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White Fox Scooters Privacy Policy

Last Updated: August 1, 2019

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We are committed to providing you notice about how White Fox Scooters, Inc. and our affiliate and subsidiary companies (together, “White Fox Scooters” or “we”, or “us”, or “our”) handle your information. This White Fox Scooters Privacy Policy (the “Privacy Policy”) applies to the information, that we collect and process about users of our Services, and those who communicate with us about our Services, interact with us on social media, attend our events, participate in our surveys, contests and promotions, or are subscribed to our marketing and informational communications (the “Interactions”). In this Privacy Policy, “Services” means:

  • White Fox Scooters websites that link to this Privacy Policy, including any versions optimized for viewing on a mobile device (the “Sites”),

  • White Fox Scooters mobile applications (each an “App”),

  • White Fox Scooters vehicles (each a “Vehicle”), and

  • the features and services available through our Sites, Apps and Vehicles

We have established this Privacy Policy to let you know the kinds of information we may gather during your use of the Services and related other Interactions, how we use your information, when we might disclose your information, and your rights and choices regarding your information that we collect and process.

For all users, White Fox Scooters, Inc, 155 2nd Street, Jersey City, NJ, USA is the responsible entity (or data controller) for your information.

This Privacy Policy contains the following sections:

  • The Information We Collect

  • Use and Processing of Information and EU Legal Bases

  • Disclosure of Your Information

  • Use of Cookies and Other Online Tracking Technologies

  • Online Advertising

  • How We Protect Your Information

  • Retention of Your Information

  • International Users

  • Third Party Links and Services

  • Changes to this Privacy Policy

  • Your Choices

  • EU Data Subject Rights

  • Privacy Information for New Jersey Residents

  • Contact Information

THE INFORMATION WE COLLECT

We collect information related to our Services and Interactions directly from users, automatically related to their use of the Services and our Interactions, as well as from third parties. We may combine the information we collect from these various sources.

Information You Provide to Us. We collect information directly from users:

  • Account registration, management, profile creation and modification

  • Account access and use, as well as uploading content to the Services and other associated activities

  • Vehicle use

  • Access to and use of the Sites and Apps

  • Submission of payment information

  • Event registration and attendance

  • Participation in surveys, contests, sweepstakes and promotions sponsored by White Fox Scooters

  • Signing up to receive alerts or other information via email, text or instant messages from White Fox Scooters

  • Customer service, technical support, and related communications

  • Participation in communities, commenting on blog entries, interacting with use on social media, and participation in other forums

  • Submission of an application or resume to work at White Fox Scooters

The types of information we collect directly from you are: your name, e-mail address, phone number, postal address, other contact information, credit card and billing details, including billing address, communications preferences, payment and transaction history, where required your birthdate and driver’s license information or other identification card, and any other information you submit to the Services or otherwise provide to us. We also collect certain demographic data if you provide it to us including age, gender, preferred language, and current location.

Automatically Collected Information. We also collect information through automated and technical means as you browse our Sites, use our Apps, or otherwise use the Services:

  • Device and Online Usage. We collect information about your computer, browser, mobile or other device that you use to access the Services. We may use cookies, pixels, log files and other similar technologies to collect such information, including IP address, device identifiers and other unique identifiers, browser type, browser language, operating system name, and version, device name and model, version, referring and exit pages, dates and times you access our Services, the length of time that you are logged into or using our Services, the links you click or features you use, software crash reports and session identification number. Please see the “Use of Cookies and Other Online Tracking Technologies” section below or our Cookie Notice for more information.

  • Location Info and Vehicle Usage. We automatically collect and store location information from your device and from any Vehicles you use. We collect and store the location information (e.g., city, state or zip code where available) associated with the IP address of the device you use to access the Services, as well as, with your permission, your mobile device’s location information using GPS or Bluetooth (you can change your location/Bluetooth settings for your mobile device; however, certain features may not be available through the App if you do so).

  • Analytics: We compile and analyze information derived from the use of our Services, such as aggregate usage patterns, user preferences, peak demand times, common routes and other information.

Information We Collect From Third Party Sources. In some cases, we collect user information from third parties.

  • Third Party Platforms and Social Media Sites. When you interact with us or post content about us on third-party social media platforms – like Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube or Pinterest – we may collect certain information about that interaction; the information that we may collect is based on your settings on and the policies of these social media platforms. We may also allow you to post certain information from these platforms to your White Fox Scooters profile, and permit you to login to the Services using your third-party social media account, in which case you will be asked to consent to our access and collection of certain information from your social media profile, subject to the policies of that platform.

  • Other Third-Party Sources. We also may collect information about you that we may receive from business partners, marketers, analysts and other sources to, enable us to verify and update information contained in our records and better customize the Services for you. We may also collect information from credit reporting agencies to determine your creditworthiness, credit score and credit usage, in compliance with and to the extent permitted by applicable laws.

  • Referrals. We may from time to time conduct a referral service so that you may introduce people you know to our Services, in accordance with applicable local laws. If you choose to use our referral service to tell someone about our Services, we will provide you with a template message and referral code to send to your friend. We will not collect the referral’s information unless he/she signs up to use the Services with the referral code.

USE AND PROCESSING OF INFORMATION AND EU LEGAL BASES

We generally use the information we collect from and about you to provide and operate the Services, respond to user requests, for customer service and support, to protect our rights and those of others, to send marketing communications, to help us personalize user experiences and to improve the Services, as explained in more detail below.

Legal Bases for Processing Under EU Law. Where EU data protection law applies, we process your personal data as defined by applicable EU law for the purposes set out in the table below, under the following legal bases:

  • Our Contract With You. Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you (e.g., to verify the information you have provided to us and provide the Services to you).

  • Our Legitimate Interests. Our processing is necessary for our legitimate interests, including to protect the security our Services; to protect the health and safety of others; to establish, protect and defend our legal rights and interests; to monitor and protect our Vehicles; to prevent fraud and verify identity and authorization of users; to personalize user experiences and content; to understand and analyze usage trends; and to improve the Services.

  • Legal Compliance. Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes).

  • Your Consent. When we have your consent as defined by applicable law.

In addition, we may process information to the extent necessary to protect the health, safety or vital interests of any person and to establish, protect and defend our legal rights.

Purpose of Use and Processing. Generally, we use the information we collect as set forth in the below table:

Purposes of Use and Processing of Information

EU Legal Bases

Providing Support and ServicesTo provide and operate the Services and related features, fulfill your orders and requests and to process your paymentsTo update the ServicesTo track Vehicles, including location, battery levels and rental statusTo permit you to update, edit, and manage your contentTo communicate with you about your use of the Services and respond to your inquiries and complaintsFor troubleshooting, technical and customer service and support purposes

Our Contract with YouOur Legitimate InterestsProtect Legal Rights

VerificationTo verify the identity of users, applicants and others with whom we interactTo confirm authorization of users that access and use the Services

Our Contract with YouOur Legitimate Interests

Improve Services and AnalyticsTo create anonymous or aggregate informationTo optimize or improve our products, services and operationsTo perform statistical, demographic, and marketing analyses of our users, to analyze and understand usage and activity trends, demographic trends and for other research, analytical, and statistical purposes

Our Legitimate Interests

Communicate with YouTo communicate with you about your account or transactions with us (including Services-related announcements) or your comments to a blog postTo communicate with you about changes to our policies

Our Contract with YouOur Legitimate InterestsProtect Legal Rights

Personalize Services and AdsTo personalize content and experiences on our Services, including providing you reports, recommendations, and feedback based on your preferences, and to use your location information for personalization purposesTo better target ads so that users receive ads that are relevant to them

Our Legitimate InterestsYour Consent

Marketing and PromotionsTo send you information, news, updates and offers about us or our Services (subject to your consent where required by applicable law)For other direct marketing and promotional purposes

Our Legitimate InterestsYour Consent

Protect Legal Rights and Prevent MisuseTo protect the Services and our business operationsTo detect, investigate, prevent or take action regarding illegal activities, misuse, suspected fraud or situations involving potential threats to the safety or legal rights of any person or entity, and as evidence in litigationTo investigate, enforce and prevent violations of our policies and terms (including this Privacy Policy, our Terms of Use and Rental Agreement)As otherwise necessary to establish, protect and defend our legal rights

Our Legitimate InterestsOur Contract With YouProtect Legal Rights

Complying with Legal Obligations To comply with the lawTo respond to legal process or enforcement or legal process requests, e.g. in response to subpoenas, court orders and other lawful requests by regulators, courts and law enforcement agencies, or related to national security requests

Legal ComplianceOur Legitimate InterestsProtect Legal Rights

General Business OperationsWhere necessary for the administration of our general business, accounting, recordkeeping and legal functionsAs part of our routine business administration, such as employee training, compliance auditing and similar internal activities

Our Legitimate InterestsProtect Legal Rights

DISCLOSURE OF YOUR INFORMATION

We disclose the information we collect, in the following ways:

  • Affiliates and Subsidiaries. Amongst our affiliated and subsidiary companies in furtherance of the purposes set out in this Policy; their use of your information is subject to this Privacy Policy.

  • Business Partners and Third Parties.  We may share your information with business partners who jointly sponsor events with us, from time to time; where required by applicable law, we will obtain your prior consent. You may at any time withdraw your consent or tell us to stop sharing your personal information (as defined under applicable law) with business partners and third parties by following the opt-out process described in the “Your Choices” section below. If you use the Services through a third-party platform that manages its own fleet of White Fox Scooters vehicles, we will also share your information with the platform operator to assist in operating the Services.

  • Third-Party Service Providers. We use a variety of third party service providers that perform functions on our behalf, such as hosting, billing and payment processing, push notifications, storage, bandwidth, content management tools, analytics, customer service, fraud protection, etc.

  • General Business Operations. Where necessary to the administration of our general business, accounting, record keeping and legal functions, to our tax advisors, legal counsel and other professional services entities or agents.

  • Legal Compliance and Protection of Rights. We may also use or disclose information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Services; (b) establish, protect and defend our rights or property, the Services or our users, including to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use, Rental Agreement, other agreements or policies, or as evidence in litigation in which we are involved; and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or users of the Services or the public. This includes exchanging information with other companies and organizations for fraud protection.

  • Other Users.  Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential and may be accessed by others. For example, if you submit a product review on one of our Sites, we may display your review (along with the name provided, if any) on other White Fox Scooters Sites and on third-party websites. Moreover, if you provide a comment on our blog, other blog readers will be able to review your comments, and if you interact with us on our social media pages, your comments will be publicly available. So, please take care when using these features. If you’d like to request removal of information that we have posted about you, please contact us as set forth in the “ Your Choices” section below.

  • Aggregate/Anonymous Information. We may share aggregate/anonymous information about use of the Services with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual, such as by publishing a report on usage trends. The sharing of such data is unrestricted.

  • Business Transfers. As we continue to develop our business, we may seek to buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

To request more information about the companies to whom we have disclosed your information, please contact us as set out in the “Contact Information” section.

USE OF COOKIES AND OTHER ONLINE TRACKING TECHNOLOGIES

Like most Sites and Apps and online Services, we use “cookies,” web beacons (a/k/a pixel tags), analytics devices and similar technologies (some of which are operated by third parties) to record your preferences, gather information about the use of our Services, personalize content and ads and track information about the performance of our advertisements. We may also use these technologies to monitor traffic and make the Services easier and/or more relevant for your use. We may combine this information with other information we collect from you.

Cookies. These are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes and associate with small text files that we use to record certain information regarding your use of our online Services, your preferences and actions, and other device and usage data as described above. Some cookies allow us to make it easier for you to navigate our Sites, Apps, and Services, while others are used to enable a faster log-in process, personalize your use of the Services, or otherwise allow us to track your activities while using our Services. Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline or block cookies if you prefer. If you delete your cookies or if you set your browser or device to decline or block these technologies, some features of the Services may not work or may not work as designed.

Pixel tags (a/k/a web beacons or clear GIFs). Pixel tags are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages or within emails. We or our service providers may use pixel tags in connection with our Services to, among other things, track the activities of users of the Site and App, help manage content, measure ad performance and compile statistics about usage. We or our service providers also use pixel tags in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Analytics Services. We use third-party analytics services, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Services. Google Analytics uses cookies and other tracking technologies to help us analyze how users interact with and use the Services, compile reports on user’s’ activity, and provide other services related to activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. To learn more about Google’s analytics services and to learn how to opt out of tracking of analytics by Google click here. We also use MixPanel to collect information about site usage. For more information and to opt out of MixPanel tracking technologies, please click here.

For more information about our use of cookies, third-party analytics and other tracking devices, please see our Cookie Notice.

ONLINE ADVERTISING

In order to display more relevant advertising on our Services, to manage our advertising on third-party sites, mobile apps and online services, and to measure and improve our ads and marketing efforts, we may work with Facebook, Google and other third-party ad companies, ad exchanges, channel partners, measurement services and ad networks. Please see the “Use of Cookies and Other Online Tracking Technologies” section below or our Cookie Notice for more information.

These third parties may use cookies, web beacons or other tracking technologies to collect information about your use of the Services and your activities across other websites and online services, which they may associate with persistent identifiers. This information may be used to provide you with more relevant advertising or other targeted content on our Services and other websites or services, and to measure the performance of such advertising. Their activities and your choices regarding their use of your information to personalize ads to you are subject to and set out in their own policies.

More Information. For more information and to exercise your choices regarding Facebook and Google ads:

Facebook (more info: privacy policy; choices: ad preferences page), and

Google/DoubleClick (more info: privacy policy; choices: ads help page)

You can also learn more about online advertising at www.aboutads.info/consumers and opt out of interest-based advertising from many participating ad companies at the ad industry websites below:

Canada: www.youradchoices.ca

EU: www.youronlinechoices.eu

U.S.: www.aboutads.info

Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see:

Apple: http://support.apple.com/kb/HT4228

Android: http://www.google.com/policies/technologies/ads/

Windows: http://choice.microsoft.com/en-US/opt-out

Please note that opting-out of advertising network services does not mean that you will not receive advertising while using our Services or other services, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs.

Do-Not-Track. Your browser or device may include “Do-Not-Track” settings or functionality. Currently, our systems do not recognize browser “Do-Not-Track” requests. White Fox Scooters’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy, whether or not a Do-Not-Track signal is received. However, you may disable certain tracking on our Sites, as discussed in this section (e.g. by disabling cookies), and you may opt-out of certain third party ad networks as described below. For more information about Do-Not-Track signals, please click here.

HOW WE PROTECT YOUR INFORMATION

We take technical, physical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. We encourage you to take steps to protect your information and prevent unauthorized access to your password or account by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

RETENTION OF YOUR INFORMATION

We retain your information a for as long as required to satisfy the purpose for which it is collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to establish, protect, or defend legal claims.

You may exercise your rights or make a request regarding your information held by us, request further information about your legal rights under applicable law, or submit a complaint about our privacy practices by contacting us at any time, using the contact details set forth in the “Contact Information” section below.  You may also access and modify much of the information that you have submitted by logging into your account and updating your profile. Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Sites or Apps for a period of time. In addition, we may retain certain information about you as required by law or as permitted by law for legitimate business purposes. For example, if you request that we delete your information but we believe that you have violated our Terms of Use, we may retain information about you in order to attempt to resolve the issue before deleting it.  Moreover, you will not be permitted to examine the information of any other person or entity.

We will consider all requests and provide our response within the time period stated by applicable law. We also may request you provide us with information necessary to confirm your identity before responding to your request.

Complaints. If applicable, you may make a complaint to the privacy regulator or supervisory authority in the country where you are based. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.

If you are a New Jersey resident, New Jersey law requires us to provide you with additional information regarding how we collect, use, and share your “personal information” (as defined in the New Jersey Consumer Privacy Act (“CCPA”)).   

Categories of personal information we collect  

Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about our users.  Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we may collect are:  

  1. identifiers (such as name, address, email address); 

  2. commercial information (such as transaction data); 

  3. financial data (such as credit card information collected by our payment processors on our behalf); 

  4. internet or other network or device activity (such as browsing history or usage information); 

  5. geolocation information (e.g., your approximate location based on IP address, or precise location with your consent);

  6. inference data about you (e.g., the additional services we think would be of most interest to you based on your interactions with us); 

  7. demographic information (such as gender and age); 

  8. insurance (including health insurance) information

  9. other information that identifies or can be reasonably associated with you.

How we source, use, and share these categories of personal information  

We source, use, and share the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy.  See the “Information We Collect,” “Use and Processing of Information and EU Legal Bases,” and “Disclosure of Your Information” section(s) above for more information.

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties.  We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.

Your New Jersey Privacy Rights 

CCPA Rights Disclosure.  If you are a New Jersey resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. 

  • Provide access to and/or a copy of certain personal information we hold about you.

  • Delete certain personal information we have about you.

  • Provide you with information about the financial incentives that we offer to you, if any.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.  Please note that certain information may be exempt from such requests under New Jersey law. For example, we need certain information in order to provide the Services to you.  We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you.  If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you. If you would like further information regarding your legal rights under New Jersey law or would like to exercise any of them, or if you are an authorized agent making a request on a New Jersey consumer’s behalf, please contact us at contactus@whitefoxscooters.com.

New Jersey Shine the Light Disclosure.  New Jersey Civil Code Section 1798.83 permits customers of White Fox Scooters who are New Jersey residents to request certain information, once per year, regarding our disclosure of their personal information (as defined by New Jersey law) to third parties for their own direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. To opt out of future sharing for these purposes, please send an e-mail to contactus@whitefoxscooters.com.

CONTACT INFORMATION

If you have any questions about this Privacy Policy, would like to exercise your rights regarding your information that we hold, or would like to raise a complaint with us related to your information, you should contact us as follows: contactus@whitefoxscooters.com.

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