Effective: July 1, 2019

 

At Newt and our family of companies (collectively “Newt,” “we,” “us,” or “our”) we are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your information. This Privacy Policy (“Privacy Policy”) describes how Newt handles information in connection with Newt’s websites and related mobile applications and services (collectively, the “Services”), and when you otherwise interact with us.

Please also read our Terms of Service which set out the terms governing the Services.

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We reserve the right to change this Privacy Policy from time to time. If Newt makes changes to this Privacy Policy, the updated Privacy Policy will be made available through our Services and if we make any material changes to this Privacy Policy, we will provide a prominent notice and may also contact you directly by email or another method.

 

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The Types of Information We Collect

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We collect or receive information in different ways. The types of information we collect or receive depends on how you use and interact with our Services. In many cases, you can choose the  information you provide to us, although certain information is required for us to provide the Services. We use and disclose this information for the purposes described further below. The types of information we collect include:

 

• Account Information such as your name, e-mail address, telephone number and payment information such as your credit card details. In order to use certain products, we may also require you to provide a copy of your driving license. 

• We collect and process location data when you sign up and use the Services. For example, to show you Newt scooters near your location, it is necessary to collect and record the physical location of your device. Data such as the location of the scooter, the routes taken by the scooter, and its rental status are also necessary to provide the Services. Newt also collects location data directly from Newt scooters including when a Newt user is riding, such as journey information.

• If you link, connect, or login to Newt with a third party service (e.g. Facebook), the third party service may send us information such as your profile information or friends list from that service.

• When you ask for customer service, support or other assistance, you can choose to provide us with your contact information so we can better respond to your requests and we may keep information about your engagement with our support services.

• Newt collects information from your browser, computer, or mobile device, which provides us with technical information such as your device’s source IP address and when you access or use the Services. We use cookies and similar technologies (like pixels and tags) to provide our Services, including to remember your settings and to gather analytics information about you.

• We collect information you share on the Services such as when you participate in communities or other forums, or comment on blog entries. Depending on your camera or photo settings, Newt will receive information you choose to send us such as photos of parked Newt scooters.

• We receive information about you when we use third party partners such as marketing and advertising partners.

• To help you introduce people to our Services, you can choose to use our referral service to tell a friend about our Services for a discount. When you choose to use our referral service we will ask for your contact’s name and email address and automatically send your contact a one-time email on your behalf inviting him or her to use our Services.

 

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How We Use Information

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We use your information, including information about your location, to:

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• provide the Services to you at your request including to manage your account and ride history;

• monitor, track and service the Newt scooters, including when they are in use by you;

• process payments or subscriptions and any discounts or special offers such as free unlocks;

• communicate with you about your account, interactions or transactions including service- related announcements such as changes to our policies. As allowed by local law, we may also send to you surveys or marketing communications, including information about features and enhancements to our Services;

• optimize, develop and improve our Services. To do this we may use third party analytics providers to understand how the Service is being used and to help us to improve the Services;

• where necessary, to comply with our legal obligations including to meet regulatory or local law requirements;

• detect, investigate, and prevent activities that may violate Newt’s policies or Terms of Service or be illegal which may include sharing information with government agencies outside of your home country, such as law enforcement agencies;

• collaborate with third parties such as universities and local government authorities, as described below in the “Who Do We Share Your Information With?” section.

 

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Who Do We Share Your Information With?

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We share your information with Newt’s affiliated companies, our service providers, other third parties where it is necessary to perform the Terms of Service and as described in this Privacy Policy. In particular we share your information with:

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• Our service providers and partners: We share your information with our trusted service providers and partners who provide services to Newt such as hosting data and our infrastructure, processing payments and donations, supporting and improving the Services, performing customer service, or providing marketing and advertising services. For example, we share information with credit card issuers in order to process your payments and refunds.

• Collaborations with third parties: After removing certain identifiers, such as your name, phone, and e-mail address (where provided), and combining the resulting information with similar information from other users, Newt may use, sell, license, and share your information, including individual trip records and trip location (journey) history, with third parties for research, business or other purposes. For example, Newt partners with universities and local government authorities to collaborate on research projects such as understanding traffic and travel patterns in a city. 

• Government, regulatory and law enforcement agencies: We may share your information if we believe in good faith that it is reasonably necessary to do so for legal reasons, including to meet federal, state, regulatory or local law requirements or as part of a judicial process or to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues or to prevent harm or injury to you, members of the public, our staff, other third parties, or ourselves; or if we need to do so to defend our legal rights or property, to take action regarding illegal activities or traffic offenses, or to enforce our contracts, such as our Terms of Service.

• Newt affiliates: We may share your information with Newt affiliate companies to help provide, maintain and improve the Services. As we grow, we may expand our corporate family by establishing local subsidiaries or other affiliates as needed, to help us provide or market the Services.

• Business reorganization: We may also share your information as part of a sale, merger, change in control, or in preparation for any of these events.

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We may also share aggregated, depersonalized, or de-identified information that cannot reasonably be used to identify you with third parties, including the types of third parties listed above.

 

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How Long We Keep Information

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We keep your information for as long as is reasonably necessary to provide the Services to you or until your account is deleted, whichever is longer, subject to any longer period as may be required by applicable law or notified to you.

We may ask for a copy of your driver license before you can use certain Newt Services. When we ask for a copy of your driver’s license, we might conduct verification checks to ensure the license is valid and we retain only limited verification information in order for you to use the Services.

When you delete your account, it may take us additional time to fully delete your information from our databases and system logs. We may also retain information from deleted accounts to prevent fraud, collect fees, enforce the Terms of Service, to comply with our legal obligations or enforce our legal rights.