Welcome to the web site (the “Site”) or mobile application of Sparrow Scooters Inc. (“we,” “us,” “Sparrow,” or “our”). This privacy policy(“Policy”) describes how Sparrow collects, uses and shares information about you when you access or use our Site, mobile application (“App”), or Sparrow Vehicles (“Vehicle”); or when you communicate with us in any available ways, participate in our surveys, attend our events or interact with us on social media. In the Policy, we define “Services” as

• Sparrow websites that link to this Privacy Policy

• Sparrow mobile applications, and

• Sparrow vehicles

By accessing or using our Services, you agree to this Privacy Policy. PLEASE ONLY ACCESS OR USE OUR SERVICES WHEN YOU AGREE TO THIS PRIVACY POLICY

1. WHAT WE COLLECT

We collect information automatically from our users when they access or use our Services, as well as from third parties. If you do not agree to share the information with us, we may no longer be able to provide your certain services.

Information You Provide to Sparrow:

• Account registration, administration, and modification of your account.

• Access to and use of the Services.

• Vehicle use

• Contents uploaded to the Services

• Information submitted to surveys and polls.

• Transaction history

• Customer service and technical assistance

• Any other information collected during our Services

Information We Collect Automatically:

When you access and use the Services, we and our third-parties service providers collect information automatically.

• Device/Online Usage information: We and our third-party services providers collect information about your computer, mobile devices, browser and any other devices that you use to access the Services using various technologies, including cookies, log files and other similar tools. We may collect information including types or devices, browser languages, referring and exit pages, frequency of visiting, IP address and unique device identities.

• Location and Vehicle Information: When you access, or use the Services, we and our third-party services providers collect your location information via GPS or Bluetooth of the vehicle, with your permission. We may also automatically collect your location information (Zip Code, States) from your computer or mobile devices. You can change the location setting of the App on your mobile devices.

• Analytics: We analyze information collected from the Services to improve our marketing campaigns, and operation. The analysis may include user preferences, aggregated usage pattern, frequent route and other information.

2. HOW WE USE THE INFORMATION COLLECTED

We use the information collected for various purposes:

Information You Provide to Sparrow:

• Provide you the Services

• Monitor, track and manager the Vehicles

• Process transactions

• Communicate with you for customer support and technical assistance

• Comply with our legal obligations including to meet regulatory or local law requirements;

• Understand how the Services are used to better improve our operation, marketing strategies and the Services.

3. WHO DO WE SHARE THE INFORMATION WITH

We share your information with:

Information You Provide to Sparrow:

• Affiliates: We may share your information with any affiliates of Sparrow in order to provide or improve the Services

• Our third-party services providers: In order to provide you the Services, we share your information with our third-party service providers for various services including, payment processing, customer services, and marketing analytics.

• Our third-party payment processor: Our software uses Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and read its privacy policy at https://stripe.com/en-ca/privacy

• Our third-party partners: We only provide aggregated information to our third-party partners for business, research or other purposes. Any personal information including your name, email address, and phone number will be removed

• Business Transfers: We may share your information when business reorganization occurs, which includes sale, and merger change in control.

• Legal Requirements and Protection of Rights: We may share your information if it is required by local laws, or it is necessary to do so for legal reasons. Security of the Information We protect your information with various methods in both physical and technical ways, from accidental or unlawful destruction, loss, access, disclosure or alteration. However, no method or information storage and information transmission is absolutely secure.

4. 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.

5. YOUR CHOICES

You can choose your information shared preference by contacting us directly. You can also change your permission for information provided on your mobile device. However, you may not be able to use certain features of the Services without providing certain information. You can choose to opt-out of any kind of marketing communication of Sparrow, including email newsletter, push notifications, etc.

6. CHANGES TO PRIVACY POLICY

We reserve the right to update and modify the Policy at any time. When we make a material change to the Policy, you will be presented the amended Policy in advance of providing any information. If you do not agree to the latest policy, you will no longer be able to use the Services.

7. ACCESS TO INFORMATION

You may have the right to access, request correction, deletion of your information, subject to our rights to retain certain information under the User Agreement or the law. Please feel free to contact us for any questions, clarifications or information regarding our Privacy Policy at hello@sparrowscooters.ca

8. CAMERA and PHOTOS

1. • • • Sparrow Scooters collects photographic data through the mobile application. This includes “end ride photos” that riders are required to take and submit upon completing their ride, as well as any photos sent during interactions with our customer support team. These photos are used to verify ride completion, ensure the safety and proper use of our vehicles, and assist in resolving customer support queries.

       • Use of the camera and images in the Mobile Application:

         • Camera: to use our services, we need to access certain functions of your device. Depending on the installed operating system, the user must explicitly grant the permission or can revoke it on a case-by-case basis. The data that we may access within the framework of authorizations will only be used for the purposes indicated in this Privacy Policy. Access to the camera feature is required to scan the vehicle's QR code to rent it. The camera may also be necessary to verify driving license and user identity.

         • Images: the user may, at their sole discretion, add a photo to their user profile. The data that we may access within the framework of authorizations will only be used for the purposes indicated in this Privacy Policy.

       • Photographic Information: At the end of each ride we ask you to take a photographic image of the vehicle’s parking place.  We retain this image to ensure that the vehicle has been parked in a safe and appropriate place.

       • Camera permissions app - In the app, we use the camera permission to be able to use your camera to scan the QR codes of Scooters and to take an end-ride photo. We store the end-ride photo on our servers to analyze parking behavior.