrastructure without having knowledge of or control over the content exchanged.
8. Why We Collect Companion Data
The collection of additional data for Companions has the SOLE purpose of PROTECTING ALL USERS of the Platform. WHAT WE ACTUALLY COLLECT — all of it typed in by the User: • Type and expiry date of the driving licence • Insurance cover details • The declaration of not carrying out the activity professionally, with date and version This data is kept on a private table and is not visible to other Users. IMPORTANT - WHAT WE DO NOT DO: MoveChat does not request, does not receive and does not store identity documents: there is no identity verification procedure, no document check, no facial recognition. What is declared is a self-certification pursuant to D.P.R. 445/2000 and therefore: • Is NOT verified by us • DOES NOT constitute certification or guarantee of reliability • DOES NOT replace the User's personal responsibility • DOES NOT guarantee the safety of meetings or interactions The only automatic check is a calendar one: if the declared licence expiry date has passed, Companion status is revoked and the User can no longer contact anyone. We DO NOT use this data to: • Track User activities • Monitor User interactions • Engage in profiling of any kind
9. Data Sharing
MoveChat DOES NOT sell, rent, transfer, or exchange Users' personal data with third parties for commercial, advertising, or marketing purposes. Data may be shared EXCLUSIVELY with: 1. TECHNICAL SERVICE PROVIDERS - Hosting and cloud infrastructure (EU servers) - Push notification services These providers: - Are bound by confidentiality agreements (DPA) - Process data only on our instructions - Comply with high security standards 2. COMPETENT AUTHORITIES Only if required by: - Court order - Request from law enforcement - Legal obligation In such cases, we will inform the User if legally possible. We DO NOT share data with: • Marketing or advertising companies • Social networks • Data brokers • Any third party for commercial purposes
10. Data Security
We adopt advanced technical and organizational measures to protect personal data: TECHNICAL MEASURES: • Data encryption in transit (TLS 1.3/HTTPS) • Data encryption at rest (AES-256) • User passwords encrypted with secure algorithms (bcrypt) • Regular encrypted backups • Firewalls and intrusion detection systems • Continuous monitoring for unauthorized access • Regular security updates ORGANIZATIONAL MEASURES: • Data access limited to strictly necessary personnel • Staff training on data protection • Documented security policies and procedures • Periodic security audits HOSTING AND INFRASTRUCTURE: • Servers located in the European Union • Certified providers (ISO 27001, SOC 2) • Data centers with advanced physical security DATA BREACH: In the event of a data breach, we will notify: • The Supervisory Authority within 72 hours • Affected Users without undue delay As required by Articles 33 and 34 of the GDPR.
11. Data Retention
Personal data is retained for the strictly necessary period: RETENTION PERIODS: Account data: • Until account deletion by the User • Or until account closure by MoveChat Chat messages: • NEVER saved on servers (as explained in section 6) • There is nothing to retain or delete Companion self-declarations (licence type and expiry, insurance, exclusion of professional activity): • Until account deletion • We do not retain identity documents, because we never have any sent to us Security logs: • Maximum 12 months • Contain only technical data (IP, timestamps) • NEVER chat content AFTER ACCOUNT DELETION: • Data is deleted within 30 days • Some information may be retained longer if: - Required by legal obligations - Necessary for legal defense - Required by competent authorities
12. Your Rights (GDPR)
Under the GDPR, you have the following rights regarding your personal data: RIGHT OF ACCESS (Article 15) You may request confirmation of processing and obtain a copy of your data. RIGHT TO RECTIFICATION (Article 16) You may correct inaccurate or incomplete data. RIGHT TO ERASURE (Article 17) You may request the deletion of your data ("right to be forgotten"). RIGHT TO RESTRICTION (Article 18) You may restrict processing in certain circumstances. RIGHT TO DATA PORTABILITY (Article 20) You may receive your data in a structured and readable format. RIGHT TO OBJECT (Article 21) You may object to processing based on legitimate interest. RIGHT TO WITHDRAW CONSENT (Article 7) You may withdraw consent at any time. RIGHT TO LODGE A COMPLAINT (Article 77) You may lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali - www.garanteprivacy.it). HOW TO EXERCISE YOUR RIGHTS: Use the "Support" section in the app Specify: "Exercise of GDPR rights" We will respond within 30 days (extendable by 60 days for complex requests). Exercising your rights is FREE OF CHARGE.
13. Cookies and Similar Technologies
MoveChat uses EXCLUSIVELY strictly necessary technical cookies: COOKIES USED: • Session cookies: to maintain account access • Preference cookies: to store language and settings • Security cookies: to prevent CSRF attacks COOKIES WE DO NOT USE: • Profiling cookies • Advertising cookies • Tracking cookies • Third-party analytics cookies • Tracking pixels • Web beacons Pursuant to applicable legislation (ePrivacy Directive and the Italian Data Protection Authority Guidelines), strictly necessary technical cookies DO NOT require user consent; therefore, a cookie banner is not necessary. We DO NOT perform: • Cross-site tracking • Browser fingerprinting • Behavioral profiling
14. Data Transfers Outside the EU
Personal data is stored and processed on servers located in the EUROPEAN UNION. TRANSFER SAFEGUARDS: In the exceptional case of transfer to third countries, we ensure that: • The destination country offers an adequate level of protection (EU Commission adequacy decision) • Standard Contractual Clauses approved by the EU Commission are in place • The transfer complies with Chapter V of the GDPR CURRENTLY: • Data is processed and stored exclusively in the EU • We do not transfer data to non-EU countries • Our cloud service providers operate in the EU
15. Profiling and Automated Decision-Making
MoveChat DOES NOT perform: • User profiling • Decisions based solely on automated processing • Predictive analysis of User behavior • Automated scoring or evaluation of Users • Advertising targeting • Profiling-based personalization The User rating system: • Is based exclusively on manual ratings by other Users • Does not include predictive algorithms • Does not produce automatic legal effects
16. Minors
MoveChat is intended EXCLUSIVELY for Users of LEGAL AGE (18+ years). PROHIBITION OF USE BY MINORS: • We do not knowingly collect data from minors • Registration requires a declaration of legal age • Accounts of identified minors will be immediately deleted WHAT TO DO IF A MINOR HAS CREATED AN ACCOUNT: If a parent, guardian, or anyone else believes that a minor has created an account: • Report it immediately using the "Report" function in the app • The account will be deleted without delay • All associated data will be removed
17. AI-Assisted Support
Support requests sent to support@movechat.app may be initially handled by an automated system based on artificial intelligence. Users may at any time request to be connected with a human operator.
18. Amendments to the Privacy Policy
This Privacy Policy may be updated periodically to: • Comply with regulatory changes • Improve services • Correct errors or inaccuracies NOTIFICATION OF AMENDMENTS: We will notify substantial changes by means of: • A prominent notice in the application • Push notification (if enabled) • Publication of the new version with the date of last update ACCEPTANCE: Continued use of the Platform after notification constitutes acceptance of the new Privacy Policy. HISTORY: The date of the last update is always indicated at the top of the document.
March 2026