Privacy Policy - ELECTROLL

Privacy Policy

'Electroll' is operated by Seus Teknoloji İç ve Dış Tic.Ltd.Şti. (hereinafter referred to as 'Seus Teknoloji' or 'We') and it is a platform (or service) providing you with control and management services of intelligent hardware devices. We understand and are fully aware of the importance of personal information to you and will do our utmost to protect the security of your personal information. We will adopt corresponding security protection measures to protect your personal information in accordance with the industry-recognized security standards.

If you use Electroll scooters ('your scooter') and its supporting online application ('App' or 'Electroll APP') among other related services ('products and services') and are thereby subject to the 'User Agreement', this 'Privacy Policy' ('this Policy') stipulates how we collect, use, disclose, process and protect the information you provide for us when using our products and services; we will only strictly abide by this Policy and / or our user terms and conditions to use this information.

Therefore, please read and understand this Policy carefully before using our products (or services). This Policy can provide details about how we manage the personal information you disclose when you use our products and services.

Please take some time to familiarize yourself with our privacy practices. Should you have any questions, please let us know.

We promise you

This Policy has been formulated with full consideration of your needs; it is very important that you fully understand how we usually collect and use personal information and that you are fully convinced that you can ultimately control the personal information you provide for Seus Teknoloji.

In this Policy, 'personal information' refers to the information itself or data that can be used to identify a specific individual after being connected with other information that can be accessed by Seus Teknoloji.

By using our products and services, it means that you have read, approved and accepted all the terms described in this Policy, including any changes we may make at any time. We are committed to complying with applicable laws (including the data protection laws where you are located) to protect the privacy, confidentiality and security of your personal information. Meanwhile, we promise all our employees and agents fulfill these obligations.

Finally, what we hope to do is to bring the best experience to our users. Should you have any questions about the data processing practices outlined in this Policy, please contact our

data protection officer at info@electroll.com.tr so that we can deal with your special needs. We are happy to handle your problem directly.

What information do we collect and how do we use it?

Types of information we collect

In order to provide you with our services, we may ask you to provide the personal information necessary to render you the said services. If you do not provide personal information, we may not be able to provide you with some of our functions or services, but it will not affect your use of the basic functions or services of this product.

We will only collect the necessary information required for specified, clear, and lawful purposes, and will not conduct further processing in a manner contrary to it. We may collect the following types of information (whether it is personal information or not):

• Device information: information related to your device. For example: model, Bluetooth, MAC address, device ID, single mileage, cumulative mileage, vehicle speed, battery information, cruise control switch, capacity recovery intensity, firmware version, vehicle body temperature, power mode, and lock

status.

• Other information: vehicle lockcode.

How will this personal information be used

The purpose of collecting personal information is to provide you with products and/or services and to ensure that we comply with applicable laws. You hereby agree that we process personal information for the purposes specified in this Policy and disclose personal information to third-party service providers (defined below).

We may use your personal information for the following purposes:

· Provide, process, maintain, improve, and develop our products and/or services provided to you, including services provided through equipment, and equipment information as is shown to you.

· Communicate with you about your equipment, services, or any general

inquiries (such as updates, customer's consulting and support, information about our activities, notifications), etc.

· Provide local services without communicating with our servers.

· For security verification and solutions when the password is forgotten.

Here are more details about how we use your information (which may include personal information):

· Display device information: After connecting to the device via Bluetooth, you can check the device information through our APP, such as speed, mileage,

battery information, cruise control switch, capacity recovery strength, firmware version, power mode and lock status.

With whom do we share your information?

We will not sell any personal information to third parties.

We may sometimes disclose your personal information to third parties (see below for definitions) in order to provide the products or services you request.

We may make disclosure to the third-party service providers and affiliates listed below in this section. In the various situations described in this section, you can be rest-assured that Seus Teknoloji will only share your personal information based on your authorization. You should understand that in any of the situations described below, when Seus Teknoloji shares your personal information with a third-party service provider, Seus Teknoloji will stipulate the practices and obligations of the third party through contracts while complying with applicable local data protection laws. Seus Teknoloji will ensure through contracts that third-party service providers comply with the privacy standards applicable to them in your jurisdiction.

Share information with our group and third-party service providers

In order to successfully engage in commercial operations to provide you with all the functions of products and services, we may disclose your personal information to our third-party service providers (our mailing shops, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and promotion service providers, agents on behalf of Seus Teknoloji) [affiliated companies and/or other third parties] (collectively referred to as 'third-party service providers') from time to time. Such third-party service providers may process your personal information on behalf of Sesu Teknoloji or for one or some of the above purposes. If you no longer wish to allow us to share this information, please send an email to info@electroll.com.tr to contact us.

Share information with others

When required by applicable laws, Seus Teknoloji may disclose your personal information without further consent.

Information that does not require consent

We may share anonymous information with third parties (such as advertisers on our website) in an aggregated form for commercial purposes; we may share general trends in the

use of our services, such as the number of customers within certain population demographics that have purchased certain products or engaged in certain transactions.

To dispel doubt, Seus Teknoloji may collect, use or disclose your personal information without your consent under the circumstances and within the scope expressly permitted by local data protection laws (for example, in order to comply with subpoenas). Besides, we may disclose your information without your consent when we believe in good faith that it is necessary to make disclosure to protect our rights, protect your safety or the safety of others, investigate fraud or respond to government requests.

Security

Seus Teknoloji’s safety measures

We are committed to ensuring the security of your personal information. In order to prevent unauthorized access, disclosure or other similar risks, we have implemented reasonable physical, electronic and management measures and procedures to protect the information we collect from your products and Sesu Teknoloji website. We will take all reasonable measures to protect your personal information.

Your information, such as device information, Bluetooth information and vehicle lock password among others are all stored locally on the device and we will not obtain it. When you delete our app, this information will be cleared together. In summary, we regularly review information collection, storage and processing practices, including physical security measures, to prevent any unauthorized access and use.

We will take all feasible measures to protect your personal information. However, you should be aware that the use of the Internet is not always safe. Therefore, we cannot guarantee the security or integrity of any personal information when it is transmitted in both directions via the Internet.

What you can do!

· Seus Teknolojiis not responsible for the security omissions caused by

third parties accessing your personal information due to your failure to maintain the privacy of your personal information. Despite the above regulations, if you become aware of any security vulnerabilities related to products and services,

you must notify us immediately.

· Your assistance will help us protect the privacy of your personal information.

Retention policy

If it is necessary to serve the purpose of collecting information, or to comply with applicable legal requirements or permission, we will always retain personal information. As long as it can be reasonably inferred that the purpose of collecting personal information cannot be fulfilled by retaining personal information, and we no longer need to retain information for legal purposes, dispute resolution, enforcement of our agreements or other business purposes, we will no longer retain personal information or eliminate the way to associate personal information with specific individuals.

You can control your information!

If you have previously agreed to our use of your personal information for the above-mentioned purposes, you can change your decision by contacting us in writing or emailing info@electroll.com.tr at any time.

Access, update or delete your personal information

· You have the right to request access to and/or delete any personal information

we have about you. When you update your personal information, we will ask to verify your identity before we process your request. Once we have sufficient information to process your request to access, correct or delete your personal information, we will respond to your request within the time specified by the applicable data protection law.

· We usually provide these services for free, but we reserve the right to charge a reasonable fee for your data access request.

· If you wish to request access to the personal data we hold or if you believe that any information we hold about you incorrect or incomplete, please write to

us as soon as possible or send an email to the email address provided below to contact us. Email: info@electroll.com.tr

· According to applicable laws and regulations, you may have the right to ask us

to delete your personal data. We will evaluate your deletion request, and if the relevant regulations are met, we will take corresponding steps including technical means to deal with it. When you have deleted relevant information or have done so with our assistance, due to applicable laws and security technologies, we may not be able to delete the corresponding information from the backup system immediately. We will safely store your personal information and isolate it from any further processing, until the backup can be cleared or anonymity can be achieved. For example, according to the 'E-Commerce Law of the People's Republic of China', your product and service information and

transaction information are kept for at least three years from the date of

completion of the transaction.

Withdrawal of consent

· You can revoke your consent to the collection, use and/or disclosure of your personal information that we hold or control by submitting a request. We will process your request within a reasonable time after you make the request,and

will no longer collect, use and/or disclose your personal information in accordance with your request.

Transfer personal information outside of your jurisdiction

If we need to transfer personal information outside of your jurisdiction, whether it is to our affiliates or third-party service providers, we will fully inform you in accordance with applicable laws and obtain your prior authorization. By implementing appropriate security measures, we ensure that all such transfers meet the requirements of applicable local data protection laws and we will not change all our commitments to complying with this Policy to protect your personal information.

Other regulations

Minors

· We believe that it is the responsibility of parents to supervise children's use of

our products and services. However, our policy does not require obtaining personal information of minors or sending any promotional materials to such groups of people.

· Seus Teknoloji will not seek or attempt to receive any personal information from minors. If a parent or guardian has reasons to believe that a minor has submitted personal information to Seus Teknoloji without their prior consent, please contact us to ensure that such personal information is deleted and ensure that the minor unsubscribes from any applicable Seus Teknoloji service.

Priority

If you agree to the applicable user agreement, and there is an inconsistency between such user agreement and this Policy, the said user agreement shall prevail.

Update on privacy policy

We will review this Policy on a regular basis. In order to reflect changes in our

information practices, we may update this Policy. If we make major changes to this Policy, we will notify you via email (sending email to the address specified by your account) or via mobile devices, make public the notification on all Seus Teknoloji websites, so that you can understand the information we collect and how we use it. Such privacy policy

changes will be applicable from the effective date specified in the notice or on the website. We recommend that you check this webpage regularly for the latest information on our privacy practices. Your continued use of the products and services on the website, mobile phone and/or any other device will be deemed to have accepted the updated privacy policy. When we collect more personal information from you or we hope to use or disclose your personal information for a new purpose, we will obtain your consent again.

Do you have to agree to any third-party terms and conditions?

Our privacy policy does not apply to products and services provided by third parties. Seus Teknoloji’s products and services may include third-party products and services, as well as links to third-party websites. When you use these products or services, your information may also be collected. Therefore, we strongly recommend that you spend time reading the privacy policy of the third party, just like reading our policy. We are not responsible for how third parties use the personal information they collect from you, nor can we control their use. Our privacy policy does not apply to other websites linked through our service.

Contact us

If you have any comments or questions about this Policy, or any questions related to the collection, use or disclosure of your personal information by Seus Teknoloji, please contact us at the following 'Privacy Policy' address:

Seus Teknoloji İç ve Dış Tic. Ltd. Şti

Address: Halkalı Merkez, Yıldızlar Oto Mitsubishi Sitesi, Basın Ekspres Cd. No:25 D:1B, 34303 Küçükçekmece/İstanbul

Email: info@electroll.com.tr

Thank you for taking the time to understand our privacy policy!