LAST UPDATE: October 18, 2022
This Policy describes the types of personal information we collect through the Site and how that personal information may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices at this Site. Please read this Policy carefully. By accessing and using this Site you are acknowledging that you understand and agree to the terms of this Policy.
1. COLLECTION AND USE OF PERSONAL INFORMATION
As you interact with AYRO, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about you or your AYRO products as further described below.
You may provide us with information about you or your AYRO products through a number of sources: AYRO websites, applications, product and related events, surveys, social media platforms, sweepstakes entries, and through our customer contact and service centers. We also receive information about you through AYRO product sales records provided by your dealer and we may obtain, with your consent, data obtained from your AYRO product.
The types of information that AYRO collects about you may include, but are not limited to:
- Contact information (such as name, address, city, state and ZIP code, age or date of birth, occupation, social security number, email address and telephone number)
- Payment information (such as your bank account information, credit card number, debit card number, bank or investor account, CVV code, expiration date, and payment history)
- Information related to your creditworthiness, assets, income, or liabilities
- Information about your AYRO product (such as license plate number, AYRO product identification number (VIN), make, model, model year, selling dealer, servicing dealer, date of purchase or lease, lease/financing term, service history, mileage, battery status, or charging history, electrical system function, gear status, and diagnostic trouble codes).
- Information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our products, services, apps, and websites (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information).
- Demographic information (such as gender, date of birth, marital status, and household composition)
- Marketing profile information (such as when you plan to purchase an AYRO product)
- Photographs and videos such as those that you may submit for case studies, contests, sweepstakes, and social sharing
- Relationships you have with AYRO in addition to the purchase and servicing of your AYRO product (such as through a rewards card, etc.)
- Incentive eligibility verification information (such as college name, branch of service, or credit union name for AYRO product purchase programs)
- Social Security Number (in limited circumstances AYRO may collect SSN, for example, if you win a sweepstakes or receive compensation that must be reported for government tax purposes)
- Investor Information (name, address, phone number, and email address)
- The kind of AYRO product you purchased
- The kind of service provided to you.
The information AYRO collects about you and your AYRO products may be used:
- To provide products and services and maintain customer relationships
- To improve the quality, safety, and security of our products and services
- To administer your account(s) and process your payments for products and services
- To operate our websites and applications, including online registration processes
- To facilitate and support AYRO dealer and supplier diversity programs and AYRO grant programs
- To autofill data fields on our websites to improve your online experience
- To develop new products and services, including connected, autonomous, and car-sharing products and services
- To provide customer and AYRO product support and service (such as recall information)
- For warranty administration and validation
- To provide information and product updates
- To evaluate AYRO product performance and safety
- For research, evaluation of use, and troubleshooting purposes
- To verify eligibility for AYRO product purchases or incentive programs
- For marketing, research, and analytics purposes
- To support the electronic signature and delivery process between you and your dealer
- To customize and improve communication content
- To comply with legal, regulator, or contractual requirements.
Communications with you in connection with these uses may be via mail, telephone, email, text message, social media, or other electronic messages, or via our websites and applications.
Personal Information You Provide
The privacy and security of the personal information that AYRO collects from you is a priority for AYRO. When you visit this Site you may be asked or choose to provide personal information that could reasonably be used to contact you or to identify you personally including: your name, address, telephone number, birth date, and email address. If you choose to purchase any products or use services offered on the Site, AYRO may ask you to provide your name, mailing address, telephone number and email address, as well as certain financial information (e.g., credit card number) for the purposes of credit checks, payment, and processing of any order.
- If you purchase products from the Site, we request that you provide your name, email address, billing and shipping address, credit card information, and any other information necessary to complete the transaction.
- You may choose to finance your purchase of products from AYRO pursuant to one of several financing options made available by third-party financial institutions. If you choose to finance your purchase of any products, you will be directed to one of the third-party financial institutions with which AYRO has a business relationship to make an application directly through that financial institution in connection with which the financial institution will ask you for the personal and financial information applicable to their own application process, the privacy and security of which will be governed by their privacy policies.
- If you choose to purchase extended service contracts or insurance services from AYRO, depending upon the choices you make in connection with your purchases of any products or services offered by AYRO or a third party with which AYRO does business, you will be asked for personal information including your name, mailing address, telephone number, email address and certain financial information such as a credit card number to be used for order processing and payment.
- You may choose to receive certain communications from AYRO via your email address upon interaction with the Site. From time-to-time AYRO may include surveys, information requests, or other features on the Site which ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by AYRO to allow you to participate in the particular feature being offered. AYRO may also retain any information you provide in order to send you information about AYRO’s products and services that may be of interest to you. AYRO will provide you with the opportunity to opt out of receiving such communications. We may use one or more service providers to administer these messages.
- From time-to-time, AYRO may offer sweepstakes, games, and other contests on the Site either by itself or in conjunction with a third-party partner. You may be asked to provide your name, mailing address and/or email address and date of birth, as well as certain other information on an optional basis (e.g., your gender, annual household income or other types of AYRO products that you have purchased), in order to participate in such sweepstakes or contest. This information may also be used by AYRO or its third-party partner to send you information about AYRO or such third-party partner’s products and services in the form of an email or regular mail communication or a telephone call. AYRO will provide you with an opportunity to opt out of receiving such communications from AYRO each time you receive such a communication. However, AYRO does not control, and shall not be responsible for, the privacy policies or practices of its third-party partners. If you no longer wish to receive such communications from any third-party partner of AYRO in sweepstakes or other contest that you may enter, you will need to contact such third-party partner directly.
You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to AYRO at this Site, you hereby consent to AYRO’s collection, use, and disclosure of such personal information.
We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.
Passive Information Collection and Use
As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We passively collect and use information in a variety of ways, including:
- Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier if you access this Site through a mobile device.
- You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. If you set your browser to reject cookies, part of the Site may not work for you.
- Pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.
- IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.
- Device Information: We may collect information about your Device, such as a unique device identifier.
- Do Not Track Requests: Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytics and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.
We permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we use advertising services provided by third-party ad partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt outs on those industry sites at https://thenai.org/ or https://youradchoices.com/.
Some additional Google Analytics features that AYRO uses are:
- Google Analytics Demographics and Interest Reporting – allows AYRO to see the age, gender and interests of website visitors to better understand them and personalize advertising.
- Google Display Network Impression Reporting – for banner ads.
- Remarketing through Google Analytics for Display Advertising – allows personalization of ads on our ad networks.
- User ID Extension for Google Analytics – allows AYRO to connect multiple devices, sessions and engagement data.
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt-Out page or by using the Google Analytics Opt-Out Browser add on.
Integrated Accounts and Social Media Information
We may implement applications or “widgets” from third-party providers (e.g., Facebook, Twitter, Instagram, LinkedIn, etc.) that allow interaction, integration or content sharing with third-party services. These widgets or applications may be visible on a page you visit on our Site or may require log-in through the third-party provider’s service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third-party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third-party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third-party policies to understand these practices.
How We Use and Disclose Information
We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a user account, (2) submit payment or credit card information, (3) submit your name and email address to receive product updates and marketing information, and (4) send email messages or feedback, or transmit other information by email. When you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), email address, mobile telephone numbers, and payment information.
We also use and transfer personal information from or about you:
- to respond to your inquiries and fulfill your requests, such as to send you documents you request or email;
- to send you information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information; and
- for our business purposes, such as marketing new products and services, data analysis, audits, developing new products or services, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our Site.
- to our service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, email services, marketing services, auditing services, and other services, in order to enable them to provide services;
- to verify your information, approve your registration as a user of the Site, authenticate payments and process orders, AYRO may disclose certain financial and other information you provide to AYRO to third parties offering products and services for sale on the Site, as well as to third parties that provide credit reporting, payment or order fulfillment services;
- You may submit information about new clubs related to AYRO products or stories and photographs for inclusion in AYRO’s online scrapbook. Any information you submit to AYRO for posting on the Site may be available to the public and may be collected and used by persons other than AYRO. You should not submit to AYRO any information that you do not want others to know. AYRO does not routinely monitor these areas of the Site, and you submit such information to AYRO for posting only at your own risk.
- to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
- when we otherwise have your consent. For example, if you sign up for programs offered by our partners, we may share certain information with the partner. This could include but is not limited to, enrollment information and the activation status of your device. Similarly, when you connect third-party devices and services to your AYRO Products, you are shown information about any proposed exchange of data. Your consent is required to allow these exchanges on your behalf and you can change your mind at any time.
We also use and disclose information we collect passively as described above, under “Passive Information Collection and Use,” and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.
Use of Information for Marketing Purposes
AYRO and our affiliates may send you regular promotional communications about our products, services, events, and promotions. Such promotional materials may use the “AYRO” brand and may be sent to you via different channels, such as email, phone, SMS text messages, postal mailings, and third-party social networks.
In order to provide you with the best-personalized experience, sometimes these communications may be tailored to your preferences (for example, as you indicate these to us, as we may have inferred from your Site visits, or based on the links you click in our emails). When required by applicable law, we will obtain your consent before starting these activities. In addition, you may withdraw your consent (opt out) at any time.
In particular, you can opt out from receiving marketing-related emails by following the unsubscribe instructions provided in each email. If you can sign-in to your AYRO account, you may be able to change your communication preferences under the relevant section of the Site. You can also contact us using the contact details provided below to opt out from receiving marketing-related communications.
Please note that even if you opt out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our products, order confirmations, notifications about your account activities, and other important notices.
2. GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION
Personal information will be collected, stored, processed and transmitted in accordance with AYRO’s established policies and applicable federal, state, local and foreign laws, rules and regulations.
The principles of AYRO with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by AYRO will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information collected by AYRO will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information collected by AYRO will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal data will be processed in a manner that ensures appropriate security of the personal data.
If AYRO engages in the processing of personal information for purposes other than those specified in this Policy, AYRO will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
3. THIRD-PARTY SITES AND SERVICES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.
Third parties may offer products and services on the Site and collect information about you by requesting certain information necessary to provide a particular product or service (including, for example, insurance coverage for your AYRO products or reports of insurance claims). AYRO may also obtain certain information about its users from third-party customer research groups (e.g., demographic information) which AYRO uses to learn more about its customers. AYRO does not control the policies and practices of third parties in relation to the use and disclosure of any information about users collected by third parties on the Site or in market research programs conducted by such third parties and any use or disclosure of such information by third parties is not governed by this Policy.
4. CHOICES AND ACCESS
We give you choices regarding our use and disclosure of your personal information. AYRO provides you with the opportunity to receive information by email, regular mail or telephone calls from AYRO, or third parties which may be of interest to you, including information relating to new products and services offered on the Site by AYRO, or other third parties. If you do not want to receive any information by email, regular mail or telephone calls, you may opt out of further communications provided by AYRO at any time by: (i) emailing email@example.com; or (ii) writing to AYRO, Attn: Marketing at 900 E. Old Settlers Boulevard, Suite 100, Round Rock, TX 78664. Note that AYRO can only comply with requests relating to email, regular mail, or telephone communications provided by AYRO. If you no longer wish to receive further information by email, regular mail, or telephone from any third party, you will need to contact such third party directly to opt out of further communications being provided to you. We will seek to comply with your request(s) as soon as reasonably practicable.
If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us.
It is your responsibility to provide AYRO with accurate personal information. Except as otherwise set forth in this Policy, AYRO shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, AYRO shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.
6. YOUR RIGHTS OVER YOUR INFORMATION
You can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. You can also ask for it to be erased and you can ask us to give you a copy of the information. You can also ask us to stop using your information, stop sharing any of your information with third parties for behavioral advertising purposes, and limit how we use your information.
Your California Privacy Rights
California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:
- information regarding their personal data AYRO has collected (the categories of personal data collected, the source of such data, and how such data has been used);
- a description of whether AYRO has disclosed their personal data to third parties, and if so what categories of data have been disclosed, and to what categories of third parties;
- a copy of their personal data collected by AYRO in the past 12 months; and
- that their personal data be deleted.
7. RETENTION PERIOD
We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.
AYRO has implemented security measures designed to protect personal information provided by you against unauthorized access and use. AYRO also uses commercially reasonable efforts to establish secure connections with your web browser for any transactions conducted online using a credit card or other financial information you may provide to AYRO. Please be aware, however, that no-data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the CONTACTING US section below.
9. USE OF SITE BY MINORS
We do not intentionally collect information from individuals under the age of 13. The Site is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through this Site.
10. COMPLIANCE WITH LOCAL LAWS
11. EUROPEAN ECONOMIC AREA (EEA) RESIDENTS
If you reside in the European Economic Area (EEA) you may have the following additional rights under the GDPR:
- the right to access (i.e., the right to be provided with a copy of your personal information);
- the right to rectification (i.e., the right to require us to correct any mistakes in your personal information);
- the right to be forgotten (i.e., the right to require us to delete your personal information – in certain situations);
- the right to restriction of processing (i.e., the right to require us to restrict processing of your personal information – in certain circumstances, e.g., if you contest the accuracy of the data);
- the right to data portability (i.e., the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations);
- the right to object (e.g., the right to object to your personal information being used for direct marketing, and in certain other situations, to object to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests);
- the right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent – without affecting the lawfulness of processing based on consent before its withdrawal);
- the right to information regarding consent (i.e., to obtain information about the possibility or providing or denying your consent and the consequences of such consent or denial of consent); and
- the right not to be subject to automated individual decision-making (i.e., the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you).
We will not discriminate against you if you choose to exercise any of these rights. You can exercise your rights under the GDPR by contacting us as follows:
By mail: AYRO, Inc.
900 E. Old Settlers Boulevard, Suite 100
Round Rock, TX 78664
By email: firstname.lastname@example.org (please use “GDPR” in the subject line)
The GDPR also gives individuals in the EEA the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
We may change this Policy. Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. Your use of this Site following these changes means that you accept the revised Policy.
AYRO will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented, and accessible. If you believe that your personal information has been processed or disclosed in violation of this Policy, AYRO encourages you to raise any concerns using the contact information provided in this Policy. AYRO will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.
14. CONTACTING US
If you have any questions about this Policy, please contact us using the contact information below.
By mail: AYRO, Inc.
900 E. Old Settlers Boulevard, Suite 100
Round Rock, TX 78664
By email: email@example.com
By phone: 512.994.4917 (Monday to Friday, 9:00 am – 5:00 pm CST)