ScootRoute Privacy Policy

Last revised and effective as of: June 20, 2020

This Privacy Policy relates to information collected online and offline by The Magellan Company, LLC (“ScootRoute” “we” or “us” or “our”) through your use of the ScootRoute website at www.scootroute.com and any subdomains thereof (the “Site”) and the services, features, and information available on the Site and/or any mobile applications we may offer (together with the Site, along with associated and successor websites, applications, features, information, and services, or any part thereof, the “Service”). This Privacy Policy is incorporated into, and part of, and governed by the ScootRoute Terms of Use. As used herein, “you” and “your” mean a user of the Service. 

You should carefully read this Privacy Policy. By using the Service, you are signifying your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you may not use the Service.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within ScootRoute or among our affiliates within the United States or internationally.

This Privacy Policy serves to notify you of the following:

What information about me is collected?

Where and when is information collected (including through the use of cookies and action tags)?

Is information submitted to the Public Areas of the Service private?

Does ScootRoute collect information from children under 13 years of age?

What does ScootRoute do with the information it collects?

When does ScootRoute disclose information to third parties?

Does this Privacy Policy apply when I link to other websites, social networks, or services?

Is the information collected through the Service secure?

Could my information be transferred to other countries?

For how long will my personally identifiable information be kept?

What choices do I have regarding my personally identifiable information?

How will I know if there are any changes to this Privacy Policy?

Who do I contact if I have any privacy questions?

WHAT INFORMATION ABOUT ME IS COLLECTED?

We want you to understand the types of information we collect as you use our Service.

Information You Create or Provide To Us

  • Account Information: information required when setting up a username you have chosen, such as your name, and password. Bear in mind that false, incorrect, or out-dated information may impair ScootRoute’s ability to provide you with the Services and to contact you when necessary. ScootRoute will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to set up a username or to be provided with certain features.
  • Information that you choose to share with ScootRoute: information that you choose to share with ScootRoute, including your name, email, a username you have chosen, password, reports associated with your username, phone number(s), rider type, scooter type and other scooter details and any other information you choose to include in an open text-box field within the Service. Even if you aren’t signed in to a ScootRoute account, you might choose to provide us with information – like an email address to receive updates about our services.
  • Communication which you choose to conduct through the ScootRoute Service: We may also collect information when you exchange communication with ScootRoute, for example, if you submit a request, contact ScootRoute’s support team, or report a violation to the abuse team.
  • Information from your social networks which you choose to connect to your ScootRoute Account: you may choose to connect your ScootRoute Account to your social network account(s). If you choose to do so, you may choose to share with ScootRoute and/or other users information from your social network accounts, such as your Facebook profile photo or other personal information shared by you.

Information We Collect As You Use Our Service

We collect information about your activity in the Service, including features which are meant to personalize your experience. This includes things like finding you the preferred route and proposing favorites or destinations commonly traveled by you to streamline your search and travel. The activity information we collect may include:

  • Detailed location, travel and route information. Location and route information is collected for example in the form of GPS signals (combined with a time-stamp) and other information sent by your mobile device on which the Application is installed and activated. This location and route information is saved to a route history of all of the journeys you have made while using the mobile application. The types of location data we collect depends in part on your device and account settings. For example, depending on your selected device settings and/or your account settings we may collect information about your location and travel (or lack thereof) also while you are not using the mobile application, in order to be able to tell you when to leave for planned trips, notify you about bad traffic in your area, provide you parking assistance, analyze how effective our ads are and more;
  • Terms or venues you searched;
  • Your views and interactions with content and ads;
  • Your voice and audio information when you use voice and audio features;
  • Communication or other content you chose to share with any third party, including ScootRoute users through the Service;
  • Your activity on third-party sites and apps that you chose to link to your ScootRoute account or that you interact with through the Service.

Meta-Data (Information About Your Device, Browser and App Use)

Once you install the mobile application, ScootRoute collects information about the use of the Service and information from the device you have ScootRoute installed on. For example:

  • ScootRoute may collect and record how often you use the mobile application and for how long, your device type, unique identifiers, operating system type & version, battery usage, the third party web pages or applications you visit or use or interact with via the mobile application, information that you viewed on our Service, advertisements that are shown to you or that you view or click on, the fact that you used the Service to communicate with other users and the fact that you used third parties application/services via ScootRoute to communicate with third parties, and the duration of such communications, the Internet Protocol (IP) address and the name of the domain that serves you to access the Service, and the geographic location of the device that you are using to log in and use ScootRoute on.
  • We also collect information about the interaction of your devices with our Service, including, crash reports, system activity, and the date, time, and referrer URL of your usage or request, pages viewed, browser type, browser language, and other statistical data involving use of the Service.

Information We Collect About You From Our Partners

We work with ad partners, including advertisers on our platform in order to show you more relevant and useful ads based on your ScootRoute activity and information associated with your device’s identifier (i.e, advertising identifiers or similar technologies) shared with us by our ad partners.

We may also receive aggregated, non-personally identifiable information and analysis from third parties measurement services which help us understand how our users interact with our ads. We may also receive information from third party services about how ScootRoute’s own marketing efforts performed on third party sites or platforms.

We use various technologies to collect and store information, including, cookies, advertising ID available on android mobile devices or similar technologies, local storage, browser web storage, application data caches, databases, and server logs.

Geolocation Information

For the avoidance of doubt, we will collect and track precise geolocation information (i.e., information about your precise location) from the mobile devices on which you have installed the our application. 

WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We will collect personally identifiable information that you submit to us. 

Registering to Use the Service and in the Course of Using the Service.

You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you will be required to provide us with information (including personally identifiable information and non-personally identifiable information) such as name and email address. In addition, we may obtain your personally identifiable information from you if you elect to create an account with a username and password, if you provide information through the “contact us/feedback” loop within our mobile application, or if you identify yourself to us by sending us an e-mail with questions or comments. Also, we will have access to any personally identifiable information that you choose to share through the Service. 

If you choose to access the Service using the Facebook Login or Instagram Login feature (to the extent available), you may be providing us with access to all information, attributes, and data in your Facebook or Instagram public profile.  We may freely store and use such information in accordance with this Privacy Policy and the Terms of Use.  Such information may be stored by ScootRoute and may be used in connection with providing the Service or to contact you.  See also “DOES THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES, SOCIAL NETWORKS, OR SERVICES” below.

Cookies and Action Tags.

We may collect information passively using “cookies” and “action tags.”

“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your account information each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings, and to target certain advertisements to your browser which may be of interest to you or to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to display or serve advertisements or to collect non-personally identifiable information in order to provide advertising-related services. In the course of serving advertisements, such third-party advertisers could place or recognize unique cookies on your browser.

You do not have to accept cookies to use the Service. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.  

For the avoidance of doubt, the Service uses third-party service platforms (including to help analyze how users use the Service).  These third-party service platforms may place cookies on your computer or mobile device.  If you would like to disable “third party” cookies, you may be able to turn them off by going to the third party’s website.

Here is a link to the main third-party platform we use:

https://www.google.com/policies/privacy/

“Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including advertisements, or e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we are able to gain valuable information to improve the Service and measure the effectiveness of our advertising and marketing campaigns. Information collected from cookies (including cookies placed by third-party vendors, such as Google and its partners) may be used to deliver advertisements to you when you are visiting other websites, such as Facebook, Instagram, LinkedIn, and YouTube. You may opt out of a third-party vendor’s use of cookies for personalized advertising by visiting www.aboutads.info. Finally, you should be aware that advertisers and other third parties may use their own cookies or action tags when you click on their advertisement or a link to their websites or services on or from the Service. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services or providers of third-party advertising.

Log Files.

We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

Public Areas.

The Service may feature various community areas and other public forums (the “Public Areas”) where Service users submit information that may be viewed by other users of the Service. These Public Areas are open to the public and should not be considered private. We cannot prevent information included within a Public Area from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings. 

Any information you share in a Public Area (including personally identifiable information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot regulate or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personally identifiable information in a Public Area you can send us an e-mail to request that we remove it by contacting us at dmca@lutzker.com. You should understand that in some cases, we may not be able to remove your information.

IS INFORMATION SUBMITTED TO THE PUBLIC AREAS OF THE SERVICE PRIVATE?

No.  Any information shared in the Public Areas of the Service is available to the public, including to all users.  Such information is not protected or treated as confidential, can be used in any manner, and is not subject to this Privacy Policy.  If you wish to keep any information private or proprietary, do not submit it to the Public Areas of the Service.  NOTWITHSTANDING THE FOREGOING, WE HAVE NO RESPONSIBILITY OR LIABILITY IF A USER’S INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF A USER SUFFERS HARM AS A RESULT OF VOLUNTARY DISCLOSURES. 

DOES SCOOTROUTE COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. The Service is not designed for or directed to children under the age of 13. We do not collect personally identifiable information from any person we actually know is under the age of 13. In fact, as currently operated persons under the age of 18 may not use the Service.  By providing information to ScootRoute, you represent that you are 18 years of age or older.

WHAT DOES SCOOTROUTE DO WITH THE INFORMATION IT COLLECTS?

We use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, to facilitate the delivery of advertising, and, unless you opt out, so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you.

We may use your information to send you a welcoming e-mail that may confirm your user name and password. Unless you opt out, we and third parties acting on our behalf may subsequently send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: dmca@lutzker.com.

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. 

We may also use the information collected to send announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Service.

WHEN DOES SCOOTROUTE DISCLOSE INFORMATION TO THIRD PARTIES?

 We generally disclose information we gather from you through the Service to the following types of third parties and as otherwise set forth in this Privacy Policy or our Terms of Use or as specifically authorized by you.

Laws and Legal Rights.

We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the ScootRoute Terms of Use or another contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Service or the general public.

Third Parties Generally.

We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. In addition to the above, when users use our Service, third parties (including without limitation third-party advertisers, analytics service providers and commercial partners) may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites.  The third parties to which we may provide or who may independently directly collect personally identifiable and non-personally identifiable information may include potential or actual advertisers, providers of advertising products or services (including vendors, analytics services providers, and website tracking services), affiliates and other actual or potential commercial partners, and other similar parties.  Please note in particular that the Service uses Google Analytics, including its data reporting, advertising, and demographics and interest reporting features.  Information collected by Google Analytics includes but is not limited to web metrics.  For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Service, such as hosting and maintaining the Service, providing credit card processing and fraud screening, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your personally identifiable information.  We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your personally identifiable information.

Sale of Business.

We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of ScootRoute or any of its Corporate Affiliates (as defined below), or that portion of ScootRoute or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in ScootRoute, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

Affiliates.

We may disclose information (including personally identifiable information) about you to our Corporate Affiliates. For purposes of this Privacy Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with ScootRoute, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

DOES THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES, SOCIAL NETWORKS, OR SERVICES?

Our Service may provide you with access to other websites and services. This may include providing you with the ability to automatically post updates on Facebook and Instagram. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. A link to a third party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Service.

Additionally, you may choose to share information between your ScootRoute account and your social network account (such as Facebook or Instagram). Through this option, you may choose to have personal information and other content about you available from social networks, transmitted and shared through the Service. Similarly, you may choose to have personal information and other content about you available from ScootRoute, including your location and route information, transmitted to and shared through your social network account.

By setting your ScootRoute Account to integrate with social networks, including by signing onto ScootRoute by using your social network account you agree to share information (including personal information) between ScootRoute and such social networks, for the purposes provided under this Privacy Policy.

The social network’s use of information made available by ScootRoute is governed by that social network’s privacy policy and controlled by the social network, not by this Privacy Policy or ScootRoute.

When you connect to the social network account through the Service for the first time or otherwise make the Service interact with your social network account, you will be asked by the social network to permit the social network to share your personal information stored on such social network with ScootRoute. We collect your information from your social network account only in accordance with the permissions granted by you (such as your name, email address, list of friends, profile picture and other information available via the applicable social network).

You understand and agree that the Service may access, make available and store such information so that it is available on and through your ScootRoute Account, until your ScootRoute Account is deleted.

Please note that certain information which you have defined as private on your third party social network accounts may become public to other ScootRoute Users through the Service once you have allowed the social network to share such information with ScootRoute.

IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?

We want your information (including personally identifiable information) to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. 

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

Personally identifiable information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. By using the Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information.  If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location. 

FOR HOW LONG WILL MY PERSONALLY IDENTIFIABLE INFORMATION BE KEPT? 

We will only retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it. 

To determine the appropriate retention period for personally identifiable information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personally identifiable information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

WHAT CHOICES DO I HAVE REGARDING MY PERSONALLY IDENTIFIABLE INFORMATION?

We generally use personally identifiable information as described in this Privacy Policy or our Terms of Use or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must “opt in” and give us permission to use your personally identifiable information for any other purpose. You may also change your preference and “opt out” of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting dmca@lutzker.com.

DO NOT TRACK

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

We may revise this Privacy Policy from time to time.  We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personally identifiable information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service. Your continued use of the Service following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.

WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact our Privacy Agent in any of the following ways:

By e-mail:

dmca@lutzker.com

By postal mail or courier:

Attn: Privacy Agent

Lutzker & Lutzker LLP

1233 20th St NW

Suite 703

Washington, DC 20036

Phone: 202-408-7600

Email: dmca@lutzker.com

BY USING THE SERVICE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE THE SERVICE.  CONTINUED USE OF THE SERVICE, FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY THAT DO NOT SIGNIFICANTLY AFFECT THE USE OR DISCLOSURE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION, MEANS THAT YOU ACCEPT THOSE CHANGES.