Scope of This Policy
This Privacy Policy applies to all personal information collected through:
- Our mobile scooter-sharing application
- Our website
- Our scooters and IoT hardware
- Customer support interactions
- Marketing and promotional activities
It does not apply to third-party websites or services that we do not control.
Information We Collect
- Account Information — name, email, phone number, password
- Payment Information — processed through PCI-compliant partners; we do not store full card numbers
- Identity Verification Data — driver's license, age verification, or government ID if required
- Customer Support Communications — messages, call logs, attachments
- Location Data — real-time GPS during rides, trip routes, start/stop points
- Scooter Telemetry — battery level, speed, diagnostics
- Device Information — IP address, device type, OS version, app activity
- Cookies & Analytics — usage patterns, crash logs, performance metrics
- Payment processors
- Identity verification services
- Marketing partners
- Law enforcement (when legally required)
How We Use Your Information
We use personal information to:
- Provide, maintain, and improve the Services
- Authenticate users and prevent fraud
- Process payments and billing
- Operate and optimize scooter fleet distribution
- Provide customer support
- Send service-related notifications
- Conduct analytics and product development
- Comply with legal obligations
Legal Basis for Processing
Although Michigan does not have a comprehensive privacy statute, we follow widely recognized principles:
- Consent — for location tracking, marketing, and optional features
- Contractual necessity — to provide scooter rides
- Legitimate interests — fraud prevention, safety, analytics
- Legal compliance — responding to lawful requests
How We Share Information
We may share information with:
- Service Providers — cloud hosting, analytics, payment processors
- Operational Partners — maintenance teams, fleet operators
- Law Enforcement — when required by law or to protect safety
- Business Transfers — mergers, acquisitions, or asset sales
Data Retention
We retain personal information only as long as necessary for the purposes described in this Policy. Typical retention periods:
User Rights
Even without a Michigan privacy statute, we voluntarily provide the following rights:
Requests can be submitted through the contact form in Section 14 of this policy or through the in-app privacy request portal.
Cookies & Tracking Technologies
We use cookies and similar technologies to:
- Maintain session functionality
- Analyze usage patterns
- Improve app performance
- Support marketing campaigns
Users may adjust cookie settings through their browser or device.
Analytics providers we use. With your consent, we load the following third-party analytics tools. These do not run until you select “Accept” on our cookie banner, and you may decline at any time:
- Google Analytics 4 (Google LLC) — measures aggregate traffic, pages viewed, approximate location, device and browser type, and referral sources. IP addresses are anonymized by Google. See Google’s Privacy Policy and opt out with the Google Analytics Opt-out Browser Add-on.
- Microsoft Clarity (Microsoft Corporation) — captures anonymized usage analytics, heatmaps, and session replays of interactions (clicks, scrolls, navigation) to help us improve the site. Keystrokes in form fields are masked by default. See Microsoft’s Privacy Statement.
Your consent and how to change it. We ask for your consent before loading any analytics, consistent with the EU/UK GDPR and the California Consumer Privacy Act (CCPA/CPRA). Your choice is stored locally in your browser. To change it, clear your browser’s site data for this site (or your saved “consent” preference) and reload the page to bring back the banner. Declining analytics does not affect your ability to use the site.
Data Security
We implement administrative, technical, and physical safeguards including:
We follow NIST and ISO/IEC 27001 best practices.
Children's Privacy
Our Services are not intended for individuals under 16. We do not knowingly collect data from children. If we discover such data, we delete it promptly.
Michigan Data Breach Notification
If a breach involving personal information occurs, we will:
- Investigate promptly
- Notify affected Michigan residents without unreasonable delay
- Notify the Michigan Attorney General when required
- Provide remediation guidance
International Data Transfers
Although we operate in the United States, some service providers may process data in other jurisdictions. We require contractual safeguards to protect transferred data.
Changes to This Privacy Policy
We may update this Policy periodically. When changes occur, we will:
- Update the "Effective Date"
- Notify users through the app or website
- Provide a summary of material changes
Contact Information
For privacy-related questions, requests, or concerns, please use the form below. We will respond within 2 business days.
The following sections apply to residents of California and Colorado. If you reside in one of these states, you have additional rights under state law.
California Residents — CCPA / CPRA
If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights apply to personal information we collect in our role as a "business" under California law.
You may request:
- The categories of personal information we have collected
- The categories of sources from which information was collected
- The business or commercial purpose for collecting or sharing information
- The categories of third parties with whom we share information
- The specific pieces of personal information we have collected about you
You may request that we delete personal information we have collected, subject to legal exceptions (e.g., fraud prevention, security, required transactions).
You may request that we correct inaccurate personal information.
We do not sell personal information. However, California defines "sharing" broadly to include certain cross-context behavioral advertising. You may opt out of such sharing at any time.
If we collect sensitive personal information (e.g., precise geolocation), you may request that we limit its use to what is necessary to provide the Services.
We will not discriminate against you for exercising your CCPA rights. We will not deny services, charge different prices, or provide a different quality of service based on your exercise of these rights.
Colorado Residents — CPA
If you are a resident of Colorado, you have rights under the Colorado Privacy Act (CPA), including the right to:
- Access personal data we have collected about you
- Correct inaccuracies in your personal data
- Delete personal data we have collected
- Obtain a copy of your personal data in a portable format
Colorado residents may opt out of:
- Targeted advertising
- Sale of personal data (we do not sell data)
- Profiling that produces legal or similarly significant effects
If we deny your request, you may appeal our decision. Instructions for submitting an appeal will be included in our response.
How to Submit a Privacy Request
California and Colorado residents may submit requests through:
- The in-app privacy request portal
- Use the contact form in Section 14 above
We will verify your identity before processing your request and will respond within the timelines required by applicable law.
Additional Disclosures
- We do not sell personal information.
- We do not process personal information for automated decision-making that produces legal or similarly significant effects.
- We only use precise geolocation for ride operation, safety, and fraud prevention.
- We maintain strict Data Minimization Practices and Purpose-Limitation Rules.