Pebble Privacy Policy

This Privacy Policy is designed to help you understand how Pebble Mobility, Inc. (“Pebble,” “we,” “us,” or “our”) collects, uses, and discloses personal information in connection with our website available at https://pebblelife.com/, our mobile application, and our other online or offline products and services.

To make this Privacy Policy easier to read, our website and other products and services are collectively called the “Services.”

Beyond this Privacy Policy, your use of the Services is subject to our Terms of Service located at https://pebblelife.com/terms-service.

1. Updates to This Privacy Policy

We may update this Privacy Policy from time to time in our sole discretion. If we do, we will let you know by posting the updated Privacy Policy on our website and/or may also send other communications.

2. Personal Information We Collect

We collect personal information that you provide to us, personal information we obtain automatically when you use the Services, and personal information from third-party sources, as described below.

(a) Personal Information You Provide to Us Directly. We may collect personal information that you provide to us, including the following:

• Order or Preorder Data. When you place an order or a pre-order, we collect personal information, which may include, but is not limited to, your first name, last name, email, phone number, and address.
• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
• Vehicle Information. If you purchase one of our vehicles (each, a “Pebble Flow”), we may collect the following information:
• Identifying information necessary for the sales process, which may include, but is not limited to, your name, signature, address, social security number, vehicle purchase information related to your vehicle purchase agreement, title and registration documents
• Vehicle and feature usage information
• Vehicle operation and performance information
• Vehicle service and repair information
• Vehicle connectivity information
• Vehicle precise geolocation information primarily for diagnostic purposes, which may include, but is not limited to, the vehicle’s current and historical precise geolocation.
• Driver profile and preference information
• Safety and crash information
• Internal and external camera information
• Roadside service information
• Charging information
• Communications with Us. If you communicate with us or our service providers, or subscribe to updates from us, we may collect your name, contact information, and the contents of any messages you send.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we may offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other personal information you provide to us.

(b) Personal Information Collected Automatically. We may collect personal information automatically when you use the Services, including the following:

• Device Information. We may collect device information automatically when you use the Services, such as your Internet protocol (IP) address, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, operating system, Internet service provider, and information regarding the location of certain routers through which your device has connected to the Services.
• Usage Information. We may collect personal information automatically about your interactions with our Services, like the content you view, the searches you conduct, any content you post or share, and the dates and times of your visits.
• Personal Information from Cookies (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
• See the “Your Privacy Choices” section below for further details on your choices regarding these Technologies.

(c) Personal Information Collected from Third-Party Services. We may collect personal information from Third-Party Services (defined below) such as publicly or commercially available sources.

3. How We Use Personal Information

We use your personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

(a) Provide the Services. We use your personal information to fulfill our contract with you and provide the Services, including:

• Managing your information;
• Providing access to certain areas, functionalities, and features of the Services;
• Answering requests for support;
• Communicating with you;
• Sharing personal information with third parties as needed to provide the Services;
• Processing your financial information and other payment methods for products and Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

(b) Administrative Purposes. We use personal information for various administrative purposes, including:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in the Services;
• Combining personal information we have collected from third-party sources with the personal information we have collected from you;
• To train automated processes, such as our models and algorithms that we utilize to provide the Services;
• Improving, upgrading, or enhancing the Services, including the models and algorithms we utilize to provide the Services;
• Carrying out analytics;
• Developing new products and services;
• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors with the Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

(c) With Your Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

(d) Other Purposes. We also use your personal information for other purposes as requested by you or as permitted by applicable law.

(e) Marketing. We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

4. How We Disclose Personal Information

We disclose your personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

(a) Disclosures to Provide the Services. The categories of third parties with whom we may share your personal information are described below:

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of the Services. This includes service providers and vendors that provide us with analytics, marketing services, IT support, hosting, customer service, and related services.
• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each, a “Third-Party Service”).
• Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
• Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising.”
• Affiliates. We may share your personal information with our corporate affiliates.

(b) Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

(c) Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. Your Privacy Choices

The privacy choices you may have about your personal information are described below:

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).
• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in the “Contact Us” section below.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services, or contact us using the information set forth in “Contact Us” below.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
• The online advertising industry also provides websites from which you may opt out of receiving targeted ads from organizations that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.

6. International Transfers of Personal Information

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

7. Children’s Personal Information

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in the “Contact Us” section below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.

8. Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

9. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at: legal@pebblelife.com.