Privacy Policy

+ Intro

This Privacy Policy (“Privacy Policy”) describes how Superpedestrian, Inc. (including its subsidiaries and affiliates) collects, uses and discloses your personal data and information (the “Information”) if you use our scooter rental service, our websites and/or our mobile application (“App”) (collectively, the “Services”). The name and address of the controller of your Information depends on where you are using our Services, and the controllers for each country are listed below under “Contact Information”. Each controller is referred to herein as “Superpedestrian,” “we,” “us” or “our”. This Privacy Policy sets forth the Information we collect, use, and share and the purpose and legal basis for doing so.

If you use our Services in the European Economic Area, Switzerland, the United Kingdom, or in California, please see the section titled “Additional Rights” below for more detail concerning your rights under applicable laws.

Please do not use our Services unless you have read and understood this Privacy Policy and have no objection to it. If you use our Services outside the European Economic Area, Switzerland and the United Kingdom, you consent to your Information being handled as described in this Privacy Policy when you use our Services. We reserve the right to change this Privacy Policy from time to time. If we make changes, the updated Privacy Policy will be made available through our Services, and we will provide notification of material changes through our App.

Please also read our Terms and Conditions, which govern provision of our Services in various countries, including any disputes about your account or your Information.

+ Information We Collect

Information You Provide We collect or obtain your Information when you use and interact with our Services. The types of Information we collect or obtain vary depending on how you use our Services. If you rent our scooters, we require you to establish an account with us so we can provide the scooter service. If you choose not to provide the required information, or request that we delete it, you may not be able to use or access our scooter rental service. Visits to our web sites and App do not require signing up for an account.

The types of Information we collect or obtain include:

Account Information. When you open an account to use our scooter rental services, we require that you provide a mobile number for the phone on which you are using our App. You may also provide your name and e-mail address on the account.

Payment Information. When you provide us with payment card information in order to rent our scooters, the information you provide is collected and processed directly by our payment processor in the location where you rent the scooter. We do not receive or store your full credit card information, only a unique identifier, the name provided with the card, and access to the payments charged for our Services.

Identity Verification. In certain cities, we are required to confirm your eligibility to ride our scooters by checking your driver’s license or similar government ID. If you do not provide your ID, you will not be able to use our scooter services in this city. When you choose to ride our scooters in these cities, we will prompt you to provide your identification information which is transmitted to a third-party provider for processing. From time to time, we may offer discounts or free rides to essential workers or students and require proof of employment as an essential worker or student status to receive the discount or ride. In some locations, we offer special pricing for low-income riders, and we may require you to provide identification and address information showing eligibility for low-income programs to qualify for this benefit. For some adaptive vehicle rentals, we may require you to provide additional identity or location information in order to deliver the vehicle to you.

Location Data. When you use our scooter rental services, it is necessary to collect and process location data from the scooter and your mobile device running the App used to complete the rental. In order to use our scooter rental services, you must turn on location services permissions on your phone so we can use the location of your phone to show you available scooters nearby and set the pricing based on the city where you are renting our scooters. If you do not allow access to location services on your phone, you will not be able to use our scooter rental services. Once you activate and begin to ride a scooter, we collect location data directly from our scooter, including location start and stop points, route traveled, vehicle status and condition, and other data points necessary to provide the Services. When you park the scooter, we use the location data from your phone as well as data from the scooter to confirm the scooter is properly parked in a valid location. We also use location data to improve our Services and to prevent theft, fraud and other misuse of the Services.

Customer Support and Claims. When you contact us by phone, email or via our App for customer service, support or other assistance, we may record or store that information about your engagement with our support services. When you report an issue with the scooter service, we ask for your name and email address to communicate with you and address your reported issues or customer support needs. If you choose to make a claim for injury or damages after using our scooter services, we may request that you provide additional information to us or a third-party administrator for the insurance carrier regarding any property damage or injuries so we may evaluate your claim and/or inform the insurance carrier.

Photos and Social Media. We may collect and store any Information you choose to share publicly or send to us voluntarily, such as photos, comments, messages or other user-generated content, on our social media, messaging or email accounts. We may also collect and store any Information you share in connection with research, surveys, or giveaways/contests.

Device Information and Identifiers. When you use our Services, we collect and analyze information such as your IP address, device type and identifiers, device service provider, operating system, and the state or country from which you accessed the Services.

Browser Data and Cookies. We use third-party cookies through Google Analytics and/or Squarespace Analytics to collect information from your browser, computer, or mobile device when you access or use our websites. You can learn more about how Google Analytics uses this data here and Squarespace Analytics here. These analytics programs use cookies and similar tracking technologies to help us understand how people use our site, remember when you return to a site, and how you navigate and engage with content on our site. On our scooter rental App, we use app logging provided by a third-party service (currently Segment) to log when you launch the app, navigate through various links, pages or features on the app, and encounter any error messages in using the app. You can learn more about how we use cookies and similar technologies in our Cookie Policy.

+ How We Use Your Information

We specify below the purposes for which we collect, use, share, or otherwise process your Information and the legal basis for why we do so, including the following:

To Provide Scooter Rental Services: The main purpose we use to collect and process your Information is to provide our Services to you at your request, particularly our scooter rental service. This purpose requires us to process your Information to:

• create and manage your account
• communicate with you about your account, interactions, or transactions including service-related announcements such as changes to our policies and/or information about features and enhancements to our Services
• provide quality scooter rental services through our App
• process your payments for our scooter rental services
• ensure compliance with rules and regulations while you ride and park our scooters, including location based geofencing and parking restrictions
• monitor the precise location of our scooters, including while you are riding them, to comply with local rules and to avoid theft or vandalism
• procure insurance
• address customer service requests or claims
• verify your identification to comply with rules or verify eligibility for discounted programs, where requested
• manage your ride history and receipts/invoices

The legal basis for this purpose is to fulfill our contract with you to provide the Services. We cannot provide our scooter rental service to you without collecting and processing your Information, including precise location data. We need your account information to allow you to use our App to rent scooters and your device location data to locate scooters available to rent and charge you the appropriate pricing for that location. We also need information about the location of any vehicle while you are riding it, the start and end points, the routes taken on the vehicle, rider behavior during the trip as it relates to rules and regulations, and where the vehicle is parked in order to provide the Services to you. We also fulfil our contract with you by communicating about your account, including service-related announcements such as changes to our Services, and engaging in customer service interactions when you request.

To Comply with Legal Obligations: We also process your Information for the purpose of complying with laws, regulations, local ordinances, and valid local law enforcement requests. The legal basis for processing your Information is that we are required to do so to meet our legal obligations. We may process and share your Information:

• when it is reasonably necessary to do so for legal reasons, including to meet federal, state, regulatory, or local law requirements in the location where you ride our scooters
• in response to valid requests from law enforcement in connection with an investigation of an incident, or as part of a judicial process, or to take action regarding illegal activities or traffic offenses, to prevent fraud or to address technical issues or abuse
• to share certain Information including account, trip route and location data with cities, local authorities and transportation authorities, including through their required software vendors, where necessary to fulfil conditions of the permits, contracts, or licenses granted to us
• to share certain Information with local law enforcement and other government agencies for the legitimate interests in investigating and preventing crime, fraud, or other illegal use or abuse of our Services

The categories of Information shared will depend on the specific factual circumstances but could include your account information, your mobile phone number, date of birth, name and email address if known, payments made, device information, trip data and location data.

To Better Manage and Improve Our Services: We process your Information to provide high quality scooter rental services and to improve and optimize our Services, including our scooter rental App and Sites. The legal basis for this purpose is to further our legitimate interests in improving and optimizing our Services in order to maintain and grow our business by better serving our users. We process your Information to protect our legitimate interests to:

• better manage our fleet of scooters, including to ensure availability, monitor usage levels, track battery charge levels, and other required maintenance checks
• provide vehicles which are in good working order and to protect our property from damage or theft
• provide high quality user experiences on our App and Sites and to improve and optimize the Services
• protect the security and safety of our Services and to investigate and prevent violations of our Terms and Conditions, or other fraud and abuse of our Services or accounts
• share information with law enforcement and other government agencies for the legitimate interests in investigating and preventing crime, fraud, or other illegal use or abuse of our Services
• to conduct internal business operations in support of our Services, such as improving security, processing claims, resolving road incidents, preventing fraud, invoicing and accounting, analytics, and research and development
• share your information among our affiliate companies and Superpedestrian to provide, maintain and improve the Services
• share aggregated rider data with universities or other researchers to pursue research projects or collaborate with studies regarding transportation
• to establish, exercise, or defend civil or criminal claims in connection with actual or potential litigation including to protect our Services, our property or other legal rights, including those of our users
• to prevent harm or injury to you, the public, or our staff, or to defend our legal rights or property, or enforce our Terms and Conditions
• to comply with federal, state, regulatory, or local law requirements and to share certain Information including account, trip route, and location data with cities, local authorities and public transport operators where necessary to fulfil conditions of the permits, contracts or licenses granted to us
• to respond to valid requests from law enforcement investigating incidents, crashes, crimes, fraud, or other illegal activities

To Contact You Regarding Marketing or Promotions. We may process your Information for the purpose of sending promotional or marketing communications, such as emails, encouraging you to use our Services, which may include promotional codes, or other offers such as free rides or unlocks to promote or market the use our Services. Where required to do so, we will only contact you regarding marketing and promotions with your consent. Where we ask for your consent, the legal basis for this contact will be your consent to receive marketing and promotional communications. You have the right to withdraw your consent at any time. Where we are not required to ask for consent to send marketing communications, the legal basis for processing your Information is our legitimate interest in promoting our Services.

+ How We Share Your Information

We share certain of your Information with our affiliated companies, our service providers, and other third parties where it is necessary to perform the Services pursuant to our Terms and Conditions, as described in this Privacy Policy. In particular, we may share your Information with:

Our service providers and partners. We share certain Information with our service providers, partners, and their employees as necessary to provide the services, including account, trip route, and location data. Examples of such services where it is necessary to share Information include providers of:

• cloud and data hosting
• ID verification
• payment processing
• customer support management/software
• software applications and service providers who assist us with financial, accounting, payroll, benefits, insurance, fleet management/optimization, marketing tools, data analysis, and legal matters
• insurance, including insurers, third party claims administrators, brokers and their vendors, as needed for the purpose of obtaining insurance for our Services and processing insurance claims
• partners or service providers in preparation for or in conjunction with a sale, merger, change in control, or financing event for our Company

Government, regulatory and law enforcement agencies. We may share your Information when it is reasonably necessary to do so, including:

• to meet federal, state, regulatory or local law requirements
• in response to valid requests from law enforcement in connection with an investigation of an incident, or as part of a judicial process, or to take action regarding illegal activities or traffic offenses
• in connection with our efforts to detect and prevent fraud and other illegal activity, to improve security, or to address technical issues or abuse
• to prevent harm or injury to you, the public, or our staff, or to defend our legal rights or property or enforce our Terms and Conditions

Cities and localities. When required by municipal governments or transportation authorities, we share with cities, transportation authorities and their required vendors certain Information, including account, trip route and location data, in order to fulfill conditions of our license or permit to operate in that location. We may also disclose your Information, including account, payment history and trip location data, where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, potential threats to safety, violation of our Terms and Conditions, or as evidence in any litigation or judicial proceeding.

Research and business partners. We may share individual trip records and trip location history with other parties for research, business or other purposes, including partnerships with universities for research projects such as understanding micromobility usage and travel patterns in a city. We may also share certain data sets containing aggregated and de-identified information that cannot reasonably be used to identify you.

Superpedestrian companies. We disclose your Information to our affiliate and parent companies. When we operate in countries outside the United States, we form local subsidiaries to provide our scooter rental services and share data back to the Superpedestrian parent companies to provide, maintain, and improve the Services. Your personal information may thus be transferred to (or stored in) a jurisdiction other than your jurisdiction of residence, and will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such jurisdictions.

Business transfers. If we merge with or are acquired by another company, or if substantially all of our assets are transferred to another company, or as part of another change of control event, financing, or bankruptcy proceeding, we may transfer the Information to another company.

+ Cookies And Similar Technologies

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Sites or Services. We may combine this information with other personal data we collect from you. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites and Services, while others are used to enable a faster log-in process or to allow us to track your activities on our Sites and Services.

There are two types of cookies: session and persistent cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We may use session cookies to allow our systems to uniquely identify you during a session. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies to track aggregate and statistical information about user activity. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We and our service providers may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Sites to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our service providers may also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Analytics. We use cookies through Google Analytics and/or Squarespace Analytics to collect information from your browser, computer, or mobile device when you access or use our Sites. We also may use other analytic means to evaluate our Sites and Services. You can learn more about how Google Analytics uses this data here and Squarespace Analytics here. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout. These analytics programs use cookies and similar tracking technologies to help us understand how people use our Sites, remember when you return to a site, and how you navigate and engage with content on our Site. On our scooter rental App, we use app logging provided by a third-party service to log when you launch the app, navigate through various links, pages or features on the App, and encounter any error messages in using the App. You can learn more about how we use cookies and similar technologies in our Cookie Policy.

+ Additional Rights In Certain Jurisdictions

European Economic Area, Switzerland and United Kingdom Privacy Rights

In certain circumstances set forth below, you may have certain rights with respect to your Information if and to the extent you use our Services in countries located in the European Economic Area and/or Switzerland and/or the United Kingdom. These rights may include the following:

Objection to direct marketing. You have the right to object at any time to the processing of your Information for direct marketing purposes.

Withdrawal of consent. Where you have previously provided your consent, such as to send you direct marketing, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal.

Access and portability. You can access much of your Information by logging into your account. You can also request a copy of the Information we have about you and an explanation for how the Information is used. You may have the right to receive your Information in a machine-readable format for data portability.

Digital Legacy. In certain jurisdictions, you have the right to provide us with specific guidance on the handling of your Information after your death.

Corrections. You have the right to request that we correct any inaccurate Information we have about you.

Deletion. In specific circumstances, you have the right to request that we delete your Information, subject to applicable law. You may also ask that we temporarily restrict the processing of your Information.

Objection to processing. Where we process your Information based on our legitimate interests, you have the right to object to this processing. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.

Please email us at legal@superpedestrian.com if you would like to exercise any of these rights or in case you should have any concerns about how we process your information. You may also contact our data protection officer at dpo@superpedestrian.com.

You also have the right to lodge a complaint with your local supervisory authority for data protection. You can access a list of European supervisory authorities here.

Transfers of Information We transmit all of your Information to the United States for processing as described in this Privacy Policy for the purpose of: (i) performing the Terms and Conditions, to which you are a party, or taking steps to enter into the Terms and Conditions with you; and (ii) for other purposes described above, such as for internal reporting, administration, and organizational reasons. The Company guarantees that in case of transfer of Information, for the purposes above, to a country or territory outside of Europe, it will take the necessary measures to protect the personal data, in compliance with the guarantees provided by the GDPR, including, among others, after having executed the standard contractual clauses (“SCCs”) approved by the European Commission and/or Switzerland and/or the United Kingdom for making this type of data transfer safer. Countries which are not located in Europe may not offer the same level of data protection as in your home country, for example there is currently no adequacy decision in respect of the United States. You may request a copy of the SCCs by contacting us at legal@superpedestrian.com. In addition, where the transfer of information is necessary to provide our Services as set out in the Terms and Conditions, we may use derogations, such as the contractual necessity derogation, where appropriate to process your Information. We transfer personal data to the following countries: the EU and the USA.

Superpedestrian is currently in a process of self-certification under the EU-U.S. Data Privacy Framework program (DPF), UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF respectively. This program was developed by the U.S. Department of Commerce and the European Commission, UK Government, and Swiss Federal Administration to provide U.S. organizations with reliable mechanisms for personal data transfers to the United States from the European Union, United Kingdom, and Switzerland while ensuring data protection that is consistent with EU, UK, and Swiss law. As soon as the self-certification process of Superpedestrian has been completed the DPF will replace the SCCs as the appropriate data protection safeguard to be used as a ground for data transfers from the EU, UK or Switzerland to third countries.

California Privacy Rights If you are a California resident, you are entitled to certain rights with respect to your personal information. For more information about those rights and how to exercise them, please see our “California Privacy Notice” set forth below and incorporated by reference into this policy.

+ Links to Other Sites

Our Sites and Services may contain links to other entities’ websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.

+ Data Security

We have implemented commercially reasonable precautions to protect the Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite these measures, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your account, your phone and your computer by, among other things, signing off after using a shared computer, locking your phone and keeping your account information private.

+ Accessing and Managing Your Information

If you have an account with us, you can review, change, or delete your information by logging into the App and editing your profile. You can change your mobile phone number or email address by using our in-App change feature. You can delete your account at any time by submitting a request to us at support@superpedestrian.com. If you wish to access or correct your personal information held by us you may also contact our data protection officer at dpo@superpedestrian.com.

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, and information that you have updated, modified or deleted may remain viewable in cached and archived pages for a period of time. We may also retain certain Information from deleted accounts to prevent fraud, collect fees, enforce our Terms and Conditions to comply with our legal obligations or enforce our legal rights.

+ Children’s Privacy

Our Services are not designed for children under the age of 18. We do not knowingly collect, maintain, or use personal information (as defined by the United States Children’s Online Privacy Protection Act) from such persons. If you believe that we might have any such information from a child, please contact us as described at the end of this Privacy Policy. If we discover that personally identifiable information of a child has been submitted without legally valid parental consent, we will take reasonable steps to delete it as soon as possible.

+ Contact Information

If you would like to change the types of communications you receive from us, including opting out of promotional communications from us, you may do so at any time by updating the communication preferences specified in your account profile. We may continue to send non-promotional communications and other information about your use of our Services. You may also contact us at legal@superpedestrian.com. You may also contact our data protection officer at dpo@superpedestrian.com.

If and to the extent you use our Services in the following countries, the data controller responsible for your information is as specified below and can be contacted through legal@superpedestrian.com:

Italy – Link Your City Italia S.r.l., Corso Re Umberto 7 CAP / 10121 Torino / Italy

Spain – Superpedestrian Spain S.L., C Balmes, Num. 76 / Planta Pra Puerta 1ª / 08007 Barcelona / Spain

Austria – Superpedestrian Europe BV - Niederlassung Österreich, Opernring 1/ R 745-748 / 1010 Vienna / Austria

Portugal – Superpedestrian Portugal Unipessoal, Lda, Rua Tomás Ribeiro nº 6 / 1º Esq / 1050-229 Lisbon / Portugal

Sweden – Superpedestrian Sverige AB, Sveavägen 9, 10th floor / 111 57 Stockholm / Sweden

Switzerland – Superpedestrian Schweiz GmbH / Klausstrasse 33, CH-8008 / Zurich / Switzerland

Canada – Superpedestrian Canada, Inc., 666 Burrard St #2500 / Vancouver / BC V6C 2X8 / Canada

France – Superpedestrian France SaS, 23 Rue d'Anjou / 75008 Paris / France

United Kingdom – Link Your City UK Ltd., 27 Greville Street / London EC1N 8TN / UK

If you use our Services in the United States or other country not listed above, your data controller is Superpedestrian, Inc., 84 Hamilton Street, Cambridge, MA 02139. If you have any questions about our privacy practices or your information, please contact us at legal@superpedestrian.com.

+ California Privacy Notice

Last updated: June 15, 2021

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

We do not sell your personal information to third parties. We do share information with certain analytics partners who perform services to help us analyze our Services. You can choose to limit the information shared with our analytics partners following the steps described in the Cookies and Similar Technologies section of this Privacy Policy.

The chart below sets forth the categories of personal information under the CCPA that we collect and the ways we may use such information for our business purposes, as described in detail in our Privacy Policy. We may use all the categories of personal information in the chart below for the purposes set forth in our Privacy Policy under How We Use Your Information. We use your Information to provide our Services to you, to comply with laws, city ordinances or permits, and valid local law enforcement requests, to improve and optimize our scooter rental Services, or for other purposes with your consent. We may share all the categories of personal information in the chart below with our service providers, affiliates, government entities, research partners, and in connection with a business transfer, as set forth in our Privacy Policy under How We Share Your Information. We may collect your personal information from the following sources, as set forth in our Privacy Policy under Information We Collect: directly from the individual, data analytics providers, service providers, social networks, internet service providers, operating systems and platforms, government entities.

Personal Information Collected

Category

Identifiers - such as name, email, mobile number, government ID

Use

• Provide the Services to you, including scooter rentals, billing, ride history
• Manage your account
• Improve the Services;
• Communicate with you

Category

Customer Records - such as name, contact information, government identifiers, account number, and financial or payment information,

Use

• Provide the Services to you, including scooter rentals, billing, ride history
• Manage your account
• Improve the Services
• Communicate with you

Category

Commercial Information - such as transaction data concerning scooter rentals

Use

• Provide the Services to you, including scooter rentals, billing, ride history
• Manage your account
• Improve the Services
• Communicate with you

Category

Usage Data – such as your use of our Services

Use

• Provide the Services to you
• Manage your account and billing
• Improve the Services
• Communicate with you

Category

Geolocation Data – such as precise location information about your device and the scooters you rent

Use

• Provide the Services to you, including scooter rentals, billing, ride history
• Track assets to prevent fraud and abuse
• Comply with city ordinance, permit or contract requirements
• Improve our operations, reliability and functionality

Category

Audio, Video and Electronic Data – such as a photograph you submit or send to us and interactions with customer service

Use

• Provide the Services to you
• Improve our customer service
• Ensure compliance with city ordinances, permit or contractual requirements
• Communicate with you

Category

Professional information – such as business contact or education information if provided

Use

• Communicate with you

California Residents’ Rights

In general, California residents have the following rights with respect to their personal information:

Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell your personal information. We do share your information with certain analytics partners who perform services to help us analyze our Services, which may be viewed as a sale under applicable laws. You can choose to limit the information shared with our analytics partners following the steps described in the Cookies and Similar Technologies section of this Privacy Policy.

Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.

Right to know: with respect to the personal information we have collected in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions): • categories of personal information collected; • categories of sources of personal information; • categories of personal information about them we have disclosed for a business purpose or sold; • categories of third parties to whom we have sold or disclosed for a business purpose their personal information; • the business or commercial purposes for collecting or selling personal information; and • a copy of the specific pieces of personal information we have collected about them.

Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests. California residents may submit CCPA requests to know (access) and requests to delete their personal information by emailing us at legal@superpedestrian.com or via the toll free number provided in the Help section of our App.

For more information about our privacy practices, you may contact us as set forth in the “Contact Information” section above.