The scope of this policy

This policy applies to all SOTE users, including Riders and Drivers, including Driver applicants, and to all SOTE platforms and services, including our apps, websites, features and other services, collectively the SOTE Platform. Please remember that your use of the SOTE Platform is also subject to our Terms of Service.

The information we collect

When you use the SOTE Platform, we collect the information you provide, usage information and information about your device. We also collect information about you from other sources such as third-party services and optional programs in which you participate, which we may combine with other information we already have about you.

A. Information you provide to us

Account registration

When you create an account with SOTE, we collect the information you provide us, such as your name, email address, phone number and payment information. You may choose to share additional information for your Rider profile, such as your photo or saved addresses, for example home or work, and set other preferences such as your preferred pronouns.

Driver information

If you apply to be a Driver, we collect the information you provide in your application, including your name, email address, phone number, birth date, profile photo, physical address, government identification number, driver's license information, vehicle information and car insurance information. We also collect the payment information you provide us, including your bank routing numbers and tax information. Depending on where you want to drive, we may ask for additional business license or permit information or other information needed to manage driving and location-relevant programs. We may also request additional information after you become a Driver, including information to confirm your identity, such as a photo.

SOS contact information

We may request contact-list permission so Riders and Drivers can add SOS contacts within the user and driver apps.

Ratings and feedback

When you rate and provide feedback about Riders or Drivers, we collect all of the information you provide in your feedback.

Communications

When you contact us or we contact you, we collect any information you provide, including the contents of messages or attachments you send us.

B. Information we collect when you use the SOTE Platform

Location information

Great rides start with an easy and accurate pickup. The SOTE Platform collects location information, including GPS and WiFi data, differently depending on your SOTE app settings, device permissions and whether you are using the platform as a Rider or Driver.

• Riders: We collect your device's precise location when you open and use the SOTE app, including while the app is running in the background from the time you request a ride until it ends. SOTE also tracks the precise location of scooters and e-bikes at all times.
• Drivers: We collect your device's precise location when you open and use the app, including while it is running in driver mode. We may also collect precise location for a limited time after you exit driver mode in order to detect ride incidents, and continue collecting it until a reported or detected incident is no longer active.

Usage information

We collect information about your use of the SOTE Platform, including ride information such as the date, time, destination, distance, route, payment and whether you used a promotional or referral code. We also collect information about your interactions with the SOTE Platform, such as the pages and content you view and the dates and times of your use.

Device information

We collect information about the devices you use to access the SOTE Platform, including device model, IP address, browser type, operating system version, carrier and manufacturer identity, radio type, preferences and settings, application installations, device identifiers, advertising identifiers and push notification tokens. If you are a Driver, we also collect mobile sensor data from your device, such as speed, direction, height, acceleration, deceleration and other technical data.

Communications between Riders and Drivers

We work with a third party to facilitate phone calls and text messages between Riders and Drivers without sharing either party's actual phone number with the other. While a third party provides the communication service, we collect information about those communications, including participants' phone numbers, date and time, and the contents of SMS messages. For security purposes, we may also monitor or record the contents of phone calls made through the SOTE Platform, and we will notify you before such recording begins.

Address book contacts

You may set your device permissions to grant SOTE access to your contact list, for example to help you refer friends to SOTE. If you do this, we may access and store names and contact information from that address book.

Cookies, analytics and third-party technologies

We collect information through the use of cookies, tracking pixels, data analytics tools such as Google Analytics, SDKs and other third-party technologies to understand how you navigate through the SOTE Platform and interact with SOTE advertising, to make your experience safer, to learn what content is popular, to improve your site experience, to serve you better advertising on other sites and to save your preferences.

Cookies are small text files placed on your device by web servers. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed each time you use the SOTE Platform. You should consult your browser settings if you want to modify cookie behavior. Please note that if you delete or choose not to accept cookies from us, you may miss certain features of the SOTE Platform.

C. Information we collect from third parties

Third-party services

Third-party services provide us with information needed for core aspects of the SOTE Platform as well as for additional services, programs, loyalty benefits and promotions that can enhance your SOTE experience. These services may include background check providers, insurance partners, financial service providers, marketing providers and other businesses. We may obtain information including:

• Background check information to help make the SOTE Platform safer for drivers and riders.
• Insurance, payment, transaction and fraud-detection information related to third-party programs or financial tools.
• Information about your participation in loyalty programs, linked applications, services or features you choose to connect to your SOTE account.
• Demographic and market-segment information provided by specific third-party services.

Enterprise programs

If you use SOTE through your employer or another organization participating in a SOTE Business enterprise program, we may collect information such as your name and contact information from that organization.

Concierge service

If another business or entity orders a SOTE ride for you through our Concierge service, that organization may provide us your contact information and your ride pickup and drop-off locations.

Referral programs

If someone refers you to SOTE, we may collect information about you from that referral, including your name and contact information.

Other users and sources

Other users or public or third-party sources, including law enforcement, insurers, media or pedestrians, may provide us with information about you, for example during an incident investigation or support request.

How we use information

We use your personal information to provide the SOTE Platform, maintain the security and safety of the platform and its users, build and maintain the SOTE community, provide customer support, improve the SOTE Platform and respond to legal proceedings and obligations.

Providing the SOTE Platform

We use your personal information to provide an intuitive, useful, efficient and worthwhile experience on our platform. This includes using your information to:

• Verify your identity and maintain your account, settings and preferences.
• Connect you to rides and track their progress.
• Calculate prices and process payments.
• Allow Riders and Drivers to connect regarding their ride and choose to share location with others.
• Communicate with you about rides and platform experiences.
• Collect feedback regarding your experience.
• Facilitate additional services and programs with third parties.
• Operate contests, sweepstakes and other promotions.

Maintaining the security and safety of the SOTE Platform and its users

Providing a secure and safe experience is central to the platform. We use personal information to:

• Authenticate users.
• Verify that Drivers and their vehicles meet safety requirements.
• Investigate and resolve incidents, accidents and insurance claims.
• Encourage safe driving behavior and avoid unsafe activities.
• Find and prevent fraud.
• Block and remove unsafe or fraudulent users from the SOTE Platform.

Building and maintaining the SOTE community

We use personal information to communicate with you about events, promotions, elections and campaigns, personalize and provide content, experiences, communications and advertising to promote and grow the SOTE Platform, and help facilitate donations you choose to make through the platform.

Providing customer support

We use personal information to investigate and help resolve questions or issues you have regarding the SOTE Platform and to provide support or respond to you.

Improving the SOTE Platform

We use personal information to perform research, testing and analysis, develop new products, features, partnerships and services, prevent and resolve software or hardware bugs and monitor and improve operations, processes, security practices, algorithms and other modeling.

Responding to legal proceedings and requirements

Sometimes the law, government entities or regulatory bodies impose demands and obligations on us with respect to the services we seek to provide. In those circumstances, we may use your personal information to respond to those demands or obligations.

How we share your information

We do not sell your personal information. To make the SOTE Platform work, we may need to share your personal information with other users, third parties and service providers.

A. Sharing between SOTE users

Riders and Drivers

Rider information shared with Driver: Upon receiving a ride request, we may share with the Driver the Rider's pickup location, name, profile photo, rating, Rider statistics such as approximate number of rides and years as a Rider, and information the Rider includes in the Rider profile, such as preferred pronouns. Upon pickup and during the ride, we may also share the Rider's destination and any additional stops entered into the app. Once the ride is finished, we may share the Rider's rating and feedback with the Driver. We remove the Rider's identity associated with ratings and feedback when we share it, although a Driver may still be able to infer who provided that feedback.

Driver information shared with Rider: Upon a Driver accepting a requested ride, we may share with the Rider the Driver's name, profile photo, preferred pronouns, rating, real-time location, vehicle make, model, color and license plate, as well as other information in the Driver's SOTE profile, such as country flag, why the Driver drives and Driver statistics like approximate number of rides and years as a Driver.

Although we help Riders and Drivers communicate with each other to arrange a pickup, we do not share your actual phone number or other contact information with other users unless needed for a lost-and-found connection and only with your consent.

Shared ride Riders

When Riders use a SOTE Shared ride, we may share each Rider's name and profile picture for safety purposes. Riders may also see each other's pickup and drop-off locations as part of understanding the shared route.

Rides requested or paid for by others

If a ride is requested or paid for by another person or organization, such as through a business profile, code, coupon, subsidized program or corporate card, we may share ride details with that party, including the date, time, charge, rating given, trip region and pickup and drop-off locations.

Referral programs

If you refer someone to the SOTE Platform, we may let them know you generated the referral. If another user referred you, we may share certain information about your use of the SOTE Platform with that user, for example where a referral bonus depends on your joining or completing a required number of rides.

B. Sharing with third-party service providers for business purposes

Depending on whether you are a Rider or Driver, SOTE may share categories of personal information such as personal identifiers, financial information, commercial information, internet or other electronic network activity information and location data for business purposes that support platform operations.

We may disclose those categories of personal information to service providers to support activities such as:

• Maintaining and servicing SOTE accounts.
• Processing or fulfilling rides.
• Providing customer service.
• Processing Rider transactions.
• Processing Driver applications and payments.
• Verifying user identity.
• Detecting and preventing fraud.
• Processing insurance claims.
• Providing Driver loyalty and promotional programs.
• Providing marketing and advertising services to SOTE.
• Providing financing.
• Providing requested emergency services.
• Providing analytics services to SOTE.
• Undertaking internal research to develop the SOTE Platform.

C. For legal reasons and to protect the SOTE Platform

We may share personal information where necessary to comply with applicable law, regulation, civil, criminal or regulatory inquiry, investigation or legal process, respond to legal process such as a subpoena or court order, enforce our Terms of Service, cooperate with law enforcement where we reasonably believe conduct may violate applicable law, or exercise or defend legal claims and protect the rights, property, interests or safety of SOTE, our users, third parties or the public.

D. In connection with sale or merger

We may share personal information while negotiating or in relation to a change of corporate control, such as a restructuring, merger or sale of assets.

E. Upon your further direction

With your permission or upon your direction, we may disclose your personal information to interact with a third party or for other purposes you request.

How we store and protect your information

We retain your information for as long as necessary to provide you and our other users the SOTE Platform. This means we keep your profile information for as long as you maintain an account. We retain transactional information such as rides and payments for at least seven years to ensure we can perform legitimate business functions, including accounting for tax obligations.

If you request account deletion, we will delete your information as described in the account deletion section below. In some cases, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations, for example to resolve open insurance claims or respond to legal claims. When we retain such data, we do so in ways designed to prevent its use for unrelated purposes.

We take reasonable and appropriate measures designed to protect your personal information. However, no security measure can be 100 percent effective, and we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties.

Your rights and choices regarding your data

SOTE provides ways for you to access and delete your personal information, as well as exercise other data rights that give you certain control over your personal information.

A. All users

Email subscriptions

You can always unsubscribe from commercial or promotional emails by clicking unsubscribe in those messages. We may still send transactional and relationship-based emails about your use of the SOTE Platform.

Text messages

You can opt out of receiving commercial or promotional text messages. You may also opt out of receiving all texts from SOTE, including transactional or relationship messages, although doing so may affect your use of the SOTE Platform. Drivers can also opt out of driver-specific messages by texting STOP in response to a driver SMS and re-enable them by texting START in response to the unsubscribe confirmation.

Push notifications

You can opt out of receiving push notifications through your device settings. Please note that doing so may affect certain features, such as notifications that your ride has arrived.

Profile information

You can review and edit certain account information you have chosen to add to your profile by logging in to your account settings and profile.

Location information

You can prevent your device from sharing location information through its system settings, but this may affect SOTE's ability to provide the full range of platform features and services.

Cookie tracking

You can modify your cookie settings in your browser, but if you delete or choose not to accept our cookies, you may miss certain features of the SOTE Platform.

Do Not Track

Your browser may offer a Do Not Track option. The SOTE Platform does not currently support Do Not Track requests at this time.

Deleting your account

If you would like to delete your SOTE account, please visit our privacy homepage. In some cases, we may be unable to delete your account, such as if there is an issue related to trust, safety or fraud. When we delete an account, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations.

Right to know

You have the right to know and see what data we have collected about you, including:

• The categories of personal information we have collected about you.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose for collecting your personal information.
• The categories of third parties with whom we have shared your personal information.
• The specific pieces of personal information we have collected about you.

Right to delete

You have the right to request that we delete the personal information we have collected from you and direct our service providers to do the same, subject to certain exceptions. Exceptions may apply where the information is necessary to:

1. Complete your transaction.
2. Provide you a good or service.
3. Perform a contract between us and you.
4. Protect your security and prosecute those responsible for breaching it.
5. Fix our system in the case of a bug.
6. Protect free-speech rights of you or other users.
7. Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that follows applicable ethics and privacy law.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Other rights

You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

How to exercise rights

You may visit our privacy homepage to authenticate and exercise rights through our website, or write to us through an email webform or support contact to exercise your rights. To respond to some requests, we may need to verify your request by asking you to log in and authenticate your account or otherwise verify your identity by providing information about yourself or your account. Authorized agents can make a request on your behalf if they have legal power of attorney or provide signed permission, proof of identity verification and confirmation that you authorized the request.

Response timing and format

We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

Children's data

SOTE is not directed to children, and we do not knowingly collect personal information from children under the age of 13. If we learn that a child under 13 has provided personal information, we will take steps to delete that information. If you believe that a child under the age of 13 has given us personal information, please contact us.

Links to third-party websites

The SOTE Platform may contain links to third-party websites. Those websites may have privacy policies that differ from ours. We are not responsible for those websites, and we recommend that you review their policies directly. Please contact those websites if you have questions about their privacy practices.

Changes to this Privacy Policy

We may update this policy from time to time as the SOTE Platform changes and privacy law evolves. If we update it, we will do so online, and if we make material changes, we will let you know through the SOTE Platform or by another method of communication such as email. When you use SOTE, you are agreeing to the most recent terms of this policy.

Contact us

If you have any questions or concerns about your privacy or anything in this policy, including if you need to access this policy in an alternative format, we encourage you to contact us.