1. WHAT PERSONAL DATA WE COLLECT AND PROCESS

Personal data means any data which can directly or indirectly identify your personal identity, such as your name and email address. Please note that we may collect your personal data for particular purposes based on the Gogoro Products and/or Services you use based on your prior consent.

When you create Gogoro account (the “Gogoro Account”), purchase and/or use any the Gogoro Products and/or Services, accept any software update, contact us, participate in our events or campaigns, or otherwise in any manners interact with Gogoro, we may collect a variety of your personal data depending on the Gogoro Products and/or Services you use within the necessary scope of purposes, including:

• When you register for the Gogoro Account: We may collect your true, accurate, current and complete registration data, including your identification and description data such as your name, password, gender, picture, and the contact data such as your email address and mobile phone number.
• When you purchase and subscribe the Gogoro Products and/or Services such as Gogoro Smartscooter and Gogoro Network battery swapping plan(s): We may collect the identification and description data such as your name, Gogoro Account ID, age, date of birth; under certain limited circumstances, we may ask for your Government-issued ID such as your national identification ID number, foreign passport, residency proof, work permission, work certificate, driver license, and other related details; If any payment and relevant financial services are involved, we may collect your financial and payment data such as your credit card number or other payment card information, bank account passbook cover, accidents or other mishaps information, and relevant situation data.
• When you use the Gogoro Products and/or Services which are associated to the Gogoro Account such as the Gogoro Smartscooter and the Gogoro Network battery swapping service: We may collect your information with respect to the use of the Gogoro Products and/or Service such as the Gogoro Smartscooter VIN, plate number, owner’s name, batteries’ serial number, Gogoro Smartscooter settings, tariff plan you have subscribed, the location of GoStation where you have swapped batteries, and Gogoro Smartscooter riding data and behavioral information.
• When you enter or approach our business premises: We may collect your personal photos, photocopy and videos taken by the surveillance cameras of GoStation(s) or in our other business premises.
• When you participate in our events or campaigns: We may collect the identification and description data such as your name, gender, age, date of birth; the contact data such as your email address, mobile phone number; the other relevant data such as your marital status, family member and other social relations, hobbies, consumption behavioral patterns, occupation, driver’s license, education, and other relevant data.
• When you use Digital Scooter Key Service: We may receive from Apple Inc. and/or its affiliates (“Apple” ) your Apple ID and your iPhone identifier; if you share your Digital Scooter Key to any other person through our Digital Scooter Key Service, we may receive from Apple the above information of such person who received the Digital Scooter Key from you.
• When you sign up a GoShare account (the “GoShare Account”) for services relating to GoShare (the “GoShare Service” ) or contact us through any channels with respect to your use of the GoShare Service: We may collect some of your basic information depending on the membership management requirements of the country or region you reside, such as your name, date of birth, phone number, mailing address and email address. Moreover, you might be required to upload a photocopy of your identification and driver’s license (both front and back sides) if and when necessary.
• When you use the GoShare Service: We may collect information about how you use the GoShare Service, including without limitation information about your devices, system setting preference, real-time location, rental term, ride routes, payment details, usage time of Gogoro Network battery and mileage, traffic tickets during rental terms and details of fine payments, photos you take when returning the rented electric scooter by using GoShare APP as well as your feedback.
• When you use the GoShare for Business or receive the riding discounts/subsidies provided by the Appointed Enterprise: We may receive your personal data (including but not limited to name of your company, job title, current employment status, email address, employment history, etc.) from the Appointed Enterprises (as defined in the relevant Terms of Use applicable in your region); further, we may provide the system permissions that are required to access your GoShare Account ID, riding time, riding fee, amount of riding discount/subsidies, refund amount, payment status to the Appointed Enterprises to enable them to collect, utilize and process for the purpose of acquisition of riding discount/subsidy or fleet management.
• When you purchase or use the Eeyo Smartwheel: We may collect your identification data such as name, gender, age, date of birth, the Gogoro Account ID and passwords; your contact details such as email address, mobile phone number, and postal address; your payment information such as the information with respect to credit card or other electronic payment methods you use to make payments to us.
• When you ride the Eeyo Smartwheel or use its services or certain functions: We may collect your Eeyo Smartwheel and device information such as the purchase date, serial number, model, battery health, total running time, total mileage, APP version, download and update history, brand or type of the paired mobile phone device, firmware version, the status of the wheel lock and unlock, battery temperature, battery usage, and battery voltage; your Eeyo Smartwheel riding information such as your riding distance, duration, location, speed, RPM, kcal, time, pedal cadence, input torque, output torque, and regen status; your physical attributes information such as height and weight.

Please note that we may only collect the relevant personal data for particular purposes based on the Gogoro Products and/or Services you use, rather than collect each and every personal data of the above categories. Further, you are not obliged to provide your personal data according to our request; however, if you choose not to provide your personal data as requested by us, we may not be able to provide you with the relevant Gogoro Products and/or Services. Please refer to Section 9 for further details.

2. HOW WE PROCESS YOUR PERSONAL DATA

We, by ourselves or in collaboration with our designated local business partners, may collect and use your personal data for the following purposes and the lawful bases:

• To provide the Gogoro Products and/or Services that are associated to the Gogoro Account such as Gogoro Smartscooter and Gogoro Network battery swapping service plan(s): We may collect and process your personal data in order to provide you with the Gogoro Products and/or Services, including to inform you of updates to certain firmware and/or software. We collect and process your personal data based on the contractual or quasi-contractual relationship between you and us, or to perform our agreement with you as described in the Terms of Use, upon your registration of the Gogoro Account, or otherwise as notified by us to you from time to time.
• To provide GoShare Account users with the membership registration and management service : When you register for membership or contact us through any channels for the GoShare Account, we may process your personal data provided by you upon the GoShare Account registration in order to verify your identity and user membership, send to you verification emails and other management-related messages, inform you of updates on this Policy or the relevant Terms of Use, understand your inquiries and needs, and for overall membership management.
• To provide, improve and promote the GoShare Service: To provide you with complete functions and features of the GoShare Service, to improve the GoShare Service, and to optimize user experience in relation to the GoShare Service, we may collect information about how you use the GoShare Service; in addition, we may use your personal data and the use records of the GoShare Service for the purposes of promotion and market analysis, and send you our marketing information.
• To provide the riding discounts/subsidies of the GoShare for Business: To provide you with the services under the GoShare for Business, or qualify you for the riding discounts/subsidies of the GoShare for Business provided by the Appointed Enterprises, we may receive your personnel data for the purpose of performing the contract(s) between Gogoro and the Appointed Enterprises to which you belong and identifying whether to offset your personal riding fees by using the available riding discounts/subsidies from the Appointed Enterprises. For avoidance of doubt, the above discounts/subsidies may not be applicable in each and every region the GoShare for Business is operated.
• To provide the basic service of the Eeyo Smartwheel: We may collect and process your personal data in order to provide you with the basic service of the Eeyo Smartwheel, including informing you of updates to the Eeyo related services.
• To provide certain functions of the Eeyo Smartwheel: Where you provide your explicit consent to us, we may also process or utilize the information about your physical attributes or location in order to provide certain functions to you such as Riding History, UI Display, Smart Feature and Machine Learning. Specifically, when you use the services of the Eeyo Smartwheel, we may process your personal data manually and/or via our IT systems. Where you provide your explicit consent, we may use the artificial intelligence technology and algorithms to analyze your data that we collect in order to facilitate your riding activities. The artificial intelligence technology may create a profile for you and analyze your riding activities through the personal data we collect from you, in order to determine the proper power to facilitate your riding activities. For example, the output of the riding power from the Eeyo Smartwheel may be optimized according to your pedaling behavior and adjusted according to the inclination of the route you are riding on as predicted by the gyroscope in your mobile phone. In addition, we may provide you with the weather or battery forecast by analyzing your location data.
• To enable customization of your device: We may collect and process your personal data in order to enable customization of your device (including without limitation your Gogoro Smartscooter) based on your setting.
• To perform diagnostics on your device: We may collect and process your personal data in order to perform diagnostics on your device (including without limitation your Gogoro Smartscooter) and to provide you with the status updates.
• To manage your account(s) and perform our internal management work: We may process your personal data for our user account(s) management purposes, including to facilitate and improve our performance of the service(s) provided to you, to establish and maintain your account(s), as well as to ensure the security and proper functioning of your account(s), of the service(s). We may process your personal data in the course of the management of our business including in the event of a business sale or restructuring. These activities are conducted because they are necessary for our performance of our agreement with you (such as creating and managing your account(s)), for our legitimate interests (such as ensuring the security and proper functioning of your account(s), of the service(s), developing our business in the course of a business sale or restructuring), or for our compliance with applicable laws and regulations (such as fraud prevention).
• To send you event invitations and other marketing information in connection with the Gogoro Products and/or Services (if you are an existing client): Unless you object in accordance with Section 14 below, we will send you invitations to events that we host, co-host or sponsor, as well as other marketing information, such as recommendations of the service(s), the Gogoro Smartscooter or similar service(s) provided by Gogoro and/or third parties which are in collaboration with us, based on our legitimate interest to develop our business activity.
• To send you event invitations and other marketing information (if you are a potential client): With your explicit consent, we may send you invitations to events that we host, co-host or sponsor, as well as other marketing information, such as recommendations of the Gogoro Products and/or Services and other service(s) and product(s) provided by third parties which are in collaboration with us.
• To provide you with the customer service: We may process customer feedback information including the problem type, description, images and error codes, for the troubleshooting purposes in accordance with our agreement with you, or, if we do not have any contractual relationship with you, based on our legitimate interest to troubleshoot any identified problem.
• To improve the Gogoro Products and/or Services and your client experience: We will collect and process your personal data, in particular to facilitate your browsing, based on our legitimate interest to improve the service, our website, our mobile application, and your client experience.
• To customize your experience: With your explicit consent, we may collect and process your personal data in order to customize the content of the service and your browsing experience.
• To host, co-host or sponsor events: If you choose to register for an event that we host, co-host or sponsor, we may use your personal data for the purpose of organizing and holding the event, based on our legitimate interest to develop our client relationship.
• To fulfill legal and regulatory obligations: We collect and process your personal data in particular when we cooperate with public, governmental or regulatory authorities or to process your requests to exercise your rights, based on our legal obligations under applicable laws and regulations.
• To defend ourselves against legal claims: Where we are required to participate in any litigation and/or arbitration which affects our business, we may process your personal data in compliance with applicable laws and regulations, in our legitimate interest, to the extent necessary for the establishment, exercise or defense of legal claims.

3. LEGAL BASIS FOR PROCESSING

There are a number of different legal bases for processing personal data. In a specific case, this will depend on how we process or will process your personal data and for what purpose. In the majority of cases, the legal bases include:

• Where you have provided your consent to us processing your personal data in the manner as specified by us;
• Where we process your personal data in our legitimate interest;
• Where it is necessary to process your personal data for entering into an agreement or performing an agreement with you;
• Where it is necessary to process your personal data for complying with relevant legal or regulatory obligations.

We generally do not collect or process any sensitive personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life, and sexual orientation, etc.). If required, we will generally rely on obtaining an additional specific consent from you at the time we collect the sensitive personal data unless otherwise permitted under the applicable laws and regulations or for other similar reasons.

4. TO WHOM WE WILL SHARE YOUR PERSONAL DATA

The personal data you provide to us may be shared with third-party companies, including but not limited to our partners, agents, contractors, service providers, business partners, or our affiliated companies if this is necessary to provide you with our service(s), respond to your inquiries, or for any of the purposes described in this Policy. This may include:

• our vendors, suppliers, dealers, partners or outsourced service providers;
• Sub-processors who store or process the information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format such that, that data cannot be linked to any particular individual and is therefore not considered to be “personal data”;
• our auditors, insurers, lawyers, and other professional advisers;
• law enforcement agencies, other governmental agencies, courts, or third parties if we are required by law to do so, or where we believe it necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party;
• our business partners, such as other electric scooter manufacturers using Gogoro Network battery swapping services;
• Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

We use outsourced service providers to assist us with the following:

• Analytics: to monitor and analyze user traffic, to assess the popularity of specific functions and to keep track of your behavior when using the service, including for marketing and advertising purposes over time and across different services and devices;
• Infrastructure monitoring: to monitor the use and behavior of Service components for performance assessment, maintenance and troubleshooting purposes;
• Hosting and backend infrastructure: to host data that enables the Gogoro Products and/or Services to function;
• Event service providers: which manage events for us;
• Other services: to provide Gogoro Products and/or Services to you, or for the performance of our agreement with you.

5. INTERNATIONAL PERSONAL DATA TRANSFERS

We may transfer your personal data to different countries/regions in compliance with the applicable privacy and personal data protection laws and regulations in such countries/regions, including the European Economic Area (“EEA”), Singapore and Japan, where the data centers of third-party cloud services we use are located.

You understand and acknowledge that when you agree to provide your personal data to Gogoro, your personal data may be transferred, storaged, used or processed to and/or by Gogoro’s affiliated companies, vendors and any of its service providers who may be located in a different country/region from where you reside. All such transfer, storage, use or process of your personal data, shall be subject to the Policy and applicable privacy and personal data protection laws and information security regulations.

For the EEA, the United Kingdom (“UK”) users, in providing the Gogoro Products and/or Service, managing your account(s) and otherwise in managing our business, we may transfer your personal data outside the countries/regions , including to the recipients described in section 4.

Where we transfer your personal data to countries/regions outside of the EEA or UK which are yet to be subject to a finding of adequacy, we put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your personal data is adequately safeguarded and protected and conduct an assessment on personal data transfers.

We may obtain written assurances from any third party given access to your personal data so as to require them to adopt standards that ensure an equivalent level of protection for your data as that adopted by us. For more information on the appropriate safeguards in place or to obtain a copy, please contact us using the details at section 14 of this Policy.

6. HOW LONG WE RETAIN YOUR PERSONAL DATA

Generally, we will retain your personal data for the period necessary to fulfill the purposes herein in this Policy, unless a longer retention period is permitted by law or required to fulfill other necessary purposes. For instance, we may retain your personal data within adequate and reasonable period for customer relationship management purpose; we may retain your personal data within the period requested by such laws and regulations to comply with tax law or other laws and regulations; we may retain your personal data for longer retention period to follow requests from governments or judiciary for purposes such as investigation or lawsuit.

7. YOUR RIGHTS

Subject to the applicable local laws and regulations, you have the following rights in relation to your personal data. To exercise these rights, please contact us using the details at section 14 of this Policy:

• Right to access: You have the right to access your personal data processed by us in order to check or view such personal data. You also have the right to request a copy of the personal data we hold about you.
• Right to rectify: If any of your personal data that we are processing is inaccurate or incomplete, you may request us to rectify it or to make the required corrections to it.
• Right to erasure/delete: You may have your personal data erased/deleted from our database or anonymised if the processing is no longer necessary for the purposes pursued by us, or if, among other things, your personal data are being unlawfully processed.
• Right to data portability: Under certain circumstances, pursuant to applicable local laws and regulations, you may have the right to receive your personal data and have these personal data directly transmitted from us to a third party, where technically feasible.
• Right to object: Under certain circumstances, pursuant to the applicable local laws and regulations, you may have the right to object to our processing of your personal data (for example, where the processing is carried out on the basis of our legitimate interests). Where we process your personal data for direct marketing purposes, you can exercise your right to object at any time without having to provide any specific reason for such objection, including demand the cessation of the collection, processing or utilization of your personal data.
• Right to restrict: The processing of your personal data can be restricted upon your request. In such circumstances, your personal data will not be further processed except with your consent, or except for the establishment, exercise or defense of a relevant legal claim or for the protection of the rights of another person.
• Right to withdraw consent: If we process your personal data for a purpose for which the lawful basis is your consent or explicit consent, you may withdraw such consent at any time by notifying us.
• Right to lodge a complaint: If you deem that your rights under the applicable local laws and regulations have been infringed, you have the right to lodge a complaint with the competent supervisory authority for data protection in your country.

The rights described above might be subject to the requirements and conditions provided by the applicable law. In certain cases, we may ask that you explain to us why you are making a specific request, or, if needed, confirm your identity. We may not be in a position to take actions at your certain requests, for example, where to do so would impede a criminal investigation.

Please note that these rights are not absolute, in some cases they will not apply to you, or to the particular use that we are making of your personal data, and there are exceptions, such as if we have to process the personal data to comply with our legal obligations), but we will let you know if you make a request that we believe we cannot comply with.

Any request from you for your above rights must be in writing or by other Gogoro assigned methods, and we will endeavor to respond within a reasonable or the statutory period after verifying your identity in compliance with the applicable privacy and data protection laws and regulations. We will comply with our legal obligations under the applicable laws and regulations with regard to your rights as a data subject.

You understand and agree that in accordance with applicable laws, we may have the right to charge you for a certain amount of fee depending on the complexity of your requests to cover our operational expenditure.

If there are other special requirements under the applicable laws and regulations in the country where you reside, we will process your personal data in accordance with such applicable laws and regulations.

8. CALIFORNIA USERS

This section applies to the users of the Eeyo Smartwheel and its service(s) of the users in California, USA. Gogoro has collected, used, and shared the categories of personal data described above in this Policy. For example, depending on the service(s) you use, this may include identifiers (e.g., email addresses, IP addresses, and mobile device identifiers), demographic information, geolocation information, and internet or other electronic network activity information. This may also include inferences we draw from the other information we collect. See section 2 and other relevant sections of this Policy for more details.

California residents may request access to, deletion, and portability of their personal data in accordance with applicable law by contacting us as set forth in section 14 of this Policy. We will not discriminate against you for exercising your rights, although some of the functionality and features on the service(s) of the Eeyo Smartwheel may change or no longer be available to you. Any differences in the service(s) of the Eeyo Smartwheel are related to the value provided.

Once we receive your request, we may verify it through your account(s) or by requesting information sufficient to confirm your identity. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise rights on your behalf.

Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

9. CONSEQUENCES OF NOT PROVIDING PERSONAL DATA TO US

If you do not provide us with your personal data which are required for the Gogoro Products and/or Services, we will not be able to provide you with the Gogoro Products and/or Services. If you register for an account(s) but do not provide us with your personal data other than those personal data required for the registration, we will not be able to fully perform the service(s). If we are required to obtain your personal data in order to fulfill legal obligations to which we are subject, and you do not provide such information to us, we may not be able to accept your use of theGogoro Products and/or Services.

10. COOKIE

We and/or our partners use tracking technologies such as cookies on our site to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their or other service(s).

Click below to consent to the use of this technology across the web. You can change your mind and change your consent choices at any time by returning to this site. If you choose to reject the use of this technology, the only tracking technology we will use is a light cookie function to memorize your choice regarding the cookie policy.

11. CHILDREN’S POLICY

We consider a child to be anyone under the equivalent age as specified by law in your jurisdiction (“Child(ren)”). We do not knowingly seek or collect personal data from or about Children without the consent of a parent or guardian and the consent of the Child.

If we become aware that personal data that has been submitted to us relates to a Child without the consent of a parent or guardian and the consent of the Child, we will use reasonable efforts to:

• Delete that personal data from its files or make it anonymised as soon as possible.
• Ensure, where deletion and anonymization is not possible, that this personal data is not used further for any purpose, nor disclosed further to any third party.

Any parent or guardian with queries regarding our processing of personal data relating to their Child should contact us using the details at section 14 of this Policy.

12. PROTECTING YOUR PERSONAL DATA

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.

13. AMENDMENTS TO THIS POLICY

We may update this Policy from time to time on our official website to comply with legal requirements or to meet our changing business needs. Unless there are other special requirements under the applicable laws and regulations in the country where you reside, such updated Policy shall take effect after such amended Policy is posted, if you continue to use the Gogoro Products and/or Services after updates are posted, you will be deemed to have accepted the updates. We urge you to check regularly to see if there is any update or change to this Policy.

14. PRIVACY QUESTION

If you would like to exercise your privacy rights as set out in this Policy, or if you have any questions or suggestions about this Policy or our privacy and security measures, please contact us at the following e-mail address:

E-mail Address: dataprivacy@gogoro.com

We will respond to your request as soon as possible within the statutory period applicable to us.