PRIVACY POLICY

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
• Do we process any sensitive personal information? Ride and fitness information and precise geolocation may be considered sensitive in some jurisdictions. We process this information to provide features you request, with your permission, or as otherwise permitted by applicable law.
• Do we collect any information from third parties? If you choose to connect a third-party service such as Strava, Garmin, Google, or Apple, we may receive information that you authorize that service to provide to RidePal.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
• In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
• How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
• What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
• How do you exercise your rights? The easiest way to exercise your rights is by visiting our account deletion request page, emailing us at contact@ridepal.app, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• usernames
• profile information and content you choose to share
• ride, route, trail, and activity information
• photos, videos, reviews, comments, and support communications

Sensitive Information.

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• fitness and activity data
• precise geolocation and route data

Payment Data.

RidePal does not receive or store your full payment card number or card security code for native app purchases. Apple App Store and Google Play process native subscription payments. RidePal and our subscription infrastructure provider, Superwall, receive limited transaction and entitlement information needed to activate RidePal Pro, prevent fraud, provide support, and maintain accounting records. This may include a store transaction identifier, product, subscription status, purchase and expiration dates, price, currency, and a pseudonymous RidePal account identifier. Website purchases, when offered, may be processed by Stripe and Superwall; RidePal receives account, transaction, and entitlement information but not your full payment card details. For more information, review the privacy notices for Apple, Google, Superwall, and Stripe.

Social Media Login Data.

We may provide you with the option to register using Sign in with Apple or Google Sign-In. If you choose one of these options, we receive the account information that the provider makes available with your authorization, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data.

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your camera, photo or video library, motion and fitness sensors, Bluetooth, and notifications. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Business listing and claim data

If RidePal invites you to manage a bike shop or rental listing, we process the business contact address used for the invitation, a one-way hash of that address, invitation status and timestamps, the RidePal account connected to the listing, listing edits, review notes, and an audit history. We also process business details and photos you choose to submit. Invitation and claim evidence is restricted to authorized RidePal personnel; approved listing details and photos are public.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Strava Integration

Connecting Strava is optional. RidePal uses Strava's authorization process, and RidePal only receives the permissions you approve. Depending on the feature and permissions you select, Strava may provide RidePal with your Strava athlete identifier, basic profile information, authorization scope, and activity information such as activity name and type, timestamps, distance, duration, route or GPS information, elevation, speed, heart rate, cadence, and power when that information is available.

RidePal collects this information through the Strava API after you authorize the connection. You may also choose to provide a Strava export file directly to RidePal. We use this information only to provide the Strava features you request, such as sending a RidePal ride to your Strava account or, where available, showing your imported Strava activities privately to you.

You may withdraw your authorization at any time by disconnecting Strava in RidePal settings or by removing RidePal from your Strava connected-app settings. Disconnecting stops future access and removes the stored authorization credentials used by RidePal. You may delete imported activities in RidePal, delete your RidePal account, or contact contact@ridepal.app to request deletion of Strava-sourced information associated with your account. We will confirm when a requested deletion has been completed.

Strava may monitor and collect information about RidePal's use of the Strava API and may use that usage information for its business purposes, including API operation, enhancement, support, security, and compliance. Your use of Strava remains subject to Strava's own terms and privacy policy.

Apple Health and Fitness Data

If you choose to connect Apple Health, RidePal can read workout data you authorize (such as cycling workouts, distance, duration, heart rate, and energy burned) to import past rides, and can save rides you record with RidePal back to Apple Health. You control this access in the Health app and in RidePal settings, and you can revoke it at any time.

We use Apple Health data solely to provide the features you request. We never use Apple Health or other health and fitness data for advertising, marketing, or similar purposes; we never sell it; and we never share it with advertisers, data brokers, or any third party except as required to provide the feature you requested or as required by law.

Public Content

RidePal is built around a public trail map, and some content you contribute is public by design. Trail reviews, ratings, trail photos, submitted trails and trail edits, and leaderboard entries are visible to other RidePal users in the app and on our public website (ridepal.app), where they may also appear in search-engine results and in link previews when a trail page is shared. Public content is attributed to your RidePal display name. Ride recordings and ride photos are private to you unless you choose to share them or attach them to a trail.

Photos you upload may contain embedded metadata (such as the location and time they were taken). We display photos publicly; think before uploading images you would not want public.

If you delete a photo or review, we remove it from trail pages. If you delete your account, your reviews and photos are disassociated from your identity or deleted, but trail map contributions (such as trail locations, names, geometry, and corrections) remain part of the RidePal trail database — like edits to a shared map, they cannot be meaningfully "returned" once merged.

Approved business listing details and business-provided photos are also public by design. If a connected account is deleted, RidePal may retain the approved business listing and moderation audit needed to keep the map accurate, while removing or disassociating account-specific access where appropriate. A business representative can contact us to update access or dispute a listing.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To provide connected-service features you request, including importing authorized Strava activities or sending a RidePal-recorded activity to your Strava account.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process your email address and related preferences to send RidePal product updates, feature announcements, offers, surveys, community news, and other promotional communications, where permitted by law and in accordance with your marketing preferences. You can opt out of marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To measure and attribute marketing. We may process device identifiers and app-usage events to measure the effectiveness of our marketing campaigns and attribute app installs. We do not use health, fitness, ride, or precise location data for advertising or marketing purposes.
• To post testimonials. We post testimonials on our Services that may contain personal information.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EEA, United Kingdom, or Switzerland, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the legal bases we rely on to process your personal information:

• Performance of a contract. Most processing happens to provide the Services you signed up for — creating your account, recording and syncing rides, displaying trails, and operating features you use.
• Consent. We rely on your consent for precise location access (which you grant through device permissions and can revoke at any time), optional connections such as Strava, Garmin, or Apple Health, marketing emails, and Live Ride sharing. You can withdraw consent at any time without affecting prior processing.
• Legitimate interests. We process limited information to secure the Services, prevent fraud and abuse, moderate public content, understand aggregate usage, and measure our own marketing — where those interests are not overridden by your rights.
• Legal obligations. We process information where necessary to comply with law, such as tax and accounting requirements.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We use service providers to operate RidePal. Depending on the features you use, these providers may process account identifiers, device and usage information, location or activity data, user content, diagnostics, and subscription information on our behalf:

• Google and Firebase. Authentication, databases, cloud functions, storage, push notifications, App Check, analytics, and crash reporting.
• Apple and Google Play. Authentication, app distribution, and processing and managing native subscriptions.
• Superwall. Paywall presentation, subscription and entitlement management, transaction webhooks, and subscription analytics.
• Mapbox. Maps, geocoding, route visualization, and related map services.
• Mixpanel, Appstack, Meta, and Vercel Analytics. Product analytics, attribution, performance measurement, and service improvement where configured.
• Stripe. Processing website payments if website checkout is offered.

We may also need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Connected Services. When you ask RidePal to send a recorded activity to Strava or another connected service, we provide the activity information necessary to complete your request. The connected service processes that information under its own terms and privacy policy.

International Data Transfers

We are based in the United States, and your information is processed and stored in the United States by us and the service providers listed above. If you use the Services from the EEA, UK, Switzerland, or another region with data-transfer restrictions, your information is transferred to the United States. Where required, we rely on safeguards recognized under applicable law, including our service providers' certifications under the EU-U.S. Data Privacy Framework and standard contractual clauses incorporated in our agreements with service providers.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services may let you register and log in using Sign in with Apple or Google Sign-In. When you choose this option, we receive an account identifier and the profile information you authorize the provider to share, which may include your name, email address, and profile picture. We do not receive your Apple or Google password.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We keep account data while your account is active and as needed to provide the Services. After account deletion, we may retain limited transaction, tax, security, fraud-prevention, dispute, and audit records where required or permitted by law. We may also retain aggregated or de-identified metrics that can no longer reasonably be linked to you. Backup copies are removed according to our normal backup lifecycle.

We retain Strava authorization credentials only while needed to provide the connection you requested. We remove those credentials when you disconnect Strava. Strava-sourced information is retained only for the connected feature and subject to Strava's requirements. You can request its deletion using the controls and contact methods described in the Strava Integration section above.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are in the EEA, UK, or Switzerland, you have the rights to access, rectify, or erase your personal information; to restrict or object to processing; and to data portability. You may exercise these rights via our account deletion page or contact@ridepal.app; we respond within the timeframes required by law. You also have the right to lodge a complaint with your local data protection supervisory authority (or the ICO in the UK), though we would appreciate the chance to address your concerns first.

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Marketing communications

If you choose to receive marketing or promotional emails from us, we may use your email address to send you product updates, feature announcements, offers, surveys, community news, and other RidePal-related communications. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link included in our emails or by contacting us at contact@ridepal.app.

After you unsubscribe, we may still send you non-marketing communications, such as account, subscription, security, service, transactional, or legal notices where permitted by law.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update or delete your user account.
• Visit our account deletion request page if you cannot access the app.
• Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
• Deleting your RidePal account does not cancel an Apple App Store or Google Play subscription. Store billing may continue until you cancel through the store that processed the purchase.

If you have questions or comments about your privacy rights, you may email us at contact@ridepal.app.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - As long as the user has an account with us
• Category B - As long as the user has an account with us
• Category D - While the account is active and longer where transaction, tax, dispute, or fraud-prevention records must be retained
• Category F - While the account is active or for a shorter analytics retention period
• Category G - As long as the user has an account with us
• Category H - As long as the user has an account with us or until the user deletes the content
• Category K - While the account is active or for a shorter analytics retention period
• Category L - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We do not sell personal information for money. We disclose personal information to the service providers and connected services described above for business purposes. Depending on applicable law and how analytics or advertising tools are configured, certain disclosures for cross-context behavioral advertising or targeted advertising may be considered "sharing." Where required, we provide applicable notice and opt-out rights.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting our account deletion request page, by emailing us at contact@ridepal.app, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at contact@ridepal.app. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@ridepal.app or contact us by post at:

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request deletion of your RidePal account and associated data, please visit our account deletion request page. You can also email us at contact@ridepal.app. Account deletion does not cancel a subscription billed by Apple or Google; cancel it separately through the applicable store to stop future renewals.