# Privacy Policy

Stable Micromobility, LLC (“Stable” or the “Company”) is committed to maintaining robust privacy protections for its users. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Services. Stable offers users of https://stablemobility.io (the “Website” or “Site”) information about Stable, including download links to the Stable App and links to Stable’s social media accounts, documentation, and contact details. Stable offers users access to Stable’s mobile applications available to download on Google’s Play Store and Apple’s App Store (the “App”), a community based mapping service to locate and park at camera-monitored locations for micromobility vehicles. Access to Stable’s Site or App and all information and features provided therein are collectively referred to as the “Services”.

The terms “we,” “us,” and “our” refer to the Company.

“You” refers to you, as a user of our Site, Services or App.

By accessing our Site or our Services, you accept our Privacy Policy and Terms of Use (found here: https://stablemobility.io), and you consent to our collection, storage, use and disclosure in certain circumstances of your Personal Information as described in this Privacy Policy.

# Information we collect

We want you to understand the types of information we collect as you use our Services

Stable collects information to provide better services to all its users - from logging parking so that you can quickly and easily email yourself specific information and evidence about your vehicle and how it was locked up when parked for proving an insurance claim if your vehicle is stolen, to populating the app with crowdsourced Stables to show other users camera-monitored spots to lock their vehicles at and which ones have had reported thefts, and showing you relevant ads from local businesses while using Stable. The information Stable collects, and how that information is used, depends on how you choose to use our Services and how you manage your privacy controls.

# Information you create and provide to us

Account Information: To use our App, you must first “register” an Account as a user by completing the required information. When you register, you are requested to disclose your email address, to select a Display Name, and to enter a password in order to enable the Company to grant access to use our App and Services. You will automatically be sent an email requesting that you verify your email address, which will enable you to recover your account using the “Forgot your password” feature on the Login page. False, incorrect, or out-dated information may impair Stable’s ability to provide you with the Services and to contact you when necessary.

In addition to the registration process, we collect additional information from you which enables us to offer the core Services within the App to log parking information and gather evidence which helps you successfully prove your insurance claim should your micromobility vehicle be stolen. The information that we collect from you is as follows:

• Registration of at least one micromobility vehicle, including the make and model of the vehicle
• Registration of at least one lock, including the make and model of the lock

Information that you choose to share with Stable: information that you choose to share with Stable, including a Display Name you have chosen, reports associated with your Display Name when mapping Stables, phone number, “favorites”, destinations you may travel to, search queries, and files you have uploaded to the App, including pictures of Posts and Stables, if applicable. You can also choose to add payment information to your Account, if applicable, specifically for paid services (such as Stable+ membership).

Communication which you choose to conduct through the Stable Services: We may collect information when you exchange communication with Stable, for example, if you submit a request, contact Stable’s support team at hello@stablemobility.io, discuss Stable Services in our Discord Server, or report a violation to Stable.

# Information we collect about you as you use our services

We collect information about your activity in the Services, which we use to provide you with the Services of Stable, including features which are meant to personalize your experience. This includes places where you’ve parked, Stables you’ve mapped, and buildings you’ve added that allow or don’t allow micromobility vehicles inside. None of your location information will be displayed to other users of the app. The activity information we collect may include:

• Detailed location information: Location is collected in the form of GPS signals (combined with a time-stamp), IP address and other information from sensors and receivers on or around your device,on which the App is installed and activated. This location information is saved to our backend as a history of all of the Stables you’ve mapped or logged parking at while using the App, including the most recent logged parking for quick access to file a theft and recover evidence. The types of location data we collect depends in part on your device and account settings;
• Terms or venues you searched;
• Your views and interactions with content and ads; and/or
• Browser information - Information that is automatically collected via analytics systems providers from your browser, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

# Metadata (information about your device, browser, and app use)

We may obtain information about the use of Services and information from the device you have Stable installed on or the browser from which you use our Services. For example:

• Stable may collect and record how often you use our Services and for how long, your device type, unique identifiers, operating system type and version, battery usage, the third party web pages or applications you visit or use or interact with via the App, information that you viewed on our Services, advertisements that are shown to you or that you view or click on, the fact that you used the Services to communicate with other users and the fact that you used third parties application/services via Stable to communicate with third parties, and the duration of such communications, (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; the Internet Protocol (IP) address and the name of the domain that serves you to access the Services, and the geographic location of the device that you are using to login and use Stable on.

# Why Stable collects data

Stable may use information collected from or provided by you for the following purposes:

# Provide our services

We use your information to deliver our services. For example:

• Use your location and/or search query history to show you mapped Stables or Posts that you can park at, provide information about sites, shops and other places and attractions in your close vicinity; and
• To provide advertising services, including personalized ads.
• To share your Stables or Posts you've mapped with other users of the Services.

# Maintain and improve our services

We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues you report to us. And we use your information to improve the service or to develop new features or services. For example, Stable may use your location information to improve the accuracy of its mapped Stables data.

# Provide personalized services, including content and ads

• We use the information we collect to operate the Services and to customize your experience with the Services. Based on your past activity on the Services we may also suggest to you common Stables where you use the app to log parking at.
• We may also use the information to provide you with support and handle requests and complaints.
• Depending on your settings, we may also show you personalized ads based on your interests and past activity.

# Measure performance

We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your usage of the Services to do things like optimize product design. We also use the data we collected about the ads you view or interact with (e.g. click on) to help advertisers understand the performance of their ad campaigns and to provide them with aggregated reports. We may also use data to measure the usability and effectiveness of Stable’s own marketing efforts on third party sites or platforms.

# Communicate with you

• We also use your information to send you updates, notices, announcements, users’ requests and additional information related to the Services (including through push notifications, email address and SMS);
• We may also use your information to conduct surveys and questionnaires; And if you contact Stable we may keep a record of your request in order to help solve any issues you might be facing.
• Subject to your prior indication of consent (to the extent required under applicable law), we may also use the email address that you provided to send you promotional and/or marketing materials. At any time you may choose not to receive such materials by clicking on the “Unsubscribe” link in the email messages that we may send to you. In any case, Stable will not share your contact details with any advertiser, unless explicitly permitted or required by law

# To protect Stable, our users, the public, and for legal reasons

We may also use and process your information and content, using different technologies to the following purposes:

• To enforce the Terms of Use or Privacy Policy;
• To contact you when Stable believes it to be necessary;
• To comply with any applicable law and assist law enforcement agencies under any applicable law, when Stable has a good faith belief that Stable’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
• To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
• To handle breakdowns and malfunctions;
• To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services;
• For purposes provided under this Privacy Policy and Terms of Use;
• To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm Stable, our users, or the public; and
• To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does Stable use aggregated information”, below.

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

# Sharing your information

# Personal information that you share

The Services are based on a community of users publicly sharing information with Stable and with other members of that community.

In particular, users may choose to share personal information such as Display Name shown on Stables they’ve mapped to other users.

You can decide whether or not to upload content to the Services. However any content that you choose to share and submit for posting is neither private nor confidential and you should expect that it may be made public and known to others. Information you choose to upload will be posted for other users to see, however, you may select whether you wish your Display Name to be shown with the uploaded information. For example, your mapped Stables will be posted on the Stable map along with your Display Name if it is enabled. If you choose to not show your Display Name, the Stables you’ve mapped will show that they were uploaded by “anonymous”. You should note that pictures you submit may sometimes contain additional sensitive information in the frame, such as names of businesses, reflections which may contain your image, bystanders in the image, and any other extra information that is not necessary for a Stable to be mapped. Therefore, you must exercise caution and common sense when submitting information. At the very least you should demonstrate the same degree of caution as when publishing personal information by means other than the Internet and cellular services.

In any event, your email address will not be visible to others through any Stables or Posts that you map, and your information will never be shared to the App users when you Log Parking.

We, at Stable, take great measures to provide you with the best experience you can have while using the Services. However, Stable has no control over the conduct of any user and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.

Participating in any user’s activities as a result, directly or indirectly, from using Stable, is entirely at your own risk. Stable is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.

# When Stable shares your information

Stable does not sell, rent or lease your personal information to third parties.

Stable will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in Stable’s good-faith discretion:

• As necessary for the facilitation and operation of the Services. For example, making public vehicle thefts you report and which are associated with a Stable you log parking at or which you’ve mapped, which may show the location;
• If Stable reasonably believes that you have breached the Terms of Use or is investigating potential breach of the Terms of Use, or believes that you abused your rights to use the Services, or performed any act or omission that Stable reasonably believes to be violating any applicable law, rules, or regulations. Stable may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing;
• If Stable is required, or reasonably believes that it is required by law to share or disclose your information;
• In any case of dispute, or legal proceeding of any kind between you and Stable, or between you and other users with respect to, or in relation with the Services;
• In any case where Stable reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of Stable, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property;
• To detect, prevent, or otherwise address fraud, security, or technical issues;
• If Stable organizes the operation of the Services within a different framework, or through another legal structure or entity, or if Stable is acquired by, or merged into or with another entity, or if Stable enters bankruptcy, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;
• To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to Stable, as reasonable for business purposes, which may be located in the European Union and the U.S.A., potentially countries outside of your jurisdiction;
• Stable may also share personal information with companies or organizations connected or affiliated with Stable, such as subsidiaries, sister-companies and parent companies;
• We work with other Google services for advertising and ad measurement purposes. In order to help advertisers decide what ads to show on Stable, Google, and websites & apps that partner with Google, we may share information with these services, such as a unique identifier for advertising (i.e, Advertising ID available on Android mobile devices or similar technologies). You can learn more about how Google uses information from sites or apps that use its services and how you can control that in this page.
• We may work with selected advertising and measurement services which help us understand how our users interact with ads served in our platform and in order to provide marketing, advertising and measurement services for Stable with respect to Stable’s own marketing efforts, by using and sharing devices’ identifiers (i.e, Advertising ID, cookies or similar technologies).
• Personal information may also be shared with Stable’s trusted partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer services

# Visibility

Please note that your Display Name and some other information may be visible to others. Note that your Display Name may be included along with any information you submit for mapping Stables if enabled. If enabled, it will therefore be visible to others.

If you prefer to remain invisible on the Stable map, you can set the Stable App to not show your Display Name on Stables you’ve mapped. To do so you should go to the Privacy Settings under your User Profile and adjust accordingly by switching on “Hide my display name”. If you make this choice, while you will be ‘invisible’ on Stables you’ve mapped to other users, your location information will continue to be collected by Stable for the purposes listed in this Privacy Policy

# Controlling your personal information

You can always review and update certain information by visiting your Account settings (such as your phone, display name, photo and more). If you become a Stable+ Member, you can review and update your information through the Stable+ Membership settings.

If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up an Account and impair the ability to provide you with Services

# Privacy controls

Your in-app Privacy Settings provide you with quick access to settings and tools that let you safeguard your data and decide how your information can make Stable services work better for you. For example, you can control your visibility on the Stables you’ve mapped.

There are other ways to control the information Stable collects whether or not you’re signed in to a Stable Account, including device-level settings: your device may have controls that determine what information we collect. For example, you can modify location settings on your device.

# Deleting your information

If you would like us to delete your Account, email us at accounts@stablemobility.io. On receiving such a request, Stable will use reasonable efforts to delete such information, however please note that information may not be deleted immediately from our back-up systems. We aim to initiate the deletion process immediately after your request. Once we receive your request, your data will no longer be used to personalize your Stable experience. We then begin a process designed to safely and completely delete the data from our storage systems. This process may take time to process. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and time frames defined in this policy. We maintain systems designed to detect and remediate such issues.

# How Stable retains data we collect

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.

• Information retained until you remove it - such as your favorites, email address and other account related information. We’ll keep this data in your Stable Account until you choose to remove it and/or update it.
• Data that expires after a specific period of time - in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. We may also take steps to anonymize certain data within set time periods.
• Information retained until your Stable Account is deleted - we may keep some data for the life of your Stable Account if it’s useful for helping us understand how users interact with our features and how we can improve our services. For example, if you made a theft report, we will keep information about reports you have submitted available for other users to view when they search for Stables to park at, even after your account is deleted. When you delete yourStable Account, the specific information about reports you have submitted is removed, but not the record of theft reports shown at a particular Stable, as that is an important feature of the Stable App.
• Information retained for extended time periods for limited purposes - sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when Stable processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include:
  • Security, fraud & abuse prevention
  • Financial record-keeping
  • Complying with legal or regulatory requirements
  • Ensuring the continuity of our services
  • Direct communications with Stable

# How does Stable use aggregated information?

Stable may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).

Stable may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to cities in an aggregated and/or anonymous form to help improve the infrastructure, particularly to add bike lanes and enclosed and secure parking facilities. The same information may be used for aggregated ads analysis to be potentially provided to advertisers.

# Cookies

Stable may use cookies and similar technologies on the Services. Cookies are packets of information sent by the Website’s servers to your web browser and then sent back by the browser each time it accesses the Website’s servers.

Stable may use cookies for various purposes, such as to save you the need to re-enter your email address and password each time you log in, to facilitate the use of the Website, to collect statistical information, to verify information, and to customize the Website to your personal preferences and for information security purposes.

Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof

# Information security

Stable considers information security to be a top priority. Stable services are built with strong security features that continuously protect your information. Stable implements systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to Stable employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.

However, these measures are unable to provide absolute assurance. Therefore, although Stable takes great efforts to protect your personal information, Stable cannot guarantee and you cannot reasonably expect that Stable’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse

# Compliance and cooperation with regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

# Data transfers

We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

# California requirement

The California Consumer Privacy Act (CCPA) requires specific disclosures for California residents. This Privacy Policy is designed to help you understand how Stable handles your information:

• We explain the categories of information Stable collects and the sources of that information in Information we Collect
• We explain how Stable uses information in Why Stable collects data.
• We explain when Stable may share information in Sharing your information. Stable does not sell your personal information.

The CCPA also provides the right to request information about how Stable collects, uses, and discloses your personal information. And it gives you the right to access your information and request that Stable delete that information. Finally, the CCPA provides the right to not be discriminated against for exercising your privacy rights.

We describe the choices you have to manage your privacy and data in Controlling your personal information section. You can exercise your rights by using these controls, which allow you to access, review, update and delete your information, as well as export and download a copy of it. You can send us an email to request to Download your data archive. If you have questions or requests related to your rights under the CCPA, you (or your authorized agent) can also contact Stable at hello@stablemobility.io. The CCPA requires a description of data practices using specific categories.

# Changes to this Privacy Policy

Stable may from time to time change the terms of this Privacy Policy. Substantial changes will take effect 30 days after Stable has posted a:

• System message to users notifying them of changes to the Privacy Policy; and
• Notification on the Website’s homepage or any other relevant web pages, explaining the changes to the Privacy Policy alongside a comparison of the “old” and “new” versions of the Privacy Policy.

Other changes will take effect 7 days after their initial posting on the Website. However, if Stable amends this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the Services

# Questions about this Privacy Policy

If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to hello@stablemobility.io.