ROADIO PRIVACY POLICY 

LAST REVISED ON: JUNE 1, 2024  

Roadio, Inc. (“Company”, “Roadio” or “We”) respect your privacy and are committed to protecting it through our  compliance with this policy. This policy describes the types of information we may collect from you or that you  may provide when you visit the website roadio.ai (our “Website”) or use the application RoadioSafety (the “or the  App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. If you're a  resident of California or Nevada or visiting us from the European Economic Area ("EEA"), you should read this  policy and the applicable sections below for residents of California and Nevada and visitors from the UK and EEA.  

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and  how we will treat it. We use your personal data to provide and improve our platform. By using the platform, you  agree to the collection and use of information in accordance with this privacy policy. If you do not agree with our  policies and practices, your choice is not to use our Website or the App. By accessing or using this Website or the  App, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see “Changes to Our  privacy Policy” below). Any changes to this Privacy Policy will be effective immediately on posting the updated  Privacy Policy unless otherwise stated or as required by applicable law (for example, notice and opt-in or opt-out  consent may be required). Your continued use of this Website or the App after we make changes is deemed to be  acceptance of those changes to the fullest extent permitted by applicable law, so please check the policy periodically  for updates.  

1. SCOPE OF ROADIO PRIVACY POLICY 

This Privacy Policy applies to all aspects of our Website or the App as well as to information we may  collect offline. This Website or the App may link to or incorporate websites or content hosted and served  by others over which we have no control, such as third-party websites, online properties, platforms, social  media, or systems, which are each governed by the privacy policy and business practices of the third party.  You understand and agree that Roadio is not responsible for the security, privacy, or business practices of  any third party.  

This policy applies to information we collect  

On this Website or the App and all associated Roadio web apps. 

In email, text, and other electronic messages between you and this Website or the App.

When you interact with our advertising and applications on third-party websites and services,  if those applications or advertising include links to this policy. 

From telematic devices, including Roadio sensors and mobile device sensors which transmit  data to our Website or the App. 

It does not apply to information collected by:  

Us offline or through any other means, including on any other website or application operated  by the Company or any third party; or 

Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or the App. 

2. YOUR INFORMATION 

2.1. Information We Collect About You and How We Collect It. We collect several types of  information from and about users of our Website or the App, including information: 

By which you may be personally identified, such as name, age, gender, postal address, e-mail  address, telephone number and any other identifier by which you may be contacted online or  offline, including IP addresses and cookie identifiers (collectively, “personal information”); 

Vehicle (ebike, moped, or other two wheeler) model, vehicle year, vehicle purchase location,  reason for purchasing a two-wheeler or three wheeler, other types of vehicles in your  household, vehicle trips ebike or other two wheeler is replacing, other accessories  purchased; and/or  

About your internet connection, the equipment you use to access our Website or the App, and  usage details. 

We collect this information:  

Directly from you when you provide it to us. 

Automatically as you navigate through the site. Information collected automatically may  include usage details, IP addresses, and information collected through cookies, web beacons,  and other tracking technologies. 

From third parties, for example, our business partners.  

2.2. Information you provide. The information we collect on or through our Website or the App  may include: 

Information that you provide by filling in forms on our Website or the App. This includes  information provided at the time of registering to use or creating an account on our Website or  the App, purchasing our products, subscribing to our services, posting material, or requesting  further services. We may also ask you for information when you report a problem with our  Website or the App. 

Details of transactions you carry out through our Website or the App and of the fulfillment of  your orders, in which event you may be required to provide financial information before  placing an order through our Website or the App. 

Records and copies of your correspondence (including email addresses), if you contact us.  Your responses to surveys that we might ask you to complete for research purposes.  Your search queries on the Website or the App or web app.  

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of  the Website or the App, or transmitted to other users of the Website or the App or third parties (collectively,  “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk.  Although take measures to ensure the security of our Website or the App, and any information we collect,  please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the  actions of other users of the Website or the App with whom you may choose to share your User  Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed  by unauthorized persons.  

2.3. Information We Collect Through Automatic Data Collection Technologies. As you navigate  through and interact with our Website or the App, we may use automatic data collection technologies to  collect certain information about your equipment, browsing actions, and patterns, including: 

Details of your visits to our Website or the App, including date, ride frequency, ride duration,  time of day, traffic data, location data, logs, and other communication data and the resources  that you access and use on the Website or the App. 

Objects visible in video footage captured on Roadio hardware and transmitted to our Website  or App. 

Information about your computer and internet connection, including your IP address,  operating system, and browser type. 

We also may use these technologies to collect information about your online activities over time and across  third-party websites or other online services (behavioral tracking). See our website for information on how  you can opt out of behavioral tracking on this website and how we respond to web browser signals and  other mechanisms that enable consumers to exercise choice about behavioral tracking.  

The information we collect automatically may include personal information, but we may maintain it or  associate it with personal information we collect in other ways or receive from third parties. It helps us to 

improve our Website or the App and to deliver a better and more personalized service, including by  enabling us to:  

Estimate our Website or the App usage statistics and usage patterns. 

Store information about your preferences, allowing us to customize our Website or the App  according to your individual interests. 

Improve the services we provide to our users. 

Recognize you when you return to our Website or the App. 

The technologies we use for this automatic data collection may include:  

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your  computer. You may refuse to accept browser cookies by activating the appropriate setting on  your browser. However, if you select this setting you may be unable to access certain parts of  our Website or the App. Unless you have adjusted your browser setting so that it will refuse  cookies, our system will issue cookies when you direct your browser to our Website or the  App. 

Flash Cookies. Certain features of our Website or the App may use local stored objects (or  Flash cookies) to collect and store information about your preferences and navigation to,  from, and on our Website or the App. Flash cookies are not managed by the same browser  settings as are used for browser cookies. For information about managing your privacy and  security settings for Flash cookies, see “Choices About How We Use and Disclose Your  Information” below. 

Web Beacons. Pages of the Website or the App and our e-mails may contain small electronic  files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)  that permit the Company, for example, to count users who have visited those pages or opened  an email and for other related website or the App statistics (for example, recording the  popularity of certain website or the App content and verifying system and server integrity). 

Telematics Devices. Use of certain Roadio products, when paired with the App, will collect  certain information about where and how you travel, and your surroundings when you do so,  via a combination of cameras and other positioning tools located within the Roadio products  and/or native to your mobile device. 

We do not collect personal information automatically, but we may tie this information to personal  information about you that we collect from other sources or you provide to us.  

2.4. Third-Party Use of Cookies and Other Tracking Technologies. Some content or the  Applications, including advertisements, on the Website or the App are served by third-parties, including  advertisers, ad networks and servers, content providers, and application providers. These third parties may  use cookies alone or in conjunction with web beacons or other tracking technologies to collect information  about you when you use our Website or the App. The information they collect may be associated with your  personal information or they may collect information, including personal information, about your online  activities over time and across different websites and other online services. They may use this information  to provide you with interest-based (behavioral) advertising or other targeted content. We do not control  these third parties’ tracking technologies or how they may be used. If you have any questions about an  advertisement or other targeted content, you should contact the responsible provider directly. For  information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.  

  

3. HOW WE USE YOUR INFORMATION 

We use information that we collect about you or that you provide to us, including any personal information: 

To present our Website or the App and its contents to you. 

To provide you with information, products, or services that you request from us. 

To fulfill any other purpose for which you provide it. 

To provide you with notices about your account, including expiration and renewal notices. To carry out our obligations and enforce our rights arising from any contracts entered into  between you and us, including for billing and collection. 

To notify you about changes to our Website or the App or any products or services we offer or  provide though it. 

To use data analysis, identifying usage trends, determining the effectiveness of our  promotional campaigns and to evaluate and improve our Service, products, services,  marketing and your experience.  

To contact you with newsletters, marketing or promotional materials and other information  that may be of interest to you. You may opt-out of receiving any, or all, of these  communications from us by following the unsubscribe link or instructions provided in any  email we send or by contacting us.  

To contact you with respect to items, products or services that are germane to the products and  services that the Company might provide you.  

To allow you to participate in interactive features on our Website or the App. 

In any other way we may describe when you provide the information. 

For any other purpose with your consent.  

We may also use your information to contact you about our own and third-parties’ goods and services that  may be of interest to you. If you do not want us to use your information in this way, please contact us at  support@roadio.ai. For more information, see “Choices About How We Use and Disclose Your  Information” below.  

We may use the information we have collected from you to enable us to display advertisements to our  advertisers’ target audiences. Even though we do not disclose your personal information for these purposes  without your consent, if you click on or otherwise interact with an advertisement, the advertiser may  assume that you meet its target criteria. We are not selling, renting, releasing, disclosing, disseminating,  making available, transferring, or otherwise communicating orally, in writing, or by electronic or other  means, your personal information and data to any persons or entities.  

4. RETENTION AND TRANSFER OF INFORMATION  

4.1. RETENTION OF YOUR PERSONAL INFORMATION AND DATA 

The Company will retain your personal information and data only for as long as is necessary for the  purposes set out in this privacy policy. We will retain and use your personal information and data to the  extent necessary to comply with our legal obligations (for example, if we are required to retain your data to  comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.  

The Company will also retain your usage data for internal analysis purposes. Usage data is generally  retained for a shorter period of time, except when this data is used to strengthen the security or to improve  the functionality of our platform, or we are legally obligated to retain this data for longer time periods.  

4.2. TRANSFER OF YOUR PERSONAL DATA 

Your personal information and data is processed at the Company's operating offices and in any other places  where the parties involved in the processing are located. It means that this information may be transferred  to — and maintained on — computers located outside of your state, province, country, or other  governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.  Your consent to this privacy policy followed by your submission of such information represents your  agreement to that transfer. 

The Company will take all steps reasonably necessary to ensure that your personal information and data is  treated securely and in accordance with this privacy policy and no transfer of your personal information  and data will take place to an organization or a country unless there are adequate controls in place including  the security of your data and other personal information.  

5. SECURITY OF YOUR PERSONAL DATA 

The security of your personal information and data is important to us, but remember that no method of  transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use  commercially acceptable means to protect your personal information and data, we cannot guarantee its  absolute security. Any natural or legal person who processes the data on behalf of the Company may have  access to your personal information or data. These third-party vendors collect, store, use, process and  transfer information about your activity on our platform in accordance with their privacy policies.  

6. DISCLOSURE OF YOUR INFORMATION 

6.1. Information We May Disclose. Some content or the Applications, including advertisements, on  the Website or the App may disclose aggregated information about our users, and information that does not  identify any individual, without restriction. We may disclose personal information that we collect or you  provide as described in this Privacy Policy: 

To our subsidiaries and affiliates. 

To contractors, service providers, and other third parties we use to support our business and  who are bound by contractual obligations to keep personal information confidential and use it  only for the purposes for which we disclose it to them.  

To a buyer or other successor in the event of a merger, divestiture, restructuring,  reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets,  whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in  which personal information held by the Company about our Website or the App users is  among the assets transferred. 

To fulfill the purpose for which you provide it.  

For any other purpose disclosed by us when you provide the information. 

With your consent. 

We may also disclose your personal information:  

To comply with any court order, law, or legal process, including to respond to any government  or regulatory request. 

To enforce or the Apply our Terms of Use and other agreements, including for billing and  collection purposes. 

If we believe disclosure is necessary or the Appropriate to protect the rights, property, or  safety of the Company, our customers, or others. This includes exchanging information with  other companies and organizations for the purposes of fraud protection and credit risk  reduction. 

6.2. Choices About How We Use and Disclose Your Information. We strive to provide you with  choices regarding the personal information you provide to us. We have created mechanisms to provide you  with the following control over your information: 

Tracking Technologies and Advertising. You can set your browser to refuse all or some  browser cookies, or to alert you when cookies are being sent. To learn how you can manage  your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you  disable or refuse cookies, please note that some parts of this site may then be inaccessible or  not function properly.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share  your personal information with unaffiliated or non-agent third parties for promotional  purposes, you can opt-out by sending us an email with your request to support@roadio.ai. 

Promotional Offers from the Company. If you do not wish to have your email address/contact  information used by the Company to promote our own or third parties’ products or services,  you can opt-out by sending us an email stating your request to support@roadio.ai. If we have  sent you a promotional email, you may send us a return email asking to be omitted from  future email distributions. This opt out does not apply to information provided to the  Company as a result of a product purchase, warranty registration, product service experience  or other transactions. 

Targeted Advertising. If you do not want us to use information that we collect or that you  provide to us to deliver advertisements according to our advertisers’ target-audience  preferences, you can opt-out by sending us an email stating your request to  support@roadio.ai. For this opt-out to function, you must have your browser set to accept all  browser cookies. 

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However these third parties may provide you with ways to choose not to have your information collected or  used in this way. You can opt out of receiving targeted ads from members of the Network Advertising  Initiative (”NAI”) on the NAI’s website.  

California residents may have additional personal information rights and choices. Please see “Your  California Privacy Rights” below for more information.  

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter  603A may submit a request to this designated address: support@roadio.ai. However, please know we do  not currently sell data triggering that statute’s opt-out requirements.  

7. YOUR CALIFORNIA PRIVACY RIGHTS 

If you are a California resident, California law may provide you with additional rights regarding our use of  your personal information.  

8. DATA SECURITY 

We have implemented measures designed to secure your personal information from accidental loss and  from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our  secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.  

The safety and security of your information also depends on you. Where we have given you (or where you  have chosen) a password for access to certain parts of our Website or the App, you are responsible for  keeping this password confidential. We ask you not to share your password with anyone. We urge you to be  careful about giving out information in public areas of the Website or the App like message boards. The  information you share in public areas may be viewed by any user of the Website or the App.  

Unfortunately, the transmission of information via the internet is not completely secure. Although we do  our best to protect your personal information, we cannot guarantee the security of your personal  information transmitted to our Website. Any transmission of personal information is at your own risk. We  are not responsible for circumvention of any privacy settings or security measures contained on the Website  or the App.  

9. CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the  Privacy Policy has been updated on the Website or the App home page. If we make material changes to  how we treat our users’ personal information, we will notify you by email to the primary email address  specified in your account and/or through a notice on the Website or the App home page. The date the  Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have  an up-to-date active and deliverable email address for you, and for periodically visiting our Website and  this privacy policy to check for any changes.  

10. CONTACT INFORMATION 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:  

Roadio, Inc.  
201 Spear Street Ste  
1100 PMB #11  
San Francisco, 94105  
Attn: Privacy Support  
support@roadio.ai

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