Legal template · Privacy · FADP / GDPR / CCPA

Privacy Policy (template).

A structured notice for a mobility product that is not yet carrying passengers. Roles, bases, rights, and transfers are written as they should look when counsel has reviewed them — they have not.

Template version · 30 August 2026 · not counsel-approved

1. Who we are

This template is published by TRELYAN Inc., a Delaware corporation (Delaware State File Number 10646511; EIN 42-3148928), principal address 311 11th Avenue, PH205, New York, NY 10001. TRELYAN Ride is a product of that company. TRELYAN Foundation is a Swiss Stiftung in formation (Zug) and is not yet entered in the commercial register. Contact: privacy@trelyan.ch and ride@trelyan.ch. See the imprint.

Until counsel confirms the controller map in writing, treat TRELYAN Inc. as the intended controller of personal data collected through this website and waitlists. Native apps, vehicles, and payment processors — when they exist — will be named in an updated notice.

2. Scope

This notice covers (a) this public website; (b) waitlist and inquiry forms; (c) email you send us; (d) intended processing for companion apps, rides, autonomy, and receipts, described prospectively so riders know the shape. It does not claim that vehicle sensor processing is already live in any named city on the /cities register.

3. Categories of personal data

3.1 Website and waitlists

  • Identity and contact: name, email, city of interest, free-text notes.
  • Technical: IP address, user-agent, timestamps, security logs as needed to run the site.
  • Preference: cookie acknowledgement in local storage.

3.2 Intended Ride service (not commercially operating)

  • Account: phone, payment tokens via a licensed processor (never full PAN stored by Ride if a processor is used).
  • Trip: origin, destination, times, accessibility flags, party size.
  • Autonomy and safety: exterior perception and vehicle telemetry as required to drive and investigate incidents.
  • Cabin: microphones/cameras only with notice and for assistance or incident modes.
  • Receipts: trip hashes and signature metadata; a hash is not the route itself but may be correlated.
  • Converse: chat content with the in-app assistant.
  • Support: tickets, recordings of remote assistance when a desk exists.

We do not seek special-category data except where you volunteer it (e.g. accessibility) or an incident requires it.

4. Purposes and legal bases

Swiss FADP and, where applicable, GDPR require a basis. Templates below; counsel will map each processing activity:

  • Website and waitlists: legitimate interests (responding to inquiries, building a trial list) and/or pre-contractual steps at your request; consent where a jurisdiction requires it for marketing.
  • Security: legitimate interests / legal obligation to keep systems safe.
  • Intended trips: performance of a contract (when Terms are in force and service is lawful); legal obligation (tax, incident, regulator); legitimate interests (safety, fraud); consent where required (certain cabin recording, marketing).
  • Autonomy improvement: legitimate interests with minimization, or consent, as counsel determines; never a hidden sale of sensor footage.

5. Switzerland (FADP)

The Federal Act on Data Protection applies to processing in Switzerland. You may have rights of access, correction, deletion, objection, and to data portability as provided by FADP. Complaints: Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern. A DPO is not claimed as appointed. Processing register: in formation (see operating licenses).

6. European Union / EEA / UK (GDPR / UK GDPR)

If we process personal data of people in the EEA/UK, GDPR/UK GDPR rights apply: access, rectification, erasure, restriction, objection, portability, and withdrawal of consent. You may lodge a complaint with your supervisory authority. An Article 27 representative is not appointed. International transfers from the EU, if any, will use an adequacy decision (including Switzerland where applicable) or SCCs — to be documented when transfers exist.

7. United States — California (CCPA/CPRA) and similar

California residents may have rights to know, delete, correct, and opt out of “sale” or “sharing” of personal information as those terms are defined in CPRA. Ride does not sell personal information for money. We do not currently run cross-context behavioral advertising on this site. To exercise rights, email privacy@trelyan.ch with “California privacy request.” We will not discriminate for exercising rights. Metrics and threshold analysis (whether Ride is a “business”) are in formation; this section is published so the structure exists.

Sensitive personal information (precise geolocation during a trip, account logins) will be used for providing the service and safety, not for inferring characteristics for ads.

8. Retention

Waitlist records: until you ask deletion, or a stated period after a trial program ends (intended: 24 months of inactivity). Security logs: typically 90 days unless an incident. Trip and sensor logs: to be set with counsel and regulators; incident locks override deletion until the investigation closes. Receipts on a public ledger, if ever written, may be technically indelible — that limitation will be disclosed before any such write.

9. Sharing

  • Processors: hosting (e.g. Vercel/Netlify), email, waitlist webhook if configured.
  • Converse (when live): message text is sent to whichever of IBM watsonx, xAI, OpenAI, and Anthropic are configured on the server. Those vendors process prompts under their terms. Degraded mode keeps replies local to this host. Do not put secrets or health data in the desk.
  • Intended: payment processors, mapping, insurers, auditors.
  • Law and safety: if required by law or to protect life, we may disclose.
  • No sale of rider lists as a brokerage product.

10. Children

This website is not directed at children under 16. A Ride service, if authorized, may allow minors only under rules set in the Terms and local law — not specified as available today.

11. Automated decisions

Waitlist intake is not an automated decision producing legal effects. Vehicle assignment and autonomy, when they exist, are safety-critical automated systems; human remote assistance is the escalation path. You will not be told a model “denied you credit”; Ride is not a lender.

12. How to exercise rights

Email privacy@trelyan.ch. We may need to verify you. Authorized agents (California) should include proof of authorization. Emergency: use local emergency numbers, not this inbox.

13. Changes

Material changes will be posted on this page with a new date. Counsel-approved versions will drop the template banner.