Effective Date: February 27, 2023
Your privacy is important to us. We created this policy to let you know about the information we collect and process about awesome people like you that use our sustainable mobility services, visit our websites, use our mobile apps, buy our products, or otherwise interact with us. It applies to you regardless of where you live.
When you read this policy (and we hope that you will), you will learn about the kinds of information we collect about you, how we use that information, when we might disclose your information to others, and your rights and choices regarding this information.
Before we get into it, just keep in mind that when you read this policy that by “Scooty,” “we,” “us,” or “our,” we mean Scooty Mobility Inc. and our related companies that we own or control.
Also note that Scooty may create de-identified, aggregated, or anonymized data from your information so that it is reasonably non-identifiable to you. Where we transform data in this way, it is not within the scope of this policy.
This policy does not apply to independent third parties that may collect or control your information separately from Scooty like our business partners and retail sellers of our vehicles. Please be aware that companies not part of the Scooty family of companies are separate legal entities from Scooty and have their own privacy policies and practices. While we encourage you to review those third-party policies, please understand that Scooty is not responsible for those companies’ privacy policies and related legal obligations.
Scooty Mobility Inc. having an address at 1 Nelson Street West, Brampton, Ontario, Canada, L6X 1B6 is the responsible entity for your information.
If you have any questions about this policy, please let us know by writing to us at email@example.com. What Information Do We Collect?
a. Information You Provide to Us
i. Contact Information: Before you take a ride on a Scooty rental vehicle, participate in our surveys, contests, sweepstakes, and promotions, subscribe to our marketing updates, register for, or attend, an event, or when you register a Scooty vehicle you purchased directly from us, you may be asked to provide certain basic personal contact information such as first name, last name, email address, and a mailing or postal address, phone number, and account information such as login and password.
ii. Government-Issued Identification: In many places where we offer vehicles for rent, rules require riders to be of a certain minimum age. To hire or employ you, we may be required to confirm your identity and eligibility for employment. We may ask you to provide your birthdate and driver’s license or other government-issued ID (which may indicate document numbers as well as birth date, gender, and photo).
iii. Demographic Data: We also collect certain demographic data if you provide it to us including age, gender, preferred language, and current location. Note that we may also derive this data from your government-issued ID. See How Do We Use Your Information section below.
iv. Payment Information: If you buy a product directly from us or rent a Scooty vehicle, we will also ask for your payment information, such as a credit card, debit card, or another payment method, and your billing address. Note that Scooty does not store your payment information; we use experienced and trusted third-party payment processors to collect and process your payments for us. We also ask for your Tax Identification Number in jurisdictions that require us to collect this information.
v. Feedback: If you respond to a survey about your experiences with us or offer opinions about our company, the mobility industry, or other topics, we will maintain that information. Likewise, if you comment on blog entries, interact with us on social media, or participate in other Scooty-sponsored forums, we collect that information, too. And, of course, we collect data when you call (such as a recording of the conversation) or write to us for help or seek other customer support services.
vi. Job Applications: If you apply for a job with us, we will collect information from your application or resume.
b. Information from Your Devices
ii. Location and Vehicle Usage: When you rent a Scooty vehicle using our app or visit our website, or connect your privately owned Scooty vehicle to our app, we automatically collect and store location information from your device and from the vehicle you use.
Devices: We collect the location information (e.g., city, state, or postal code where available) associated with the IP address of the device you use to access the services, as well as, with your permission, your mobile device’s location information using GPS or Bluetooth (you can change your location/Bluetooth settings for your mobile device; however, certain features may not be available through the mobile application if you do so).
- Vehicles: We collect the time of use, latitude and longitude of your vehicle in real-time. This information can be used to determine your device or vehicle’s current location, travel direction, and speed.
See Online Advertising in the How Do We Use Your Information section, Other Third Parties in the How Do We Share Your Information section and the Cookie Notice for more information about how we may use this information for advertising.
c. Information from Others
i. Social Media Sites: When you interact with us or post content about us on social media platforms – like Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube, or Pinterest – we may collect certain information from your public profile as well as interests, “likes” and similar information you permit social media platforms to share in this way.
ii. Referrals: We may invite our customers to introduce their friends to our services. If you choose to use our referral service to tell someone about our services, we will provide you with a template message and referral code to send to your friend. We will not collect the friend’s information unless they sign up to use the services with the referral code.
2. How Do We Use Your Information?
a. Products, Services, and Customer Support
- Establish and maintain your account
- Sell and deliver a vehicle to you that you have purchased from us
- Confirm your identity
- Verify your eligibility to rent a vehicle from us
- Rent a vehicle to you
- Troubleshoot and resolve your questions or concerns
- Provide and operate our websites, mobile apps, and related features
- Track our vehicles’ location and availability
- Monitor vehicle health and statuses
- Process payments you make to us
- Provide services to you
- Comply with our agreements with you
b. Consumer Marketing Messages and Other Communications
Communicate with you about:
- Vehicle rental, purchase, or use
- Questions, complaints, or issues you may have
- Changes to our policies
- Your opinions about your experiences with us
- Third-party marketing offers (subject to your consent where required by law)
- Send to you information, news, updates, and offers about us or our services (subject to your consent where required by law)
- Conduct data analyses to better predict content and marketing offers that may interest you
- Personalize content, experiences, and marketing offers to you, including providing you reports, recommendations, and feedback based on your preferences
- Provide more relevant ads to you
- Improve vehicles, products, and services
- Develop new vehicles, products, and services
- Optimize or improve our products, services, and operations
- Help us understand how our products and services can better meet the needs of our customers and cities through statistical, demographic, and marketing analyses of our products and services, app and website use, rider activity, vehicle routes, and demographic trends, for research, analytical, and statistical purposes
d. Business Operations and Legal Compliance
- Manage and protect our networks, services, employees, and users
- Detect, investigate, take action regarding, and prevent illegal activities, misuse, suspected fraud, or situations involving potential threats to the safety or legal rights of any person or entity
- Comply with the law and fulfill lawful requests for information
- Permit you to update, edit, and manage your content
- Conduct research and perform data analyses to better understand our customers and how our vehicles, products, services, websites, and mobile apps are used
- Create pseudonymous, anonymous, and aggregate information about our customers’ use of our vehicles, products, services, websites, and mobile apps
- Use as evidence in litigation
- Establish, protect and defend our legal rights
- Confirm your identity
- Verify eligibility of job applicants
3. How Do and With Who Do We Share Your Information?
a. Affiliates and Subsidiaries. We share information among the companies within the Scooty family of companies. Our “family of companies” includes companies related to us by common control or ownership. We share information within our corporate family as a normal part of business operations and to provide products and services.
b. Public Partners and Transportation Authorities. Because our services are sometimes offered through cities or other political/executive subdivisions or require government or administrative permission to operate in certain locations, our business partners may include governmental authorities, local (regional, provincial, city-level) administrations, local quasi-government entities like a city transit authority, and local public transport operators and appointed data aggregators (each a “public partner”). We may share your information with public partners as may be required to operate in a particular city or location. Public partners may use this information to help improve, inform, or manage city planning activities, public transportation services, traffic congestion, or our vehicles or services (for example, for designating vehicle parking zones, issuing parking fines, or creating restricted areas where our vehicles may not go, like sidewalks) among other public interest purposes the public partner may determine. In some cases, sharing your information with our public partners may be required by law or regulation. For some of these purposes, cities have adopted a standard data set called “Mobility Data Specification” (MDS), MDS standardizes communication and data-sharing between cities and private mobility providers, such as Scooty. Scooty may provide MDS data to public partners where we provide services. For more information about MDS please visit https://www.openmobilityfoundation.org/about-mds/.
c. Other Third Parties
i. Service Providers: We use a variety of third-party service providers to help us run our business and perform functions on our behalf, such as professional services (like law firms, consultants, accountants, and tax advisors), hosting, billing and payment processing, delivering push notifications, providing customer service, helping us prevent fraud, securing our systems, delivering app features, etc. For example, we share your information with companies we’ve hired to provide customer support or assist Scooty in protecting and securing our systems where access to your information is necessary to provide those services. And we could not provide our services without third parties that maintain, service, and manage our fleets of vehicles in all of the cities where we operate. In these cases, we require the third-party service provider to use adequate safeguards to protect the confidentiality of the information they receive and to use your information only for the purposes for which they have been granted access.
ii. Business Partners: We share personal information with other companies that, among others, help us provide services to our customers, or reach potential customers with our marketing messages. Examples include:
Platform Operators: If you use our services through a third-party platform that manages its own fleet of Scooty vehicles, we will also share your information with the platform operator to assist in operating the services.
Advertising and Digital Analytics Companies: Please see the Cookie Notice for a description of how we work with ad exchanges, channel partners, measurement services, and advertising and digital analytics providers like Facebook, Google, and other third-party ad companies.
Joint Marketing Partners: We share information with partners with which we offer co-branded services or engage in joint marketing activities.
- Universities and Research Organizations: We collaborate with universities and researchers around the world to better understand important questions about mobility services like how people use them, how they can be improved, and how they impact the climate. To help with this research, we may share your information with our research partners with your consent.
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- In the event of exigent circumstances, to help prevent the loss of life or serious injury or to protect the personal safety of our personnel, users of our vehicles, websites, mobile apps, or the public
- Detect, investigate, or prevent fraud or privacy issues
- Detect, investigate, prevent, stop, or remediate security incidents involving our computer systems or networks
- Protect our rights or property, and those of our subsidiaries and affiliates, or others, including by enforcing our agreements, terms, and policies
e. Blogs and Social Media. When you interact with us or post content about us on social media platforms – like Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube, or Pinterest – any information that you submit through such features is not confidential and may be accessed by others. For example, if you submit a product review on one of our sites, we may display your review (along with the name provided, if any) on other Scooty sites and on third-party websites. If you provide a comment on our blog, other blog readers will be able to review your comments, and if you interact with us on our social media pages, your comments will be publicly available. So, please take care when using these features. If you’d like to request the removal of information that we have posted about you, please contact us.
f. Parties to Corporate Transactions. We may transfer personal information as part of a corporate transaction like a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets. If a transfer for these reasons is subject to legal restrictions, we will comply with the law.
g. Other Collaborations: After removing certain identifiers, such as your name, phone, and e-mail address (where provided), and combining the resulting information with similar information from other users, Scooty may use, sell, 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, Scooty partners with universities and local government authorities to collaborate on research projects such as understanding traffic and travel patterns in a city.4. Our Legal Basis for Using Your Information
a. It is necessary to provide the services and perform our obligations in accordance with the User Agreement. For example, we cannot provide the service unless we collect and process basic information about you and your location;
b. You have provided your consent to us processing your information (in which case you may revoke your consent at any time);
c. 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;
d. To protect vital interests of our users, pick-up/drop-off partners, staff, and members of the public both on and off the services;
e. It is permitted by law, we may process data in the public interest; and/or
f. The processing is necessary for the purposes of Scooty’s or a third party’s legitimate interests, provided that we have balanced these against your fundamental rights and interests.
5. How long do we keep Information and additional information
a. 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 any applicable law or notified to you.
b. We may ask for a copy of your valid driver's license before you can use certain Scooty Services. When we ask for a copy of your driver’s license, we conduct verification checks to ensure the license is valid and we retain only limited verification information in order for you to use the services.
c. 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 Terms or Service or our Rental Agreement to comply with our legal obligations, or enforce our legal rights.
d. Right to object – Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
e. 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. At our direction, an access or administration fee may apply.
f. Right of rectification – You have the right to request that we rectify inaccurate information about you.
g. Right of erasure – You have the right, in certain cases, to request that we delete your information, provided there are valid grounds for doing so and subject to applicable law.
h. Right to restrict processing – You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.
i. 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.
j. Right to withdraw 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. Furthermore, even in case of a withdrawal, we may continue to use your information as permitted or required by law.
l. 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 Scooty to collect your information, please do not use the Scooty services.
m. 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 such as staffing confirmations, and other information about your use of the service. If you refer others to us using our email functionality, please note that they may choose not to receive any promotional emails from us in the future by following the opt-out instructions in the email invitation.
n. Accessing and Managing Your Information: If you have an account with Scooty, 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 Scooty account at any time by submitting a request to us at firstname.lastname@example.org or by using the in-app “Submit a Request” feature.
Other Important Disclosures
Children’s Personal Information. Scooty services are neither designed for nor targeted to children under the age of 16. If you are under the age of 16, do not provide your personal information through the Scooty service platform. If you believe your child has impermissibly provided us with their personal information, please contact us, so that we can identify and delete their information.
Security and Retention. We use commercially reasonable administrative, technical, and physical security measures to protect personal information entrusted to us.
What is a “Cookie?”
b. Cookies are small files that store Internet settings. A Cookie consists of a string of letters and numbers that uniquely identifies your device and collects information about your use of our website, and in some cases, other websites.
How does Cookie technology work?
a. The first time you visit a website, your device’s Internet browser will download the Cookies placed on the site and store them in your web browser (e.g., Chrome, Safari, Edge, etc.) The Cookie will collect information about your visit – things like what pages you visited, how the site performed, what ads you clicked, how you were brought to the site, account sign-on, or your preferences and settings – depending on the type of Cookie.
b. The next time you visit the same website with the same device, the Cookie, and the information stored in it, are sent back to the website (a first-party Cookie) or sent to another website if the Cookie is operated by a third-party (a third-party Cookie). This exchange of information allows the website to know you’ve been there before and perhaps display more relevant information.
c. We use Cookie data to help us understand things like how many site visitors we had, how fast the pages loaded, or whether we had any performance issues, to record your preferences, personalize content and ads, and track information about the performance of our advertisements, among other purposes. We may combine this information with other information we collect from you.
- What types of Cookies do you use?
Different Cookies serve different purposes. Based on the Cookie’s function and purpose, we divide them into five categories: Strictly Necessary, Performance, Functional, Advertising, and Pixels and Beacon.
a. Strictly Necessary: Cookies that are “strictly necessary” ensure the performance of a website. Without strictly necessary Cookies, you would not be able to use this website as intended. For example, when you open a web page, you are shown a version that corresponds to the bandwidth of the Internet connection you are using, or when traffic is high, we can switch to another server.
b. Performance and Analytics: As the name suggests, performance Cookies collect information on how a website is used and how it performs. They tell us how many visitors we have, how they were referred to our site, how they move about on our site, whether visitors encounter error messages, how fast pages load, and measure the performance of our advertising, etc. This information helps us measure and improve the performance of our site. Performance Cookies do not save any information that permits the identification of the user and are only used to understand and improve the functionality of our websites. One of the performance Cookies we use is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). To learn more about Google’s analytics services and to learn how to opt-out of tracking of analytics by Google click here.
c. Functional: These types of Cookies enhance a website’s performance and functionality like saving details that have already been provided (e.g. user name, language choices, or your location so you don’t have to enter the information later) or enabling the playback of videos. Because functional Cookies collect anonymized information, they cannot track your movement on other websites.
d. Advertising: These Cookies may be set on our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They do not store directly personal information but are based on uniquely identifying your browser and device. When your browser connects to a third-party advertising partner’s web server, the advertising partner is able to read (or set) its own cookies on your device and may collect information about your online activities over time and across different websites or online services. This information is used to show you ads across the Internet that are tailored to your interests. If you do not allow these Cookies, you will experience less targeted advertising.
e. Pixels and Beacons: Pixel tags (a/k/a web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to Cookies described above. You will find invisible pixel tags embedded on web pages or within emails. We, or our service providers, may use pixel tags, among other things, to track the activities of users of our websites or mobile apps, help manage content, measure ad performance and compile statistics about usage. We or our service providers also use pixel tags in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
- How can I control or delete Cookies?
a. Web Browsers
- Change your Cookie settings for at any time using the Cookie consent tool on the website.
- Control Cookies by using the Cookie settings on your browser. Note that If you use your browser settings to block all Cookies (including strictly necessary Cookies) you may not be able to use or access our site.
- Some browsers have incorporated features referred to as “Do Not Track” (DNT). DNT tells the websites you visit that you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals, however, you can still control Cookies by using the other options available to you as described in this section of the Cookie Notice.
If you accept some or all Cookies on the website you still have the option of setting your browser to notify you when you receive a Cookie, so that you may determine whether to accept it or not.
b. Mobile Devices. Apple and Android mobile devices each generate an advertising identifier that can be accessed by apps and used by advertisers in much the same way that Cookies are used on websites. Each operating system provides options to limit tracking and/or reset the advertising ID.
c. Email pixels/web beacons. You can disable pixels or web beacons in email messages through the settings of your email services to prevent the automatic downloading of images.
d. General advertising opt-outs
Many companies are members of industry advertising associations, which provide a simple way to opt out of analytics and advertising cookies, which help you make choices:
- United States: Network Advertising Initiative and Digital Advertising Alliance
- Canada: Digital Advertising Alliance of Canada
- Europe: European Digital Advertising Alliance
For more information and to exercise your choices regarding Facebook and Google ads:
You can also learn more about online advertising at www.aboutads.info/consumers and opt-out of interest-based advertising from many participating ad companies at the ad industry websites below:
- United States: www.aboutads.info
- Canada: www.youradchoices.ca
- Europe: youronlinechoices.eu
Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see:
- Apple: http://support.apple.com/kb/HT4228
- Android: http://www.google.com/policies/technologies/ads/
- Windows: http://choice.microsoft.com/en-US/opt-out
Please note that opting-out of advertising network services does not mean that you will not receive advertising while using our services or other services, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs.
Do-Not-Track. You may disable certain tracking on our websites, as discussed in this section (e.g. by disabling Cookies), and you may opt-out of certain third-party ad networks as described in this Section. For more information about Do-Not-Track signals, please click here.