Ellipse Privacy Policy

 

This Privacy Policy (“Policy”) describes how Velo Labs Inc. (“Company” or “we” or “our” or “us”) treats information collected or provided in connection with an end user’s (“you” or “your” or “user”) use of the Ellipse mobile application (the “App”) in connection with one or more Ellipse bike locks (each, a “Lock”).  Please note that your use of the App constitutes your acceptance of this Policy as set forth below:

1. Collected Information.  The information collected during your use of the App includes the following:
    (a) Submitted Information.  As part of using the App, you may submit certain information to us.  For example, we collect your name, email, and mobile phone number when you register for an account on the App.  You may also submit to us through the App contact information for individuals who should be contacted in the event of an emergency, and other information such as your itinerary for a planned bike ride.  To the extent you decline to share certain information with us, we may not be able to provide some or all of the features and functionalities found on the App.  
    (b) Automatically Collected Information.  When you use the App, we gather certain non-personally identifiable information from you, and this information can be associated with your user account and information you submit to us.  This includes usage information, such as information on when, how often and for how long you use the App, as well as server log data such as your device type, operating system and IP address.
    (c) Analytics.  Third party analytics service providers may receive data regarding your usage of the App in order to provide analytics services to us. If you elect to opt-out of data collection by these service providers (to the extent available) and subsequently use the App through a different device or otherwise change your cookie or privacy settings on your device, you will need to opt-out again.
    (d) Social Networking Information.  We may allow you to create your App account by logging in through a social networking site such as Facebook (“Social Services”).  Integration with Social Services allows us to offer a more personalized experience to you when you use the App.  When you log into the App using your Social Service account, the Social Service will provide us with access to certain information that you have provided to that Social Service (such as your profile picture, interests, and connections), and we will use, store and disclose such information in accordance with this Policy.  Please remember that the manner in which Social Services use, store and disclose your information is governed by the terms and conditions and privacy policies of each Social Service, and not the Company.
    (e) Location Information.  With your permission, the Company will receive your precise physical location when you are using the App through your mobile device. The Company will also receive the precise physical location of your This location information will be used and disclosed as specified below.

     

    2. Use of Information.  We internally use the information we collect about you (which includes all information outlined in section 1 above) as follows:

      (a) Provision of Services.  We may use collected information for the purposes for which you provided the information including, for example, to create and maintain an App account for you or to respond to a question that you e-mail to us.  We also use the collected information as necessary to provide the features and functionality of the App to you.
      (b) Updates and Troubleshooting.  We may also use the collected information to contact you regarding updates or modifications to the Service, to help troubleshoot problems, or alert you to changes in our policies or agreements that may affect your use of the Service.
      (c) Personalized Content; Improvements.  We may use the collected information to personalize the content that you and others see based on personal characteristics, preferences and/or your location.  We may also analyze collected information relating to your use of the App in order to help us improve the App and develop and improve other products and services.
      (d) E-mail Information and Offers.  We may use the collected information to provide you with newsletters, promotional materials and offers via e-mail.  However, we will give you the ability to opt out of receiving such e-mails in accordance with applicable law.  We will not provide your personally identifiable information to third parties for their own marketing purposes without your consent.
      (e) Social Service Information.  If you use a Social Service to log-in to your App account, we may give you the ability to invite your Social Service connections to use the App and connect you to your Social Service connections on the App.
      (f) Location Information.  In addition to other uses of collected information outlined in this Section 2, we may use information regarding your physical location to provide features of the App to you which are dependent on knowing your location (whether statically or over time), such as features calculating distance traveled or speed.  
      (g) Combination.  We may combine personal information collected through the App with other information that we or third parties collect about you in other contexts, such as our communications with you via e-mail, phone, or your customer service records.
      3. Disclosure of Information.  We share and disclose the information we collect about you as follows:

      (a) Other Users.  The App may include various sharing features, such as the ability to share use of your bike with another user by providing an unlock code to that user.  Use of such sharing features will cause your information, including information regarding the precise physical location of your Lock, to be shared with other App users in accordance with the functionality of the applicable sharing features.  
      (b) Third Parties.  We may use contractors and third-party service providers to assist us in the operation of the App, including service providers who assist us with providing customer service and e-mail newsletter management.  Such third-party contractors or service providers may obtain access to the information you provide, including personally identifiable information.  In addition, the App may allow you to authorize us to provide other third parties with information about you in certain circumstances.  For example, if the App detects that your Lock may be involved in a crash, we may provide your location information to the emergency contacts you have designated in the App.  
      (c) Aggregated Information.  We may provide advertisers and other third parties with aggregated, non-personally identifiable information about our user base and its interests and usage patterns.  This may include making available or publishing aggregated, anonymous data regarding activity on this App, including without limitation in relation to location data.
      (d) Business Arrangements.  We may disclose non-personally identifiable information to third-party partners in furtherance of our business arrangements with them, including without limitation to jointly offer a product or service to you or create interoperability between our products and services and the products and services of such partners.
      (e) Legal Requirement.  We will use and disclose any information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights or property of Company, our users and/or third parties.
      (f) Advertising.  The App may include advertising served by third parties, which may be targeted to you based on your App usage and the information we collect through the App about you.  We may also partner with third party advertising companies in order to serve online advertising regarding our products and services to you after you use the App.  For more information on such advertising targeting practices, you may visit http:///www.aboutads.info.  For the ability to opt-out of such targeting practices, you can visit http://www.aboutads.info/choices/ and also download and use the apps referenced at http://www.aboutads.info/appchoices.   
      (g) Affiliates.  We may disclose this information to our affiliates for use as described in this Policy.
      4. Effective Date; Changes.  This Policy applies to all information collected by or provided to us on and after the Effective Date.  When we make any material changes to this Policy, we will change the Effective Date.  We will treat your continued use of the App following such change as your acceptance of the changes.  
      5. Third Parties.  The App may contain offers from third parties or links to third-party websites.  This Policy does not apply to information that you may provide to or that may be collected by third parties.  We encourage you to request such third parties to provide you with their applicable privacy policies and other terms and conditions before engaging with or making a purchase from such third parties.
      6. Viewing, Amending and Deleting Information.  You can log into your account and view, amend or delete your account information at any time.  Please note that while changes to your profile information are reflected promptly in active user databases, our servers may retain previously provided information.  Deletion of a mobile device application from your device or deletion of your App user account will not result in the deletion of location data from our servers. Note that the Company will maintain your e-mail address for use to send you our newsletter and/or promotional materials, provided that you can always opt-out of receiving such messages in accordance with instructions provided in such messages.
      7. Security.  The personally identifiable information we collect about you is stored in limited access servers.  We will maintain reasonable safeguards to protect the security of these servers and your personally identifiable information.  However, no security measures are 100% effective and we cannot guarantee the security of your personally identifiable information.  We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your personal information or usage information.
      8. Children Under 13.  We do not knowingly collect information from children under 13 and the App is not directed at persons under 13.  If you are a parent and believe your child under the age of 13 has used the App and provided personally identifiable information to us through the App, please contact us at the phone number and address provided in Section 11 of this Policy and we will work to delete that App account and any such personally identifiable information.
      9. Transfer as Corporate Asset.  In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Company, the information we possess, including personally identifiable information, shall be transferred as a corporate asset to the acquiring entity, provided that such entity will continue to handle such information in accordance with this Policy.
      10. Transfer to the U.S. or Other Countries.  The Company uses facilities in the United States.  Your information will be stored and processed in the United States or other countries where Company has facilities.  By using the App, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards.
      11. Contacting Us.  If you have any questions about this Policy, please contact us at  support@lattis.io or (415) 503-9744.

      Velo Labs Inc.

      Attn: Privacy Questions

      661 Natoma Street

      San Francisco, CA 94103

      USA