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Privacy Notice

At SCOOBY and our family of companies (collectively ” SCOOBY ,” ” we ,” ” us ,” or ” our“), we are strongly committed to transparency, and we want you (” you” or ” your“) to understand how we collect, use, share and protect your information This Privacy Notice (” Privacy Notice“) describes how SCOOBY handles information in connection with SCOOBY’s websites (including its e-commerce shop), SCOOBY-branded user-owned vehicles, SCOOBY-owned vehicles and related mobile applications and services (collectively, the ” Services“), and when you otherwise interact with us When specified, this policy also describes our data practices related to OOBYs  which sets out the terms governing the Services

We reserve the right to change this Privacy Notice from time to time If SCOOBY makes changes to this Privacy Notice, the updated Privacy Notice will be made available through our Services and if we make any material changes to this Privacy Notice, we will provide a prominent notice and may also contact you directly by email or another method

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)
  • We collect and process location data when you sign up and use the Services For example, to accurately show you SCOOBY 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 SCOOBY also collects location data directly from SCOOBY vehicles including when a SCOOBY user is riding, such as journey information
  • When you use certain products (eg 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 SCOOBY with a third-party service (eg 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
  • SCOOBY 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
  • 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, SCOOBY will receive information you choose to send us such as photos of parked SCOOBY vehicles
  • We receive information about you when we use third-party partners such as marketing and advertising partners, such as social media networks

In addition, if you are a OOBY who helps SCOOBY collect and charge vehicles, we collect additional information:

  • submitted as part of your application to work as a OOBY such as government issued identification;
  • details of the work you carry out for SCOOBY such as information about the vehicles you charge for SCOOBY;
  • your bank account details so we can pay you; and
  • that which is required by law such as social security number, tax number or work visa

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 w you access the Services via Integrated Partner services, such as Uber Uber and SCOOBY are joint controllers for this processing; for more information on the division of responsibility between SCOOBY and Uber, you can contact SCOOBY
  • confirm your government-issued driver’s license (if provided) is valid, not currently linked to any other SCOOBY 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 ;
  • monitor, track and service the SCOOBY vehicles, including when they are in use by you W 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, w 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 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 SCOOBY and/or third parties, including information about features and enhancements to our Services;
  • personalize advertisements to you (for more information, see the “Advertising and Analytics” section below);
  • ptimize, develop and improve our Services, including for creation and training of machine learning models to optimize, develop and improve our Services (eg to improve the accuracy of our helmet detection software) To do this we may use third party analytics providers to understand how the Service is being used and to help us to improve the Services;
  • w necessary, to comply with our legal obligations including to meet regulatory or local law requirements;
  • detect, investigate, and prevent activities that may violate SCOOBY’s policies OR 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

In addition, if you are a OOBY, we use your information to: calculate your pay and to pay you; and to monitor the work which you do for SCOOBY and to track SCOOBY vehicles

Who Do We Share Your Information With?

We share your information with SCOOBY’s affiliated companies, our service providers, other third parties w it is necessary to perform the and as described in this Privacy Notice In particular, we share your information with:

  • Our service providers and partners : We share your information with our trusted service providers, partners, and their personnel who provide services to SCOOBY such as hosting data and our infrastructure, providing ID verification services, processing payments and donations, supporting and improving the Services, performing customer service, or providing marketing and advertising services 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 (w provided), and combining the resulting information with similar information from other users, SCOOBY 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 For example, SCOOBY partners with universities to collaborate on research projects such as understanding traffic and travel patterns in a city Learn more about these collaborations 
  • 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,
  • Integrated Partners : We share your information with third party services which integrate or provide access to SCOOBY vehicles and/or the Services and/or to provide access to third party vehicles on the Services For example, SCOOBY has partnered with Uber so users can rent a SCOOBY scooter through the Uber app
  • Cities, local authorities and public transport operators : We share your information with these recipients w necessary to fulfill conditions of our license or w 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 For example, in the UK, SCOOBY partners with the Department for Transport (” DfT“) to assist the DfT to understand and build a picture of vehicle demand and to assess the safety of vehicles in the UK The data shared for these purposes includes:
    • Account information, such as SCOOBY user identifier, name, email address, telephone number, government-issued driver’s license, date of birth, and gender;
    • 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 SCOOBY 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

Learn more about how sharing ridership data helps communities 

  • SCOOBY affiliates : We may share your information with SCOOBY affiliate companies to help provide, maintain and improve the Services As we grow, we may expand our corporate family by establishing local subsidiaries or other affiliates as needed, to help us provide or market the Services
  • Business re-organization : We may also share your information as part of a sale, merger, change in control, or in preparation for any of these events

We may also share aggregated, depersonalized, or de-identified information that cannot reasonably be used to identify you with third parties, including the types of third parties listed above

Advertising and Analytics

We allow others to provide analytics services and serve advertisements on our Services and on our behalf across the web and in mobile apps These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information This information may be used by SCOOBY and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, measure the effectiveness of our advertising, and better understand your online activity You can manage your preferences, find more information about interest-based ads, or opt out of having your web browsing information used for behavioral advertising

W SCOOBY uses the Facebook pixel (a type of cookie), to provide advertising to you, SCOOBY and Facebook Ireland are joint controllers for this processing SCOOBY and Facebook Ireland have divided their responsibilities under GDPR in respect of this joint processing, for example, SCOOBY is responsible for providing this notice to you and Facebook Ireland is responsible for managing your individual rights relating to the joint processing For information on how to exercise your rights with Facebook Ireland in relation to the joint processing, and for information on how Facebook Ireland subsequently processes your personal information as independent data controller, please see the Facebook Data Policy

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

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 SCOOBY relies on a number of legal bases to collect, use, share, and otherwise process your information for the purposes described in this Privacy Notice, including w:

  • it is necessary to provide the Services and perform our obligations in accordance with the, 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, OOBYs, 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 SCOOBY’s or a third party’s, 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 

How We Transfer Your Information

As we offer our Services in many locations globally, we may transfer your information to or from these locations for the purposes of providing you Services

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 Examples of some of our retention periods are set out below

Type of Data

Retention Period

Account information

Lifetime of the account Certain information relating to transactions relating to an account are retained for 7 years in line with SCOOBY’s accounting obligations

Government issued driver’s license information and result of verification of whether selfie matches ID

After we conduct verification checks to ensure the license is valid, we retain only limited verification information for fraud prevention purposes and in order for you to use the Services When we use facial recognition technology to verify that your driver’s license matches your image, we retain only information about whether the image matched We retain this information for the lifetime of the account unless a different period is required by law in your jurisdiction

 

Customer support queries

Lifetime of the account

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 , to comply with our legal obligations or enforce our legal rights

In addition, if you are a OOBY, SCOOBY retains certain information to the extent necessary to comply with our legal obligations For example, SCOOBY may keep some of your information in order to comply with applicable tax, legal, reporting and auditing obligations and other requirements in the countries in which we operate

Your 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

Right to object (marketing) – You have the right to object to processing for direct marketing purposes at any time

Right to object (legitimate interest) – W we process your information, you can object to this processing in certain circumstances Unless we have compelling legitimate grounds or w it is needed for legal reasons, we will cease processing your information when you object

Right of access – 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 information explaining how the information is used

Right of rectification – You have the right to request that we rectify inaccurate information about you

Right of erasure – You have the right, in certain cases, to request that we delete your information, provided t are valid grounds for doing so and subject to applicable law

Right to restrict processing – You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided t are valid grounds for doing so

Right to data portability – You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to another controller

Right to withdraw consent – W 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 Furthermore, even in case of a withdrawal, we may continue to use your information as permitted or required by law

Right to provide guidance on the management of your data after your death – You have the right to provide us with specific guidance on the storage, deletion of communication of your personal data after your death

Please get in touch with us as set out in the “Who Is Responsible for My Information?” section below if you would like to exercise any of these rights or in case you should have any concerns about how we process your information For security purposes, we may require that you follow certain steps in order to verify that you are the owner of a SCOOBY account For example, we may require that you have a verified email associated with your SCOOBY account and that you get in touch with us using the verified email associated with your SCOOBY account You also have the right to lodge a complaint with your local supervisory authority for data protection You can access a list of EU supervisory authorities  You can also contact SCOOBY’s Data Protection Officer at 

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 SCOOBY to collect your information, please do not use the Services

Emails and Other Communications : 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 the Service

Accessing and Managing Your Information : If you have an account with SCOOBY, you can review, change or delete your information by logging into your account 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 SCOOBY account at any time by submitting a request to us

Who Is Responsible for My Information?

To see who is responsible for your personal information and how to contact them