justswitch.com is committed to your right to privacy. We recognize the importance of privacy to our customers and website visitors. By reading this statement you consent to the processing of your data in accordance with this Privacy Policy. We will keep this policy under review and any changes made from time to time will be posted on this page. This Privacy Policy sets out details of the personal information we collect about you and the ways in which we may use that information.

Personal information

justswitch.com endeavors to collect and use your personal information only with your knowledge and consent. We may gather your information from a purchase through your customer enquiries via email or through our customer services team, when you request product information or, when you register online or enter any promotions or competitions through any channel. For web visitors, a user must first complete a registration form. During registration, the user is required to give their contact information (such as name, phone number and email address). This information is used to contact the user about the services on our site for which they have expressed interest. justswitch.com does not share any personal or private customer information submitted online with third parties. Demographic information may also be requested (such as region or PO Box). This information will be stored, analyzed and used to assist justswitch.com to improve our services. The information you provide on the justswitch.com website and/or other communication channels will be held only by justswitch.com and its duly authorized agents. Your information will not be given or sold to any outside organization for marketing purposes without your consent. We may disclose your information to other companies in the Axiom Telecom LLC, including their respective partners, agents and subcontractors, for any relevant purposes. In addition, we may disclose your information as may be required by law, regulation or legal proceedings.

Data Collection

By submitting your personal information you accept that your details and related information will be managed by justswitch.com. Please note that justswitch.com may provide aggregate statistics and general information about justswitch.com customers, sales, traffic patterns and related site information to reputable third-parties, but these statistics and general information will not include personally identifying information.

Purpose of collecting information

If you are an justswitch.com registered customer, we may use your personal information for the purposes of: (a) verifying that you are an authorized user if you call the justswitch.com customer services, (b) informing you of any service related changes affecting your purchase. justswitch.com may also use the personal information for the purposes of: (c) providing you with axiom telecom and related products and services, (d) informing you of justswitch.com special offers that we think may be of interest to you. justswitch.com may also be obliged to disclose your personal information to meet any legal or government regulatory requirements or obligations in accordance with applicable laws. If you decide that you no longer want to receive information from us, you should contact justswitch.com directly at [email protected]. From time to time justswitch.com also requests information from users via our online surveys and satisfaction questionnaires. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and address) and demographic information (such as PO Box and age). Survey information will be used for purposes of monitoring or improving customer experience.

Comments and Questions

justswitch.com reserves the right to amend or modify this Privacy Policy at any time and in response to changes in applicable data protection and privacy legislation. If you have any comments or questions about this Policy or about the information we have gathered about you, please contact justswitch.com at [email protected]. SWITCH Scooter & SCOOT by Switch Smart Commuting App Privacy Notice Effective date [21/7/2022] The SWITCH scooter & SCOOT by Switch smart commuting App Privacy Notice (“Privacy Notice”) describes: how SWITCH collects, uses, stores or otherwise processes an individual’s personal data in the context of the SWITCH scooter / SCOOT by Switch smart commuting; Before you proceed with the registration of your SWITCH scooter, we want you to know thatusing the SWITCH smart commuting(“the App”) will involve certain data processing activities of your personal data by SWITCH and its partners. In this privacy notice, “SWITCH ”, “we” or “us” refers to SWITCHand its affiliated group companies. SWITCH will process your personal data as a data controller of your personal information. This Privacy Notice governs the relationship between you and SWITCH, and the specific personal data processing activities conducted in connection with the SWITCH scooterand the SCOOT by Switch smart commuting App. Such privacy notice includes among others, a description of your data protection rights and how you can exercise them, how we may share your personal information or how we protect personal data in our products. What personal data does the SCOOT by Switch smart commuting App process? Please be aware that personal data means any information which is related to an identified or identifiable natural person. When you choose to install and use the App, SWITCH requires you to provide certain personal data, as described in the table below, to complete registration, and for the purpose of enabling you to use the App features. When you use the product, data is generated. Categories of data generated can be summarized into: a) user’s account data; b) interaction（between User & the App）data; c) device data and d) User‘s feedback. Please see the following table below for more detailed information.

Data Type	Source of the Data	Legal Basis	Purpose
Email Address	Directly from you, when signing up and linking the app with the product.	Contract performance Consent, where necessary	To create an account. To deliver the features and functions of the App. To deliver support when needed. To improve the App. To manage and renew your subscription. To communicate with you regarding product updates, education and current privacy affair.
Account Login Credentials	Directly from you, when signing up and linking the app with the product.	Contract performance Consent, where necessary	For user authentication and identification.
Event Data (i.e. sweep, pause, set restricted area, edit room partition, remote control and other command events)	From the App as a result of your interaction with the App and SWITCH scooter	Contract performance Consent, where necessary	For query logs and troubleshooting.
IP Address	From the App.	Contract performance Consent, where necessary	To determine the country where the equipment must be, for instance to locate problems, such as anti-cross cargo.
Device Type OS Type App Version Crash Data	From the App.	Contract performance Consent, where necessary	To deliver support if you have an issue To maintain feature compatibility with Operating Systems To confirm that the App is interoperating with your device correctly To provide Device Sync.
Serial Number MAC Address Equipment Unique Identification Certification	From the App.	Contract performance Consent, where necessary	To analyze device logs and behaviors to help users resolve issues.
Your opinion on the App	From you if you choose to send feedback.	Consent, where necessary	To understand how we can improve the App. This is voluntary and you can choose not to provide feedback.

What specific permissions do you grant us, and how to withdraw consent? In order to process your personal information, when it is necessary, SWITCH will ask for your consent within the App for specific features. The table below describes how you can grant and withdraw your consent to such specific consent items. Please note that some features would not be available if you do not grant the App permission. Also, we want you to know that we will not sell nor share your data for marketing related purposes. In addition, we will not send you marketing related communications by email, or via in-app push notification unless we have previously obtained your consent.

Feature	Data Processed	Purpose	Withdraw Mechanism
GPS	Specific location as per app permissions.	To connect the App to the device via Bluetooth. Some smartphones can’t find Bluetooth device until GPS swich is enabled. SWITCH will not collect your precise location data.	System/App settings in your phone
Wi-Fi	Wi-Fi settings as per app permissions.	To transfer data and interact with the device and cloud.	System/App settings in your phone
Camera	Access to your camera and phone gallery as per app permissions.	To upload your avatar picture. If you add the device by scanning the QR code, the camera needs to be turned on.	System/App settings in your phone
Bluetooth	Access to your Bluetooth as per app permissions.	To transfer data between the device and phone.	System/App settings in your phone
Cellular	Access to your cellular as per app permissions.	To transfer data and interact with the device and cloud.	System/App settings in your phone

How do we share your personal data? In order to provide the service, we will share your information with Axiom Telecom LLC. To maintain the App at good accessibility & usability. As part of SWITCH’s data processor arrangement with them, SWITCH requires that Axiom Telecom LLC maintains information security best practices, makes all reasonable efforts to secure your data and only processes your data for the purposes listed in the table below.   How Long do we keep your personal data? When we design a product, we focus on delivering the best user experience. In order to do so, we will process personal data for the purposes described in this Privacy Notice, but we will only retain your personal information as long as necessary to achieve proper performance of the product. In some cases, we may need to retain your personal data when it is required by law. Please see below detailed information about the data retention schedule.

Type of Data	Retention Period
Regular Personal Data	18 months
Location Data	18 months
User Content	18 months after the account is inactive
App Data	18 months
Hardware/Device Data	18 months
SN of the device	18 months after the account is inactive

Changes to this Privacy Notice Our mission is to be as transparent as possible. We might update this privacy notice to let you know about any changes in the way the product, or SWITCH process your personal data and ask you if you are happy with those changes when necessary by law. We will let you know via in-app push notification or e-mail about such changes to make sure you are up to date. Contact us For any privacy related matters please contact the SWITCH Privacy Program at [email protected] or Free toll number 800-SWITCH. We will get back to you as soon as possible.