Privacy Policy
1. Data controller
- AVENIDA SUBTIL - UNIPESSOAL LDA (Lux Transfers Travel Solutions) · Tax ID (NIPC) 516962515
- Address: Rua Mercedes Carlos Campeão, n.º 10, 3.º, 2460-067 Alcobaça
- Contact for privacy matters: suporte@luxtransfers.pt
2. What data we collect
| Data | From whom | What for |
|---|---|---|
| Name, email, phone number, gender, profile photo | Passengers and drivers | Create and manage the account; show it to the other person on the ride; "woman driver" option |
| Location (GPS) | Passengers: when requesting and during the ride. Drivers: while online, also with the app in the background | Find the nearest driver, navigate, calculate the price and route, safety (SOS) |
| Rides: pickup, destination, stops, route, times, price, ratings, tips | Passengers and drivers | Provide the service, invoice, pay drivers, handle complaints |
| Payments: method, status; MB WAY number | Passengers | Charge for rides. Card details are handled by Stripe; MOV neither sees nor stores them |
| Tax number (NIF, optional) | Passengers | Issue invoices with your tax number |
| Documents: licence, Citizen Card, TVDE certificate, criminal record, DUA, insurance, inspection, IBAN; car details | Drivers | Check the legal TVDE requirements and pay earnings. Each document is first read by an automated system (Anthropic) that points out anything that does not match; the decision to approve or reject is always made by a person on the MOV team |
| Calls and messages through the app | Passengers and drivers | Contact during the ride and lost and found. Calls are not recorded |
| SOS alerts with location | Passengers and drivers | Emergency help |
| Technical data: notification token, phone model and system | Passengers and drivers | Send notifications and solve technical problems |
3. On what legal basis
- Contract: to provide the service you ask for (account, rides, payments).
- Legal obligation: the TVDE law (Law no. 45/2018), invoicing and tax obligations (including SAF-T) and requests from the authorities.
- Legitimate interest: safety of passengers and drivers, fraud prevention and service improvement.
- Consent: notifications and access to location, camera and gallery, which you can withdraw in your phone settings.
4. Who we share it with
- Between passenger and driver on the same ride: name, photo, rating, pickup and destination, location during the ride and, for the driver, the car and licence plate.
- Service providers, who process data only on our behalf: Stripe (payments), Google (Firebase: authentication and notifications; Google Maps: maps and routes), Facturalusa (certified invoicing), Anthropic (automated pre-review of driver and company documents), Hostinger (server hosting).
- Authorities: IMT, the Tax Authority, police and courts, when the law requires it.
Some of these providers may process data outside the European Union; in that case the safeguards provided for in the GDPR are used (for example, the European Commission's standard contractual clauses). We don't sell your data.
5. For how long
- Account data: while the account is active.
- Rides, invoices and payments: 10 years, due to tax obligations.
- Driver documents: while the account is active and for as long as the TVDE law requires afterwards.
- SOS alerts: up to 1 year, unless they are needed in legal proceedings.
- Backups: up to 60 days.
6. Your rights
You can request access to, correction, erasure, restriction or portability of your data, and object to processing based on legitimate interest, by writing to suporte@luxtransfers.pt. We reply within one month. You can delete your account in the app (Profile → Delete account) or through the same contact; see how to delete your account (data the law requires us to keep, such as invoices, is kept for the legal period). You also have the right to lodge a complaint with the Portuguese Data Protection Authority, CNPD (www.cnpd.pt).
7. Security
Data travels encrypted (HTTPS), passwords are stored irreversibly, documents are only seen by the MOV team (after the automated pre-review described in section 4) and we make regular backups.
8. Minors
MOV is not intended for people under 18.
9. Changes
If we change this policy, we'll let you know in the app and ask you to accept it again.
See also the Terms of Use and the Electronic Complaints Book.