MUTE International Ltd and Subsidiaries Privacy Policy

Last update 1st September, 2022

Table of Contents

  1. Introduction
  2. Who we are
  3. Data Controller and Data Protection Officer
  4. Personal Data we collect
  5. How we collect Personal Data
  6. How and why we use Personal Data
  7. Information we collect from a Vehicle
  8. Cookies Summary
  9. Who we give your Personal data to
  10. Where we store your Personal Data
  11. Payment processing
  12. How we protect your Personal Data
  13. How long we keep your Personal Data
  14. Your rights
  15. Changes to this policy

1. Introduction

MUTE International Ltd (“MUTE”, “we” “us” and “our”) is committed to respecting the privacy of a customer’s (“Customer”, “you”, “your”) personal information (“Personal Data”, “Personal Information”, “Information”). 

We are required to comply with data protection legislation in respect of our processing of personal data, (which includes information about our staff, clients, customers and suppliers).

This notice will inform you about how we collect, use, dispose process manage and transfer of your Personal Data by MUTE International and its subsidiaries and franchises in other locations and jurisdictions. 

We are bound by privacy requirements and local laws in the countries in which we operate as may be applicable to you depending on where you are using our products or services, including

  1. If you are a habitual resident of the European Union, you are protected by and enjoy rights under the European Union’s General Data Protection Regulation 2016/679 (GDPR)
  2. If you are a habitual resident of the United Kingdom, you are protected by the Data Protection Act 2018
  3. If you are a national of China, you are protected by The Data Security Law (DSL) and Personal Information Protection Law (PIPL) 2021. We maintain a separate Privacy Policy for habitual residents and nationals of China. 

Other jurisdictions have data and personal privacy laws and regulations and if they differ in legal requirement from the above, we follow those when collecting, storage, using, processing, transmission, provision and disclosure for nationals of those countries and jurisdictions. We set out details of this in the Other Jurisdictions section below. 

Please read the following carefully to understand how we will treat and protect your Personal Data and how you can access and modify it. By visiting and using our App, visiting and using our Site, opening an account, registering and subscribing to use the MUTE Services and Vehicles you acknowledge that you have read, understood and agreed to this Privacy Policy. 

2. Static and dynamic content editing

MUTE International Ltd., ("MUTE") is a UK company with registration number 09905462 and address:

MUTE International Ltd

c/o Memery Crystal LLC

165 Fleet St, Holborn

London EC4A 2DY

United Kingdom

MUTE International Ltd.  is the parent of other MUTE subsidiary companies in China, Indonesia, Australia, Belgium and Spain, and this privacy notice is issued on behalf of all MUTE entities except China, (which has a separate privacy policy for nationals of China) so when we state “MUTE”, “we”, “us”, or “our” in the Privacy Policy we are referring to the relevant company within MUTE responsible for processing your personal data. 

3. Controller for processing of personal data and Data Protection Officer

For the purposes of UK, Swiss and EU Data protection laws, ("Data Protection Laws"), the controller for the processing of your personal data is:

MUTE International Ltd

c/o Memery Crystal LLC

165 Fleet St, Holborn

London EC4A 2DY

United Kingdom

We have a Data Protection Officer who is responsible for overseeing privacy and privacy compliance at MUTE.

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify, transfer or otherwise exercise your rights relating to your personal data, please contact our Data Protection Officer.

You can contact the Data Protection Officer at: or at the above address.

4. Personal Data we collect

This is information about you that you give us directly when you interact with us through our website, (“Site”), website app (“App”), direct communications, phone calls and face to face meetings. This information is required for us to offer the Services to you. Should you not wish to provide us with the information, you will be unable to use our Services. 

You can also see how we use the information in: Section 6: How We Use your Personal Information

Types and Examples of Personal Data

Identity and Profile Data:

Full name, Date of Birth, Usernames and passwords (logon credentials), Passport or other ID documents as required to show identity (both data and image format)

Contact Data:

Mailing and or billing address, email address, contact phone numbers.

Eligibility Data:

Driver’s license(s), CBT certificates (both data and image format)

Financial and Transaction Data:

Provided to our Payment Processor: Encrypted debit or credit cards details, bank information (including names, account numbers) if required for payment to and from you.

Technical Data:

URL, Internet Protocol (IP) address, login data, browser/device details and location/time zone.

Technical Usage Data:

Details of your use of the App and Site from Cookies (see Cookie policy here <link>

Vehicle Usage Data:

Data on the location (GPS or GNSS), route, direction speed as well as the status of the vehicle.

Device Location Data:

We do not currently collect mobile device location data, typically the GPS coordinates (latitude/longitude) of your device and/or (b) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.

Marketing Data:

Your preferences and contact (email, phone number) for receiving marketing or promotional data from us or third parties, if you have opted in or not unsubscribed.

Aggregated Personal Data:

We also collect, use (process) and store aggregated data such as demographic and statistical data derived from your Personal Data (though it is not personal data if it does not directly or indirectly identify you).

Aggregated Usage Data:

We collect aggregated Vehicle usage data (locations (start/stop/waypoints), trip patterns and frequency, which is not personally identifiable, for various uses.

Insurance Related Data:

While this is not usually Personal data, in the event that you are we have to make a claim for an accident caused by you or another party, certain types of information may be required to be given to us and the Insurer by you. This may include photographs, diagrams, witness statements, police and accident reports.

5. How We Collect Personal Data

The personal data and information is required generally to set up an account to use our Services, allow us to assess your eligibility to use our Services and Vehicles, for you to pay our subscription, administer your account, provide customer service, locate your vehicle, communicate with you about updates and resolve Service and Vehicle problems with you or if directed to relevant authorities. We use this information to inform you of promotions if you have opted to allow us to do so. 

How we collect your Personal data

Direct Interactions:

You may give us Personal Data by completing and submitting online forms, corresponding with us by email, phone, letter and face to face meetings. This includes personal data provided when you sign up on our App, Site for an account with us and apply to use our Services and Vehicles. 

Automated technologies/interactions:

As you interact with our Site or app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs

 and other similar technologies. Please see the Cookie section for further details.

Third Parties and Public Sources:

We may receive Personal Data about you from various third parties and public sources as set out below:

  • Analytic providers such as Google
  • Our payment processor Stripe
  • Our biometric ID verification processing provider 
  • Government agencies such as licensing authorities that hold publicly available driving records
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and insurance companies, professional services providers, cloud service providers and telecommunication providers.

6. How we use your Personal Data and Why

Generally, we rely on obtaining your implied consent as part of using our site, applying to use our Services and using our Services as our legal basis for processing your Personal Data (except for sending third party direct marketing communications to you via email or text message or, when required to by law). 

You have the right to withdraw consent to our or third party direct marketing at any time by contacting

Below we set out the ways we plan to use your Personal Data and the legal bases that we rely on to do so or where we have identified our Legitimate Interests in such processing.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please contact if you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will inform you and we will explain the legal basis which allows us to do so. We may also process your Personal Data without your knowledge or consent in compliance with law where this is required or permitted by law.

How we use your Personal Data and the basis for doing so:

Purpose/Activity for collecting / using your Personal Data

To register you as a new customer and an applicant for our Services

To process your payment to transactions and deliver goods or services including:

  • Managing subscription payments, fees and charges and refund
  • Collecting or recovering money owed to us
  • providing you with Customer Support

To manage our relationship with you which will include:

  • Notifying you about changes to our terms and conditions
  • Contracts or privacy policies, cookie policies or notices
  • Asking you to leave a review or take a survey

To administer and protect our business and our website or app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

To deliver relevant website and app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

To use data analytics to improve our website and app, products/services, marketing, customer relationships and experiences

To make suggestions and recommendations to you about products or services that may be of interest to you

To prevent or recover from Vehicle theft, loss or impoundment and to:

  • Provide support in the case of an accident or loss of Vehicle
  • To cooperate with and inform relevant authorities if we are legally required

Type of Personal Data

  • Identity and Profile
  • Contact
  • Identity and Profile
  • Contact
  • Financial and Transactional
  • Identity and Profile
  • Contact
  • Financial and Transactional
  • Marketing
  • Identity and Profile
  • Contact
  • Technical
  • Technical Usage
  • Identity and Profile
  • Contact
  • Technical
  • Technical Usage
  • Marketing
  • Technical
  • Technical Usage
  • Identity and Profile
  • Contact
  • Technical
  • Technical Usage
  • Identity and Profile
  • Contact
  • Vehicle Usage

Our lawful basis for processing including any legal basis relying on our Legitimate Interest to process Personal Data

  • To provide the Services to you on an initial basis (to open an account)
  • Our Legitimate Interest in conducting our Eligibility check
  • To provide Services to you on an ongoing basis
  • Necessary for our Legitimate Interest to transact payments
  • Performance of Contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our Legitimate Interest (to keep our records updated and to study how customers use our products/services
  • Necessary for our Legitimate Interest (for running our business, provision of administration and IT services, network security, to prevent fraud or in the context of a business reorganisation or group restructuring exercise or sale of us or any part of us to someone else or to subcontract any of our services)
  • Necessary to comply with a legal obligation
  • Necessary for our Legitimate Interest  to study how customers use our services or how our suppliers provide their products/services, to grow our business and to inform our marketing strategy.
  • Necessary for our Legitimate Interest - to define types of customers for our products and services, to keep our website and app updated and relevant, to develop our business and to inform our marketing and business strategy)
  • Necessary for our Legitimate Interests - to develop our products/services and grow our business
  • Necessary for our Legitimate Interests to work with insurance requirements and claims
  • Necessary for our legitimate interests to whom we are compelled or required to do so under law or in response to a competent or government agency or court order or where necessary to protect, defend or enforce the rights of the MUTE International.

7. Information we collect from a Vehicle

Through the onboard telematics embedded in all our Vehicles, we can collect information from you each time you use our Vehicles. This includes technical information, information about location, route, stopping points and how much time is spent at each location. This information is collected by a 3rd party company who provides it only to us only on request (that is, when we specifically ask for it). 

In the future, if you opt in, this may include the collection of the same data by our App- but does not as of this policy.  

This is to provide, if necessary ,  the location of your ride, to provide the location services that are dependent on knowing that location. This is so we can display to you in the App, the location of your Vehicle available bikes if it is necessary.

Your Vehicle can be tracked for the duration of any use, including any pauses. This also informs whether we treat the bike as being located outside a designated parking area, abandoned, lost or stolen and it may also be used for reporting any loss or theft of the bike to the Police. It can also be used to assess the condition of the bike (for example but not limited to an accident, damage or unauthorised use). 

You can choose to either limit location services to only when the App is in use or for as long as the app is active in the background of your device. Please refer to the App and 'Your Rights' section of this Privacy and Cookies Policy to learn more.

8. Cookies Summary

Our Site and mobile web App uses cookies and/or other similar technologies ('Cookies') to collect and store certain information. These typically involve pieces of information or code transferred to or accessed from, your device to store and sometimes track information about you. Cookies enable you to be remembered when using that device to interact with online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

Some are essential to provide you with the service you register for. Otherwise you set your cookie choices and you can change them at any time. However, you may not be able to take full advantage of our App if you do so.

We use Cookies to create a unique device ID for the following uses.

  • Strictly necessary Cookies. These are required for the operation of our App and under our terms with you. They include validating your access to your account.
  • Functionality cookies. These are used to recognize you when you return to our App. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences.
  • Analytical/performance Cookies. They allow us to recognize and count the number of users and to see how visitors move around the App when they are using it. This helps us for our legitimate interests of improving the way our App works, for example, by ensuring that users are finding what they are looking for easily.
  • Customization cookies. These help us to tailor and manage our App content and messaging to those communications that are relevant to you.

Instructions for how to activate and deactivate cookies varies on what browser you are using. Please click on the following links to find out how to manage cookies on your browsers:

You can also read our Cookie Policy here

9. Who we give your information to

We may give your information to selected third parties. Our selected third parties may include:

  • Organizations who process your personal data on our behalf and in accordance with our instructions and Data Protection Laws. This includes in supporting the services we offer through the App in particular those providing and hosting the App platform, providing fulfilment services, distributing any communications we send, facilitating feedback on our services and providing IT support services from time to time. These organizations (which may include third party suppliers, agents, sub-contractors) are required to only use your information to the extent necessary to perform their support functions
  • Analytics and search engine providers that assist us in the improvement and optimisation of the App - subject to the Cookies section of this policy (this will not identify you as an individual)
  • Payment service providers who provide secure payment processing services – see Payment Processing
  • Partners in the 'first 10 minutes free' scheme as described in Profiling and Direct Marketing and to provide analytics on carbon emissions
  • We will disclose your personal information to third parties:
  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
  • If MUTE or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect our rights, property, or safety and those of our customers, or others.

10. Where we store your information

The data that we collect from you is stored in an Amazon Data Centre located within the EU. Our host provider is Zoho.  

Personal data may be transferred to, and stored at, a destination outside the EU, which may not be subject to equivalent Data Protection Laws. If so we will take reasonable steps to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

We may transfer your personal information outside the EU:

Where we are legally required to do so.

In order to facilitate the operation of our business, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

Please see Contact Us for details on how to request information on protecting your personal data if transferred outside the EU.

11. Payment processing

Payment details you provide will be encrypted using leading technology and software before they are submitted over the internet. Payments made on the App and Site are made through our payment gateway provider, currently Stripe. 

You will be providing credit or debit card information directly to the payment services provider which operates a secure server to process payment details, encrypting your credit/debit card information and authorizing payment. Information which you supply to the payment services provider is not within our control, not stored or processed by us and is subject to its own privacy policy and terms and conditions.

Stripe’s Privacy Policy can be viewed here:

12. How we protect your information

All information you provide to us is stored on secure servers. Any payment transactions handled through our payment gateway provider are subject to their Payment Card Industry (PCI) certification. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our App you are responsible for keeping this password confidential. It is important that you do not share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our App may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

13. How long we keep your information

We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

14. Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to marketing or to the further processing of your personal data;
  • to request that your provided personal data be moved to a third party.
  • You may opt out at any time from allowing further access by us to your location data by altering the privacy settings of your device. You can also stop all information collection by un-installing the App. You may use the standard un-install processes as may be available for your mobile device. Please note however that location services are integral to administering and delivering the hire of the bike
  • Your right to withdraw consent

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.

You can exercise the rights listed above at any time – see Contact Us.

If your request or concern is not satisfactorily resolved by us, you may approach the data protection authority. The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

15. Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by email.