Effective: August 28, 2023

We may change this privacy policy from time to time. In the event of material changes we will i) inform you about these changes in advance and ii) inform you of your right to object to these changes

The Types of Information We Collect

We collect or receive information in different ways. The types of information we collect or receive depends on how you use and interact with our Services. In many cases, you can choose the information you provide to us, although certain information (such as account information) is required for us to provide the Services and if it is not provided, we will not be able to provide the Services. We use and disclose this information for the purposes described further below. The types of information we collect include:

• Account Information such as your name, e-mail address, telephone number, date of birth, gender, address details, and payment information such as your credit card details. In order to use certain products, we may also require you to provide photos of your government issued driver's license (front and back). When you purchase a Go Eco-branded vehicle on our e-commerce site, we'll collect your shipping information, we also collect government-issued ID and proof of low-income status for verification purposes.
• We collect and process location data when you sign up and use the Services. For example, to accurately show you Go Eco vehicles near your location, it is necessary to collect and record the physical location of your device. Data such as the location of the vehicle, the routes taken by the moped, bike, scooter, or other vehicle and its rental status are also necessary to provide the Services. In the event you register your own vehicle on our Services, we collect location data to show you the location of your vehicle and to enable you to lock and unlock it. We also collects location data directly from our vehicles including when our user is riding, such as journey information.
• When you use certain products (e.g. mopeds) that require a government-issued driver's license and the use of a helmet or other legally required protective gear, we will ask you (and your passenger, if applicable) to take a selfie which we collect, and we may collect images and/or video footage of your ride. By providing us images of your passenger, you represent that you have authority from your passenger to share such information with us.
• If you link, connect, or login to Go Eco with a third-party service (e.g. Facebook), the third-party service may send us information such as your profile information from that service.
• When you ask for customer service, support or other assistance, you can choose to provide us with your contact information so we can better respond to your requests and we may keep information about your engagement with our support services.
• GO ECO and third parties (such as Facebook) collect information from your browser , computer, or mobile device, which provide us with technical information such as your device's source IP address when you access or use the Services. We use cookies and similar tracking technologies (like pixels and tags) to provide our Services, including to protect the security of the Service, remember your settings and to gather analytics information about you. Third parties may use the technical information to provide measurement services and targeted ads. You can learn more about how we (and third parties) use cookies and similar technologies and how you can opt-out of the information being used for advertising purposes in our Cookies Policy.
• We collect information you share on the Services such as when you participate in communities or other forums, or comment on our social media accounts or blog entries. Depending on your camera or photo settings, we will receive information you choose to send us such as photos of parked our vehicles.
• We receive information about you when we use third-party partners such as marketing and advertising partners, such as social media networks.

How We Use Information

We use your information, including information about your location, to:

• provide the Services to you at your request including to manage your account and ride history. This includes where you access the Services via Integrated Partner services if applicable.
• confirm your government-issued driver's license (if provided) is valid, not currently linked to any other GO ECO account, and has not expired;
• verify your selfie matches your government issued driver's license such as by using facial recognition technology. You can read more about how we use facial recognition technology here;
• monitor, track and service the  vehicles, including when they are in use by you. Where applicable, this includes collecting images and/or video footage of your ride;
• confirm riders and passengers are wearing a helmet and other legally required protective gear, where required;
• ship or deliver products that you purchase through our e-commerce store or otherwise, including associating the unique ID code of any vehicles purchased through our e-commerce store with your account;
• process payments, subscriptions or donations and any discounts or special offers such as free unlocks;
• communicate with you about your account, interactions or transactions including service- related announcements such as changes to our policies. As allowed by local law, we may also send you surveys or marketing communications on behalf of Go Eco and/or third parties, including information about features and enhancements to our Services;
• where necessary, to comply with our legal obligations including to meet regulatory or local law requirements;
• detect, investigate, and prevent activities that may violate GO ECO's policies or User Agreement or be illegal which may include sharing information with government agencies outside of your home country, such as law enforcement agencies; and
• share and collaborate with third parties such as universities, local government authorities and other third parties to build or improve transportation infrastructure, as described in the "Who Do We Share Your Information With?" section below; and

IWho Do We Share Your Information With?

We share your information with Go Eco's affiliated companies, our service providers, other third parties where it is necessary to perform the User Agreement and as described in this Privacy Notice. In particular, we share your information with:

• For example, we share information with credit card issuers in order to process your payments and refunds.
• Collaborations with third parties : After removing certain identifiers, such as your name, phone, and e-mail address (where provided), and combining the resulting information with similar information from other users, We may use, license, and share your information, including individual trip records and trip location (journey) history, with third parties for research, business or other purposes. Government, regulatory and law enforcement agencies : We may share your information if we believe in good faith that it is reasonably necessary to do so for legal reasons, including to meet federal, state, regulatory or local law requirements or as part of a judicial process or to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues or to prevent harm or injury to you, members of the public, our staff, other third parties, or ourselves; or if we need to do so to defend our legal rights or property, to take action regarding illegal activities or traffic offenses, or to enforce our contracts, such as our User Agreement.
• Cities, local authorities and public transport operators : We share your information with these recipients where necessary to fulfill conditions of our license or where necessary to operate in a particular city or location or for the purposes of city planning and understanding mobility insights. This may include the recipients contacting riders to request participation in surveys and integration into public transport operators' apps and journey planning apps.

• Trip data, such as trip ID number, date and time of trip, distance of trip and duration of trip;
• Location data, such as location of the scooter and the routes taken by the scooter;
• Survey data, such as user identifier, survey date, survey type and question and answer (in the case of user experience surveys only). Such survey data may be onward shared by the DfT with their third-party research contractors for the purpose of e-scooter trials.
• Pseudonymised data such as vehicle ID, vehicle status, trip ID and waypoint.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

We do not sell or share your personal information with third parties for their direct marketing purposes, except with your consent.

Our Legal Basis for Using Your Information

In Europe, we are required to specify the purposes for which we process your personal information and the legal bases which we rely on to do this. We rely on a number of legal bases to collect, use, share, and otherwise process your information for the purposes described in this Privacy Notice, including where:

• it is necessary to provide the Services and perform our obligations in accordance with the User Agreement. For example, we cannot provide the Service unless we collect and process basic information about you and your location;
• you have provided your consent to us processing your information (in which case you may revoke your consent at any time);
• necessary to comply with a legal obligation, including, for example, responding to government agency or law enforcement information requests or to establish, exercise or defend legal claims;
• to protect vital interests of our users, staff, and members of the public both on and off the Services;
• it is permitted by law, we may process data in the public interest; and / or
• the processing is necessary for the purposes of Go Eco's or a third party's legitimate interests, provided that we have balanced these against your fundamental rights and interests.

More information on our lawful basis for processing your personal information is available here.

How Long We Keep Information

We keep your information for as long as is reasonably necessary to provide the Services to you or until your account is deleted, whichever is longer, subject to any longer period as may be required by applicable law or notified to you.

When you delete your account, it may take us additional time to fully delete your information from our databases and system logs. We may also retain information from deleted accounts to prevent fraud, collect fees, enforce the User Agreement, to comply with our legal obligations or enforce our legal rights.

While some of these rights apply generally, certain rights apply only in limited cases. Some of these rights may not apply to you if you are based outside the regions indicated below.  However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal, we may continue to use your information as permitted or required by law.

Your Choices and How You Can Manage Your Information : We believe you should have choices about the collection, use and sharing of your information. If you do not want Go Eco to collect your information, please do not use the Services.