Privacy Notice

Velopower, Inc.

Last updated March 15, 2022

Velotric Values Your Privacy

At Velotric and our family of companies, we take your personal privacy seriously and recognize that you expect privacy and security for all your personal information. We understand the need to protect and safeguard sensitive information about you, and we maintain strict standards and procedures designed to prevent misuse of your information.

We encourage you to read this privacy notice (the “Privacy Notice”) carefully to understand the information we collect and what we do with it.

Velopower, Inc. and its affiliates and subsidiaries (collectively “Velotric,” “us,” “our,” or “we”) are responsible for your information, and this Privacy Notice constitutes an agreement between you and Velotric. When you access and use our United States website (the “Site”) you acknowledge that you have read this Privacy Notice, understood it, and that you do not object to our processing activities.

This Privacy Notice describes how Velotric collects, protects, uses, and discloses information and data collected and created in the course of your access to and use of the Velotric Site, products, and services, as well as your interactions with Velotric via telephone, through mail or at our physical locations. It also explains what your rights are, which may differ depending on where you are located.

At certain points in your interaction with the Site, certain third party service providers engaged by Velotric (“Service Providers”) may be responsible for collecting information pertaining to you, your interactions with the Site, your preferences, your settings, or other general information. At other points you will need to submit various pieces of information to a Service Provider in order to take advantage of services offered by Velotric, including but not limited to making a purchase, financing a purchase, applying for employment, or entering a contest. This Privacy Notice will identify instances where your information is being collected, transmitted or stored by a Service Provider, and in such instances, your information will become subject to terms and conditions and a privacy policy operated by that Service Provider. Please see the “Access to Your Information” section below for more information about our Service Providers.

Consent

By accessing this Site, registering with Velotric, creating a user profile on our Site, or submitting information to Velotric, you consent to this Privacy Notice and the collection and use of information as described below. We will take steps to notify you and confirm that you agree at different stages of collecting information. If you do not agree with our policies and practices, you may not be able to access or benefit from certain portions of this Site.

Scope

Please be advised that this Privacy Notice applies to information that we collect:

• when you visit the Site.
• when you submit your information to us on the Site.
• when you create or use a user profile on the Site.
• when we communicate with you through email and other communications.
• through Service Providers that we work with to provide our services.
• by any other means over the course of your use of our services.

How We Collect Your Information

The only personal information we collect about you is either provided by you voluntarily or as described below under “Information Collected from Your Use of the Site.” Velotric does not collect biometrics or sensitive information relating to health, race, gender, or other special category data.

Information We Collect. If you access or submit an inquiry through our Sites, set up an account, subscribe to a service, register to receive marketing materials, participate in contests, sweepstakes or promotions, upload a photo, or receive other services, we may ask you to provide certain personal information such as your name, email address, phone number, location, and zip code, and other personally identifiable information (“Personal Information”).

We take reasonable steps to make sure that we only ask for the information we need for the purposes listed in “How We Use Your Information”. We also take steps to ensure that your contact information is accurate, complete, current, and otherwise reliable. We will only collect and process your Personal Information if we

• first obtain your consent;
• have a legitimate interest in collecting and processing the data for our direct marketing purposes; or where required or permitted by law.

We may periodically supplement the Personal Information we collect from you with personal or non-personal information about you or another person obtained from companies with whom we have marketing or other business relationships and other third-party sources. Any aggregate information that is linked or linkable to your Personal Information will be treated by us as Personal Information under this Privacy Notice.

Information Collected Automatically. Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser including your IP address, "cookie" information, potential email information, and the page you requested.

"Cookies" are identifiers we transfer to your computer through your browser that allow us to recognize your browser and tell us how and when pages in our site are visited and by how many people. You may be able to change the preferences on your browser to prevent or limit your computer's acceptance of cookies, but this may prevent you from taking advantage of our Website's best features. Our advertising partners may also transmit cookies to your computer, when you click on ads that appear on our site. This Privacy Policy does not cover the use of cookies by any advertisers.

Children Under Age 16. Velotric products and services are designed for adults, not children. As such, this Site is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Site. If you are under 16, do not use or provide any information on this Site or on or through any of its features/register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

Payment Information. Velotric does not collect or maintain any payment information. When you place an order for an ebike or other products all payments are processed through our third party payment processor, which as of the date of this Privacy Notice, is Shopify Inc. When you provide payment information on this Site, it will be submitted through Shopify’s payment portal. All payment information and transactions are subject to Shopify’s privacy policy and terms of use. If there is any trouble processing an order, we will use your contact information to contact you to alleviate such trouble. We do not share your personal and financial information with any third parties, except as specified in this Privacy Notice.

Velotric also works with Service Providers to provide convenient financing options for the purchase of our ebikes. When you choose to finance an ebike purchase you will be redirected to a Service Providers’ site or portal in order to submit the necessary information to obtain financing. Velotric has no right or ability to alter a decision regarding financing, and does not have access to any information related to financing, such as your credit score. All requirements for financing options are determined by the applicable Service Provider.

Information Collected from Your Use of the Site. We or a Service Provider may use Site analytics tools or other licensed technologies from third parties to collect information about you from your use of this Site. This information may be combined with other information that you choose to submit to us. This information may also be merged into aggregate information about site visitors and traffic. We also may use third-party Service Providers’ analytics tools to distinguish and analyze user behavior. Here are the details of how we do this and the reasons why:

• Log Files. We or a Service Provider may collect anonymous and technical information from your computer, including your Internet Protocol address, data about your computer or other device, the type of browser or operating system your device uses, the programs, services, and version of software you use, and the address of any linking site, when you request a web page while visiting the Site. We use this information for statistical purposes, to ensure that our pages on our Site will appear and function appropriately on your computer, to determine which site referred you to our Site, and to personalize your access to our Site or conduct our own analyses and research to improve our programs, products, services, and content. We use Service Providers to collect and analyze information, and we reserve the right to change which Service Providers collect and analyze said information in the future. If you do not agree with Velotric or its Service Providers collecting and using your anonymous and technical information as described in this paragraph, your choice is discontinue use of the Site or contact us as described under “Controlling Your Personal Information.”
• Cookies. Cookies are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. Velotric and our Service Providers use cookies to track use of our Sites and online services. Cookies may also be used to monitor traffic, improve the Sites, make the Sites easier and/or more relevant for your use, and improve the performance of our advertising on other Sites. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you are sent a cookie. However, certain features of our Sites or other services may not work if you delete or disable cookies. For more information on cookies and how to disable them on your computer please visit: https://www.consumer.ftc.gov/articles/0042-online-tracking.

Generally-speaking, we use 1st and 3rd-party session and persistent cookies. The cookies set by us are called “1st-party cookies” and the cookies set by our Service Providers are called “3rd-party cookies.” Session cookies are temporary cookies that remain on your device until you close your web browser. Many session cookies are essential to make our Site work correctly, as they typically enable you to move around our Site and use our features. Persistent cookies remain on your device after you close your browser or until you manually delete it (for the former, the amount of time the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings). Persistent cookies help us recognize you as an existing user of our Site, so it’s easier and convenient to return to our Site or interact with our services without signing in again. In addition, persistent cookies also help us recognize you when you view a resource belonging to our Site from another website or app (such as an advertisement) and help us record information about your web browsing habits during the lifetime of the persistent cookie.

• Example of cookies we use:
• Strictly Necessary Cookies: these cookies are strictly necessary for our Site to function properly and ensure our Services are accessible to you (e.g., log-in functionality, load balancing, navigation, filling in forms). The Site cannot function properly without these cookies.
• Preference Cookies: enable our Site to provide enhanced features or settings based on your previous visits and selections, such as language preferences, remembering log-in details, remember searches and filter settings, and other conveniences.
• Statistic Cookies: Statistic cookies enable us to understand how visitors interact with our Site by collecting and reporting information anonymously.
• Social Media Cookies: These cookies are used to allow you to share or like our pages and content through third-party social media websites.
• Marketing Cookies: Marketing cookies are used to track visitors across our Site. The intention is to display ads that are relevant and engaging for the individual user.
• Web Beacons. Some pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us or a Service Provider, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
• Social Networking. If you access any of our Sites from a social networking site (e.g., Facebook or Twitter), or if you otherwise agree to associate your account with us through a social networking site, we may also receive Personal Information about you from such social networking site. Our receipt of your Personal Information via a social networking site is governed by the terms of use and privacy policy of the social networking site. For marketing purposes only, we may retain this information with the information we collect from you directly.

Information We Collect Offline. We collect information when you visit a Velotric retail showroom to make a purchase/payment, fill out a registration agreement, take a tour, test ride an ebike or submit an inquiry at such retail showroom. This may include:

• Your personal contact information, such as your name, address, email address, and phone number.
• Your sensitive personal information, such as your emergency contact and release information, driver’s license number, and employer information.
• Your financial information as needed to process a payment.
• Video recordings of your entrance to and exit from our retail showroom.
• Information collected offline by third parties in order to facilitate services, such as credit card, banking, or other payment-related information.

How We Use Your Information

We use your Personal Information for the purposes described at the time of collection and to manage the internal operations and security of our Site consistent with this Privacy Notice. We may also use your Personal Information for analytical and direct marketing purposes, such as:

• Sending you periodic email and newsletter communications;
• Confirming, sending, and tracking your order, subscription, or registration;
• Communicating with you about your order, subscription, or registration;
• Responding to customer inquiries;
• Sending you surveys and other communications;
• Analyzing preferences, trends, and statistics;
• Informing you of our new products, services, and offers; and
• Providing you with other information from and about VELOTRIC.

We will only contact you in ways compatible with your communications choices. However, even if you have opted-out of receiving marketing communications from us, we may need to contact you to address questions or issues specific to the services you have requested.

Other Ways We Might Use Your Information. In addition to the specific uses and purposes described above, we might use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Site and its contents to you.
• To provide you with information, products, or services that you request from us.
• To allow you to participate in interactive features on our Site or to notify you about changes to our Site or any products or services we offer or provide though it.
• To provide you with other information from and about VELOTRIC or a business or organization with which we are associated.
• To protect your privacy and enforce this Privacy Notice;
• If we believe it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Velotric, or to others.
• To fulfill any other purpose for which you provide your information.
• To analyze preferences, trends, and statistics.
• To protect our rights and property.
• To comply with a law, regulation, legal process or court order.
• For any other purpose with your consent.

Access To Your Information

We do not share, sell, rent, or transfer your personal information other than as described in this Privacy Notice. Your information will be accessible to Velotric employees who are trained to comply with our internal policies for handling Personal Information and assisting you in exercising your legal rights over your personal information.

Service Providers may also have access to your personal information while they are carrying out their services. However, we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.

We allow some Service Providers to assist us with behavioral advertising by collecting and analyzing certain information when you visit our Sites (e.g., click stream information, browser type, time and date, subject clicked or scrolled over). These Service Providers typically use a cookie or third party web beacon to collect this information. You can find more information about opting out of behavioral advertising by visiting:

 www.networkadvertising.org/choices or www.aboutads.info/choices/

Disclosure of Your Information. We will only disclose, sell, or share your Personal Information or other information:

• To Service Providers. We may disclose, sell or share Personal Information to one or more Service Providers with which we have contracted to provide services to us or to offer the services you have requested from us. We may also disclose Personal Information to one or more Service Providers who are interested in providing services or products to you. We do not control how these Service Providers use or disclose your Personal Information.
• To Affiliated Businesses. We may disclose, sell or share Personal Information to one or more third parties that have contracted with us (“Affiliated Businesses”) specifically in order to provide you with the services you have requested. The Affiliated Businesses may contact you directly by email, telephone, regular mail, in person visits or other means. We do not control how these Affiliated Businesses use or disclose your Personal Information.
• To Affiliates. We may disclose some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under common control with us, in which case this Privacy Notice will apply to the same extent it applies to Velotric.
• For Our Internal Analyses and Operations. We may disclose Personal Information to third party vendors for our own internal statistical, design or operational purposes, such as to estimate our audience size, measure aggregate traffic patterns, and understand demographic trends among our users. The use and disclosure of your Personal Information by these third parties is restricted to performance of such tasks and subject to confidentiality.
• For Legal and Other Compliance. We may disclose Personal Information when we believe it is appropriate to:

(a) comply with the law,

(b) enforce or apply this Privacy Notice or our other policies or agreements, protect our or our users’ rights, property or safety,

(c) protect our users from fraudulent, abusive or unlawful use of, our Site, or

(d) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

• As Part of Business Transfers. We may disclose Personal Information as part of any merger, acquisition, debt financing, sale of company assets or other business transaction.
• As Aggregated Information. We may share or sell aggregated, anonymous information to our advertisers, business partners, and other third parties that includes or is based on information about you. We take technical and organizational measures to anonymize your information and combine it with other users’ information so that it does not directly identify you. This information may be used by those third parties for marketing, promotional or statistical purposes. We do not limit the third parties’ use of the aggregated information.

Security

It is Velotric’s policy to treat your Personal Information with complete confidentiality. We employ commercially appropriate and reasonable safeguards both online and offline to maintain the security, confidentiality, and integrity of information that we collect about you. We maintain physical, electronic and procedural security measures to safeguard your non-public personal information. We update and test our technology to improve the protection of our information about you and to assure the integrity of that information.

We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and special training programs. We take appropriate disciplinary measures to enforce employee privacy practices.

Please note, however, that no transmission of data over the internet is 100% secure. While we employ reasonable measures to protect your Personal Information, we cannot guarantee that unauthorized third parties will not defeat those measures or use nonpublic Personal Information for improper purposes. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or for actions of third parties. The safety and security of your information also depends on you, and you are responsible for keeping your password confidential. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place. All Internet users should take care with how they handle and disclose their personal information.

Please refer to the Federal Trade Commission’s Site at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to help protect yourself against identity theft.

Third Party Sites & Advertising

This Privacy Notice applies only to information collected by Velotric. We may provide links to third party sites from our Sites as a service to our users, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third party sites. When you click on links that take you to external sites, you will be subject to their privacy policies and practices and not ours. We encourage you to review and understand the privacy policies of such sites before providing them with any information.

Third party advertisers or ad networks may use cookies or other technologies on our Sites for various purposes, including measuring the effectiveness of their ads and analyzing and personalizing ads or other content delivered to you. We have no ability to control the privacy and data collection, use, and disclosure practices of such third parties’ sites and the privacy policies of such sites may differ from the Sites. Therefore, we encourage you to review and understand the privacy policies of such sites before providing them with any information.

Controlling Your Personal Information

Opting Out of Communications. You can modify or limit the communications we send to you by contacting us directly by email at help@velotricbike.com. Please be sure to include your full name, email address, mailing address, and specifically what information you do not want to receive. If you like, you may use one of the following statements in your message to us:

• I prefer not to receive email advertisements, such as updates regarding products and services, special promotions, or upcoming events.
• I prefer not to receive direct mail advertisements, such as periodic catalogs and mailings regarding products and services, special promotions, or upcoming events.

Your rights. Depending on applicable law, you have the right to submit a complaint or object to our collection and use of your information at any time, or to require us to review, transmit, change, or delete your information that we have collected and retained. We will fulfill your request to exercise any of these rights within the applicable time period subscribed by such laws. You can exercise these rights, express concerns, or obtain additional information about the use of your personal information by contacting us as outlined below.

Retention of your Personal Information. We will only retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and to the extent permitted or required by law.

California Privacy Rights. VELOTRIC adopted this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and applies solely to residents of the State of California (“California Consumers”). Without limiting the foregoing, this section provides California Consumers with the disclosures and notices required under the CCPA. Certain exceptions and limitations may apply to a California Consumer’s rights and Velotric’s obligations under the CCPA.

• No Sale of Personal Information. Velotric has not sold any Personal Information in the preceding twelve (12) months. If Velotric ever chooses to sell Personal Information, you would have the right to opt out of the sale of your Personal Information.
• Right to Disclosure. California Consumers have the right to request that we disclose certain information about our collection and use of your Personal Information over the past 12 months, such as:
• the categories of Personal Information we have collected;
• the categories of sources for the Personal Information we have collected;
• our business or commercial purpose for collecting or selling that Personal Information;
• the categories of third parties with whom we share that Personal Information;
• if we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing

1. (i) sales, identifying the Personal Information categories that each category of recipient purchased; and
2. (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Please note that under the CCPA, Velotric is only required to respond to two requests for disclosure, access or deletion over a twelve (12) month period.

• Verification. We cannot respond to your request or provide you with Personal Information unless we can verify your identity and your authority to make the request and confirm that the Personal Information relates to you. A verifiable California Consumer privacy request must:
• provide sufficient information that allows us to reasonably verify you are the person about whom we have collected Personal Information or an authorized representative;
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• Authorized Agent. You may make a verifiable consumer request on behalf of your minor child. Otherwise, only you, or a person you have designated in writing as your authorized agent or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (“Authorized Agent”) may make a verifiable consumer request related to your Personal Information. If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.
• Velotric’s Response. We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.

We do not charge a fee to process or respond to your verifiable consumer privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

• Other California Privacy Rights. California Civil Code sections 1798.83-1798.84 (the Shine the Light Act) entitles California residents to request disclosure regarding Personal Information sharing with affiliates and/or third parties for marketing purposes. If you are a California resident and you would like to request a copy of this notice, please contact us at help@velotricbike.com with the subject line “Request for California Privacy Information.”

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Do Not Track Signals. At this time, Velotric does not respond to Do Not Track browser settings or signals. In addition, Velotric may use other technology that is standard to the internet to track visitors to Velotric Sites. For information about Do Not Track, visit www.allaboutdnt.org.

Unauthorized Use. If you become aware of any unauthorized submission of information to Velotric, including children’s information, please inform us by contacting us at the contact information listed below so that we may delete it.

Terms

Terms & Conditions. The Terms of Use, Purchase Terms, and Warranty of this Site and the Velotric services govern all matters not set forth in this Privacy Notice.

Changes to this Privacy Notice. We may occasionally make changes to this notice to ensure its accuracy. If we make changes, the revised notice will be posted online and the date of the newest version will be listed. Please check back frequently, especially before you provide us with personal information, to determine the current scope of the notice.

Contact Information

If you have any further questions about our collection and use of your Personal Information, or if you wish to exercise any of your rights over your personal information or if you have any questions about this privacy notice, please contact us at help@velotricbike.com.