Privacy Policy

(Applicable to RevZilla, Cycle Gear, J&P Cycles, and REVER)

Effective Date: June 1, 2021

This Privacy Policy (the “Privacy Policy”) describes how Comoto Holdings, LLC (“Comoto”) and our affiliated entities collect, use, and share your personal data and information (collectively “personal information”). This Privacy Policy applies to Comoto, and to Cycle Gear, RevZilla, J&P Cycles, and REVER (collectively, the “Companies” or “we”, “our,” or “us”).

This Privacy Policy applies to your use of the Companies’ websites, our mobile applications, and all other digital and online services provided by the Companies, as well as information collected offline (collectively, the “Services”), and describes our privacy practices relating to the Services.

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Your Privacy Is Important to Us

We value your privacy, and are committed to protecting it. Generally, we need to collect, process, and use your personal information to operate our organization and provide you with certain Services as discussed in more detail in this Privacy Policy. Before accessing, using, or interacting with the Services you should carefully review the terms and conditions of this Privacy Policy. Your use of the Services is governed by this Privacy Policy and our Terms of Use.

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Personal Information We Collect About You

Personal information is information that can be used to identify you (whether alone or in combination with other information), and may include:

Name
Title
Email Address
Postal Address (including billing and shipping address)
Geolocation Information
Telephone Number
Date of Birth
Vehicle and Equipment Information
Riding Style
Gender
Physical Traits (such as measurements and sizes for apparel, shoes, helmets, etc.)
Reward Points Balance
Payment Information (including credit and debit card information)
Order History and Saved Items;
Unique Personal Identifier or Customer Number;
Online Moniker or Alias
Social Media and Third-Party Login Information (first name, last name, and profile photos for all social media or third-party logins, as well as gender and birthdate for those logging in using Facebook);
IP Addresses;
Unique Identifiers (such as a universally unique identifier (“UUID”) that remains on your device persistently to help you log in faster and enhance site navigation);
Log file Information (such as your IP address, browser type, access times, domain names, operating system, referring web page(s), pages visited, geographic location, your mobile carrier, device information (including device and application IDs, and screen size), search terms, and cookie information);
Information From Cookies, Web Beacons, HTTP Referrers, and Other Tracking Technologies (IP address, location, age, gender, pages you view on our website, duration of your visit, pages you view immediately before and after you access our website, search terms you enter on our website, and information about your browser type, language and operating system. For our full Cookies Policy, please click here); and
Website Analytics Information.

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Additional information is collected about users of REVER’s apps and products. For more details, please click here.‍

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How We Collect Your Personal Information

The Companies collect your personal information through various means, including when you directly provide information to us and when we automatically collect information about you through your use of the Services. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use certain features of the Services.

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Information You Provide to Us

We may collect personal information you provide directly to us, including:

When you, or someone on your behalf, provides information to us to:
Purchase goods or services from us;
Register or maintain an account with us;
Find the best-fitting products (e.g., by providing information about your physical traits or riding style);
Register the products you purchase from us or make warranty claims for those products;
Post comments to our online communities;
Apply for employment with us;
Obtain technical support;
Participate in our customer loyalty programs;
Participate in a survey, marketing promotion, sweepstakes or contest; or
Connect with us via social media, or respond to one of our usage requests.
Through business partners, resellers and suppliers;
Our mail, email, text, phone, and fax communications with you.

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Information We Collect Automatically

In addition to information you provide to us, the Companies and our agents, vendors, and consultants (collectively “Service Providers”), as well as other third parties may collect information automatically about our Services and how you use them. Examples of the types of personal information that may be collected automatically when using the Services include:

IP address
Browser type and language, operating system, access time, duration of visit, and referring website address
The pages you view within our websites and other actions you take while visiting us
The pages you view immediately before and after you access our Services
Information related to whether you’ve opened an email or clicked on a link contained in an email we sent
Information from a referring source (an advertising site, a blog, a social media site, etc.)
Information from surveys and promotions
Information from content you post or share publically on discussion forums or other social media pages (including the content you post, your name, and a link to your profile) may be shared across our Services and in other public or private areas of the Internet
Usage data collected when you download or use our apps, including the REVER app

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Cookies and Tracking Technologies:

We and our Service Providers may use cookies or other tracking technologies to collect and store information about interactions with the Services, including information about your browsing and purchasing behavior. Cookies are small files that a website or its service provider transfers to a computer’s hard drive through a web browser that enable the site’s or service provider’s systems to recognize the user’s browser and capture and remember certain information. In general, we and our service providers use cookies and other tracking technologies (such as web beacons, tracking pixels, and HTTP referrers) to optimize the functionality of our Services, to help us understand how the Services are used, and to provide users with interest-based content or advertising based on their browsing activities.

If you would like to opt-out of cookies, visit www.aboutcookies.org or www.allaboutcookies.org for further information. These sites also provide details on how to set your browser not to accept cookies and how to remove cookies from your browser. In a few cases, some of the features of our Services may not function if you remove or delete Cookies. More information on how we use cookies can be found in our Cookies Policy.

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Google Analytics

Our Services use Google Analytics to help us analyze user activity. Google Analytics uses cookies to generate information about your use of the Services, including your IP address, for the purpose of evaluating use of the Services, compiling reports on website activity, and providing other information related to user activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process information on Google’s behalf. Google will not associate your IP address with other data held by Google. Data collected by Google is subject to its privacy policy. If you want to know more about how data is collected, used and shared by Google, please review the Google Privacy Policy.

You may prevent Google Analytics from collecting your information by disabling cookies on your browser as noted above or you may opt-out of Google’s use of cookies by visiting the Google Analytics Opt-out Page.

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Google AdWords

Google AdWords is a remarketing service provided by Google Inc. The Companies use Google AdWords to deliver and track online ads. AdWords’ tools, such as cookies, enable us to display ads on sites across the Internet based upon your visits to our websites. You can personalize the ads you receive, opt-out of ads from other advertising networks or opt-out of ads from Google by visiting the Google Ads Settings page. For more information on Google’s privacy practices, please visit Google’s Privacy Policy Privacy.

Hotjar

We use Hotjar to help us understand and analyze how visitors use the Services, and to improve the Services. Hotjar may collect the following types of information from users of our website:

Device IP address
Device screen size
Device type (unique device identifiers)
Browser information, geographic location (country only)
Preferred language used to display our website

Hotjar stores the above information in a pseudonymized format. Hotjar does not use this information to identify individual users, or match or link the information with other information about users. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For more information regarding Hotjar’s collection and use of information, please visit Hotjar’s privacy policy. You can opt-out of Hotjar’s use of tracking cookies and collection of information related to your use of our Services by following this opt-out link.

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How We Use Your Personal Information

We may use your information in various ways to serve you better as a customer and provide an improved online experience. The table provided below outlines how and why we use your personal information:

TYPE OF PERSONAL INFORMATION OR DATA	PURPOSE(S) FOR WHICH WE USE THIS INFORMATION
Name and Contact Information (including your title, email address, postal address, phone number, etc.)	To fulfill orders and deliver your purchases
	To handle returns
	To send you order updates through email and text messages
	To facilitate your participation in our loyalty programs
	To send you information on products, services, and articles with your permission
	To detect and prevent fraud against you and/or the Companies
	To show you relevant ads while you are browsing the web or using social media
	To contact you in order to obtain information about your product or service preferences and how the Companies can improve their businesses
Date of Birth	To detect and prevent fraud against you and/or the Companies
	To facilitate your participation in our loyalty programs
Riding Style, Vehicle Type, Gender, and Physical Traits	To help Customer Service find the right gear for you
	To provide you with appropriate products, services, recommendations, and updates
	To help you find relevant products and services more quickly
	To facilitate your participation in our loyalty programs
Payment Information (including credit and debit card information)	To fulfill orders and provide refunds
	To detect and prevent fraud against you and/or the Companies
Rewards Points Balance	To facilitate your participation in our loyalty programs
Order History and Saved Items	To provide you with appropriate products, services, recommendations, and updates
	To help you find relevant products and services more quickly
	To provide customer service and support
	To handle returns
	To facilitate your participation in our loyalty programs
Online Chat Information	To provide you with appropriate products, services, recommendations, and updates
	To help you find relevant products and services more quickly
	To provide customer service and support
Contact History	To provide customer service and support
	To provide training to our staff
Device and Usage Information (such as geolocation data, IP addresses, device type, screen size, preferred language, unique identifiers, online monikers, and log files)	To make it easier for you to log into our websites and apps
	To provide you with appropriate products, services, recommendations, and updates
	To help you find relevant products and services more quickly
	To show you relevant ads while you are browsing the web or using social media
	To improve our websites, set default options, and provide you with a better shopping experience
	To facilitate your participation in our loyalty programs
	To protect the security of our websites
	To detect and prevent fraud against you and/or the Companies
Communications You Send Us By Mail, Email, Text, Phone, or Fax	To provide you with appropriate products, services, recommendations, and updates
	To learn how the Companies can improve their businesses
	To provide customer service and support
	To handle returns
	To facilitate your participation in our loyalty programs
	To provide training to our staff
Responses to Surveys, Competitions, Promotions, and Sweepstakes	To learn how the Companies can improve their businesses
	To provide you with opportunities to win awesome stuff
	To facilitate your participation in our loyalty programs
	To learn how the Companies can improve their businesses
Sponsorship Information (including information submitted for the Cycle Gear Racing program)	To evaluate you for sponsorship
Product Registration and Recall Information	To communicate with you regarding recalls for registered products
Event Registrations	To communicate with you about our events
	To send you information on products, services, and articles with your permission
	To facilitate your participation in our loyalty programs
	To show you relevant ads while you are browsing the web or using social media
	To contact you in order to obtain information about your product or service preferences and how the Companies can improve their businesses
Technical Support Information	To assist you with your request for tech support
	To improve our Services and better handle future support requests from you or other users
Social Media and Third-Party Login Information	To register you for an account with us
	To make it easier for you to log into our websites and apps
	To help you connect and share content with your friends and followers
	To provide you with appropriate products, services, recommendations, and updates
	To help you find relevant products and services more quickly
	To facilitate your participation in our loyalty programs
	To send you information on products, services, and articles with your permission
Cookies, Web Beacons, HTTP Referrers, and Other Tracking Technologies	To make it easier for you to log into our websites
	To provide you with appropriate products, services, recommendations, and updates
	To help you find relevant products and services more quickly
	To facilitate your participation in our loyalty programs
	To show you relevant ads while you are browsing the web or using social media
	To improve our websites and apps, set default options, and provide you with a better shopping experience
	To protect the security of our websites
	To detect and prevent fraud against you and/or the Companies
Telephone Recordings	To improve the quality of our customer service
	For training purposes
Website Analytics Information	To provide you with appropriate products, services, recommendations, and updates
	To help you find relevant products and services more quickly
	To facilitate your participation in our loyalty programs
	To show you relevant ads while you are browsing the web or using social media
	To improve our website, set default options, and provide you with a better shopping experience
	To protect the security of our websites
	To detect and prevent fraud against you and/or the Companies
Employment Applications	Please see our Employment Application Policy
Publicly Available Information	Any purpose

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Aggregated/Deidentified Information

We may aggregate and/or de-identify your Personal Information so that it can no longer be linked to you. We may use and share aggregated/de-identified information for any purpose at our sole discretion.

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Additional Information for REVER Members

In addition to the uses described above, REVER’s apps and products process personal information in ways that differ from the other Comoto brands. For more details, please click here.

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How We Share Your Personal Information

The following describes our policies with respect to the sharing of your personal information with others.

When we share your personal information, we require that our contractors, business partners, and Service Providers use the information only in accordance with the terms of this Privacy Policy.

We may share your personal information as follows:

Within our group of companies including our affiliates, subsidiaries, locations, brands, etc.
With our Service Providers in connection with their delivery of services to the Companies. Our Service Providers are prohibited from using your Personal Information for any purpose other than the delivery of services to us. However, we may permit our Service Providers to use aggregated or de-identified information that does not personally identify you or any other user of the Services
As necessary, for the following purposes: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.
With our distributors, resellers and suppliers for business purposes. For example, we may share your personal information to process your orders, fulfill your requests, provide customer service, and improve our products and services
To our insurers and professional advisers for the purposes of managing risks, obtaining professional advice, exercising or defending against legal claims, etc.
To third parties in connection with or during negotiations of any reorganization, acquisition, 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)
With third parties for co-marketing purposes, to improve our product recommendations and Services, or to provide you with other products and services
With other sites, including social media platforms and advertising partners (such as Google and Facebook), for the purpose of ad targeting, remarketing, and customized advertising content
We also provide an online chat service for our customers. If you use this chat service, the content of the chat messages as well as your email address and other personal information you provide via the chat feature may be shared with our Service Providers.

Sharing Information Through Social Media

We work with social media sites, and with application developers who specialize in social commerce so you can connect with us through your social networks, and share information and content such as reviews, photos, text, videos, routes, and usage data (“User Content”) with us. We provide our social media service providers with access to our Services so we can generate interest in our products among members of your social networks and to allow you to share your interest in our products with friends in your network. These social media service providers may collect or register your views (including whether you liked or purchased a product), and make those views available to us and on public portions of our Services. For example, when you use our hashtags in a social media post or respond to one of our usage requests (i.e., by using #YesRevZilla, #YesCycleGear, #YesJPCycles, or #YesREVER), your post is shared with us, and may appear on our websites. By using our hashtags or responding to one of our usage requests, you are consenting to our use of the information you post (including your likeness) for commercial purposes and without compensation.

For more information, please see our Terms of Use.

If you do not agree to all of these terms, please do not submit user-generated content to us or reply to our usage requests. If you do not want a social media platform to share information about you, you must contact that the social media provider and determine whether it gives you the opportunity to opt out of sharing such information.

We reserve the right to select what content appears on our social media accounts, websites, and apps, and may choose not to display your content even if you express an opinion about our services or products, use our hashtags, or affirmatively consent to a usage request. We reserve the right to remove content from our websites, apps, and social media accounts at our sole discretion.

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Charitable Giving

At Comoto, we believe in giving back to our fellow riders and the community more broadly. From time to time, we post information on our websites about charitable organizations we support, which may include links allowing donations. Our posting of information on our websites related to charities we support is not a solicitation for donations—whether you donate is completely up to you and in no way affects how we provide our products and services to you. We do not process charitable donations, and information you provide to a charity is subject to its terms of service and privacy policy. In some cases, some information you provide in order make a donation may be shared with us by the charity. Charities that share information in this way are required to notify you of that practice in their privacy policies. We appreciate you keeping our community strong, and welcome any questions about our charitable giving or how you can get involved.

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Additional Information About REVER and Geolocation Tracking

REVER helps riders find the best roads and trails, map and plan their routes, connect with each other, and track their riding activities anywhere in the world—even without cell service. In addition to the other information practices described in this Policy, REVER collects and processes:

Geolocation information when you register for and use the service online or through the REVER app.
Contacts information from your mobile device or social networking accounts if you choose to allow REVER access to this type of information. REVER uses this information in order to help you identify potential connections in REVER.
Information from Connected Apps and Devices. For example, if you connect your RLINK GPS Security device to your REVER account, information from this device will be passed along to REVER, and vice versa. Use of RLINK is subject to its Privacy Policy and Terms & Conditions.

In addition to the other uses of personal information discussed elsewhere in this Policy, REVER uses the personal information of its members to operate and customize the REVER app and website, help its members evaluate and improve their riding/driving experience, and assist members with vehicle maintenance and security. For example, REVER uses your personal information to suggest routes, challenges, events or communities that may interest you, or members that you may want to follow. REVER may also use information about you to target ads to you.

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Community and Privacy Settings

When you join the REVER community, your profile and activities are set to be viewable by everyone by default. Your name, profile information, photos, videos, routes, members you follow, members who follow you, communities you belong to, and the vehicles for which you use REVER may be accessed by REVER members and non-members or viewable on publicly accessible REVER pages, unless you modify your settings to restrict such disclosures.

REVER provides tools that allow you to limit the sharing of some of this information. For example, you can change the visibility of the activities you upload to REVER, and can choose whether to invite your contacts to view your location and activities using REVER LiveRIDE.

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Sharing With Third-Party Apps, Websites, and Plugins

REVER members may choose to share their activities with their contacts via text, email, or on social media applications like Facebook, Instagram, and Twitter. If you link your REVER account to third-party social networks and share your activities, your personal information (including your location) will be viewable on such third-party platforms. You should use caution when sharing information with third parties and carefully review the privacy practices of such third parties.

REVER also enables sharing with third parties offering integrated features on the REVER app, such as challenge sponsors. If you click on a third-party link, you will leave our platform and the sponsor may be able to identify that you visited their platform from REVER. Information collected by these third parties is subject to their terms and policies.

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Public Forums, Community, and Reviews

The Companies offer various communities and forums across the Services, as well as the ability to provide reviews of the products and services we sell. We offer several features that allow users to connect and communicate in public or semi-public spaces as part of the Services. You do not have to use these features, but if you do, please use common sense and good judgment when posting in these communities or sharing your personal information with others.

Please be aware that any personal information you choose to submit in any communities, forums, or reviews can be read, collected, or used by others, or could be used to send unsolicited messages to you. We may engage our Service Providers to assist in providing community services to you. The Companies generally do not control or remove content from public forums or communities on their websites (though we reserve the right to do so in our sole discretion). Your posts may remain public if you subsequently close your account(s) with the Companies.

Despite our safety and privacy controls, we cannot guarantee that you will not encounter inappropriate or illegal conduct from other users when using the Services. You can help us to make our websites (including public forums) welcoming for all users by reporting any offensive or unwelcome conduct to us.

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Our Services Are Not Intended for Children

Our Services are not intended for children nor targeted to children under the age of sixteen (16). Our Companies do not knowingly collect personal information from children under the age of 16. If we learn that we possess information from a child under the age of 16, we will delete such information in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws. If you are a parent or guardian and you believe that your child under the age of 16 has provided us with personal information without your consent, please contact us at [email protected].

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Data Retention

We may retain your personal information for the periods necessary to: (a) fulfill the purposes described in this Privacy Policy, (b) meet the timelines determined or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.

Email Communications

You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in every commercial email we send, or (if you have an account with us) by logging into your account and changing your preferences, or by sending us a request to unsubscribe at [email protected]. If you opt-out of receiving marketing email communications, we may still send you email messages related to your account with us, including specific transactions or our services. Unsubscribing yourself from our marketing communications will not affect our service to you.

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Text Messages and Alerts—Opting In and Out

You have the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you have shared with us. Once you have opted-in, we may send you text messages (i) regarding your account; (ii) to investigate or prevent fraud; and (iii) to alert you in the event of an emergency. We may send you text messages and alerts using autodialed technology. We will not contact you via text messages or alerts for marketing purposes without your prior express written consent. You do not have to opt-in to text messages and alerts to use and enjoy our websites and Services. If you opt-in, standard text messaging charges may apply. For more information regarding our text messaging and alerts, please contact us at [email protected] or 1-877-792-9455.

You may choose to opt-out from our text messages and alerts at any time using any reasonable means. To directly opt-out, send us a text message from your mobile phone with the word STOP, STOP ALL, END, QUIT, CANCEL or UNSUBSCRIBE, and we will unsubscribe you from text communications. Once you opt-out, you will not receive any additional text messages via your mobile phone. Please keep in mind that if you opt-out of receiving text messages and alerts we may not be able to contact you with important messages regarding your account. However, if there is an emergency or account question, we will make every attempt to contact you in other ways, such as by email or on a landline phone.

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Do Not Track

The Companies do not currently have the technology to automatically respond to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. If you are a California resident who wishes to delete your personal information, please see the instructions for submitting such requests, below.

Third-parties, such as Google Analytics, may collect data that relates to you on our websites, across time, and over other websites. Third-parties’ responsiveness to do-not-track signals is governed by their privacy policies. You also may limit certain tracking by disabling cookies in your web browser. For more information on Do Not Track, please visit https://allaboutdnt.com.

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Additional Information for the United Kingdom and the EU/EEA

The following describes the categories of personal information that we may collect about data subjects in the United Kingdom, the EU and the EEA, the purposes for which we may process the personal information, and the legal bases for such processing. In the case of personal information that we do not obtain directly from you, the source and specific categories of that data are also described:

We may process personal information relating to transactions, including purchases of goods and services that you enter into with us either as an individual or on behalf of your employer and/or through our Services or sites linked to our Services (“Transaction Information”). Transaction Information may include your contact details (such as company, name, email address and/or phone number), and the transaction details. Transaction Information may be processed for the purpose of supplying services and keeping proper records of transactions. The legal basis for processing Transaction Information is the performance of a contract between you and the Companies and/or taking steps, at your request, to enter into a contract.
We may process personal information related to an account you maintain with the Companies either as an individual or on behalf of your employer (“Account Information”). Account Information may include your name, title, email address and postal address. The legal basis for processing Account Information is the performance of a contract between you and the Companies and/or taking steps, at your request, to enter into a contract and/or our legitimate interests in the proper administration of our Services and business.
We may process personal information contained in any inquiry you submit to us regarding goods and services (“Inquiry Information”). The legal basis for processing Inquiry Information is the performance of a contract between you as an individual or on behalf of your employer and the Companies, and/or taking steps, at your request, to enter into such a contract and/or our legitimate interests in responding to inquiries regarding our products and Services.
We may process personal information related to your use of our websites and Services (“Usage Information”). Usage Information may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of our Services. The source of the Usage Information may be cookies, analytics services, tracking technologies or other methods. Usage Information may be processed for the purposes of analyzing your use of our Services. The legal basis for processing Usage Information is our legitimate interest in the proper administration of our Services and business, including monitoring and improving our Services.
We may process personal information about you to provide appropriate safeguards for your personal information, our Services and our IT systems. The legal basis for this processing is our legitimate interests in the safety, security and administration of our Services.
We may process information that you provide to us when you subscribe to our email marketing communications, newsletters and communications to keep you up-to-date on the Companies’ events and news (“Notification Information”). The legal basis for processing Notification Information is your consent if required. If you are an existing customer, the legal basis for this processing is our legitimate interests in providing you with information on our products and services.
We may process information contained in or relating to any communication that you send to us (“Correspondence Information”). Our Services use different forms for account or event registration, feedback, subscriptions, notification and authentication. Each form may require different information about you such as your name, title, company, address, or email address. For example, if we need to mail or ship information to you, we will ask for your name, company, and address. If you ask us to notify you of changes to our Services or products, we may ask only for your email address. We also may use your IP address to help diagnose problems with our servers and to administer our Services as well as for other reasons such as website monitoring, improvement, preference settings, etc. Correspondence Information may be processed for the purposes of communicating with you and recordkeeping. The legal basis for processing Correspondence Information is our legitimate interests in the proper administration of our Services and business communication with you.
We may process your personal information where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, an investigation, or other legal matters such as an acquisition, divestiture or merger. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. We may process your personal information where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
We may process the personal information included in your personal profile on our websites (“Profile Information”). This Profile Information may include your name, address, telephone number, business or personal email address, and social network information. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you or your employer and the Companies and/or taking steps, at your request, to enter into such a contract and for marketing purposes.

You may have the following rights:

The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object to processing
Rights in relation to automated decision-making and profiling

You can inquire about your Personal Information and how we process it, and obtain further information on the above data subject rights by contacting our Data Protection Officer using the details set out below.

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Data Protection Officer

Address: ________________

Phone: ________________

Email: ________________

You may also reach us as follows:

Completing the online request form available here
Emailing us at [email protected] [with “Privacy - Data Subject Request” in the subject line
Calling us at 1-877-792-9455
Sending a request to:

4020 S 26th St

Philadelphia, PA 19112

USA

Attention: Privacy - Data Subject Privacy Request

We will respond to most requests within thirty (30) days of receipt. We will contact you if an extension period is required to respond. We may ask for additional information to verify your identity and understand your request. There may be exceptions and limitations related to your request. We may, for example, charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, we may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice law enforcement, interfere with pending or future litigation, etc. In all cases, you have a right to file a complaint with the appropriate Supervisory Authority.

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Information Security

We have implemented appropriate and reasonable physical, technical, and administrative safeguards to help prevent unauthorized access to, use of, and disclosure of, your personal information. However, there is no perfect security. We cannot guarantee the security of your personal information. You are responsible for maintaining the secrecy of any credentials used to access your account with us and you should report suspected unauthorized activity to us immediately.

The Companies specifically reserve the right to terminate your access to the Services and any contract you have with the Companies in the event we learn or suspect you have disclosed your account or password information to an unauthorized third party.

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International Data Transfers

The Companies are global business based in the United States. We and our affiliated companies have offices and facilities in the United States, and we transact business in the United Kingdom, Germany, France, Spain and many other EU countries as well as other jurisdictions throughout the world.

We may transfer your personal information to recipients in countries whose laws may not provide the same level of data protection as your country. When we do so, we will ensure that there are adequate safeguards in place to protect your personal information and to comply with our legal obligations.

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Your California Privacy Rights

If you are a resident of California, your right to submit certain requests relating to your personal information is described below. Please note that when submitting a request, you will be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the process described below.

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Right to Opt Out of the Sale of Your Personal Information

California residents have the right to opt out of the sale of their personal information. To exercise this right, please submit a request through our Do Not Sell My Personal Information form found on our homepage, call us at 1-877-792-9455, or email us at [email protected]

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Right to Request More Information

If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:

(1) The categories of personal information we have collected about you

(2) The categories of sources from which we have collected your personal information

(3) The business or commercial purpose why we collected or, if applicable, sold your personal information

(4) The categories of third parties with whom we shared your personal information

(5) The specific pieces of personal information we have collected about you

(6) The categories of personal information that we have shared with third parties about you for a business purpose

(7) The categories of personal information that we sold about you and the categories of third parties who received your personal information in the sale

(8) A list of all third parties to whom we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes

You may submit a request for the information above by calling us at 1-877-792-9455, emailing us at [email protected], or submitting a completed form available her.

Please note that due to the different requirements of the applicable laws, our response times may vary depending on the specific type(s) of information sought. We respond to all verifiable requests for information as soon as we reasonably can and no later than legally required.

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Right to Request Deletion of Your Personal Information

California residents also have the right to request that we delete your personal information collected or maintained by us. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers (such as Google Analytics) that may have collected personal information about you through our websites to delete your personal information from their records. There may be circumstances where we cannot delete your personal information or direct service providers to delete your personal information from their records. For example, if we need to: (1) retain your personal information to complete a transaction or provide service(2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug or repair errors; or (5) comply with a legal obligation. You may submit a request to delete your personal information by calling us at 1-877-792-9455, emailing us at [email protected], or submitting a completed form available here. Should you wish to delete your personal information assoicated with any of our loyalty programs (and thereby cancel your participation in the program) please contact us at [email protected] and 1-877-792-9455. In connection with submission of your request, we will take steps to verify your identity as outlined below, and you will need to verify your identity before action is taken.

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Verification of Requests for Further Information or to Delete Personal Information

Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates, and to prevent unauthorized access or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of personal information provided to verify your identity, the nature of our business relationship with you, and available technology for verification.

We will generally try to avoid requesting additional information from you for the purpose of verification, but we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by law.

The following generally describes the verification processes we use:

Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity, but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.

Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:

For requests to know categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
For requests to know specific pieces of personal information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records.
For requests to delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.

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Verification by Authorized Agent. You may designate an authorized agent to make the requests above on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the process described above.

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If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.

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Right to Non-Discrimination for the Exercise of Your Privacy Rights

If you choose to exercise any of the privacy rights conferred by the California Consumer Privacy Act of 2018, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing our services to you, charge you different prices or provide a different level or quality of services to you unless those differences are related to the value of your personal information.

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Nevada Privacy Notice

Under Nevada law, Nevada residents who have purchased goods or services from us may opt-out of the “sale” of “covered information” as defined by Nevada law to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your personal information are not sales under Nevada law, so no opt-out is required.

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Changes to Our Privacy Policy

We reserve the right to revise this Privacy Policy at our sole discretion at any time. It is your responsibility to review our Privacy Policy each time you use our Services or provide personal information to us as our Privacy Policy may have changed.

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How to Contact Us

If you have any comments or questions about how we collect and use your personal information, communications can be submitted to our postal address, via email to [email protected], or by telephone to 1-877-792-9455.

Comoto Holdings, LLC

4020 S. 26 Street

Philadelphia, PA 19112

United States

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What’s New?

Effective _________, 2021, we updated our Privacy Policy to address REVER. REVER, which is the premier app that helps riders find and map their routes, and connect with each other is now part of Comoto. The latest version of our Privacy Policy includes descriptions of personal information collected and processed by REVER, and aligns the terms applicable to REVER with those of the other Comoto brands where possible. This meant making a few changes for REVER users:

Opting Out of Interest-Based Advertising

The previous REVER Privacy Policy had a specific section on how to opt-out of interest-based advertising. This has been removed in order to align REVER’s policy with the other Comoto brands. Information on opting-out of and removing cookies is described above under How We Collect Your Personal Information.

Data Subject Access Rights

The Policy now applicable to REVER addresses access, deletion, and rectification rights for individuals on a jurisdiction-by-jurisdiction basis, rather than the blanket approach of the old REVER policy. This includes new sections dedicated to California and the EU. Individuals who reside in a jurisdiction that does not provide such rights may not be able to access, delete or otherwise limit the use of their personal information.

Most of the other terms will be familiar to Comoto customers but are stated differently or differently organized compared to the previous REVER policy. Please feel free to reach out to us should you have any questions.