Effective Date: 2020/5/20

We, Gogoro Taiwan Limited, a company incorporated in Taiwan (company registration number: 53433060) with its head office located at No. 33, Dinghu Road, Guishan District, Taoyuan City, Taiwan (“we” or “Gogoro”), respect and are committed to protecting your privacy and personal data.  In this Privacy Policy (the “Policy”), we explain how we, as data controller, handle your personal data when you register for a Eeyo™ account (the “Account”) or access our mobile application and/or our web site in order to use the Eeyo™ Service.  Please read this Policy carefully before you register with us. If you accept the provisions of this Policy, you are agreeing to us processing your personal data in the ways that are set out in this Policy.

1.     Who We Are:

Gogoro Taiwan Limited is a company with its head office located at No. 33, Dinghu Road, Guishan District, Taoyuan City, Taiwan.  We are a high-tech company providing our customers and members with cutting-edge, energy saving, environmentally friendly and sustainable transportation vehicles and services. 

Our representative in the European Union for the purposes of the General Data Protection Regulation 679/2016 (the “GDPR”), if applicable, is Gogoro Europe B.V. (NL).

2.     What Personal Data We Collect and Process:

When you register for the Account and during the course of your using the Eeyo™ Service, we will collect and process the following personal data which relates to you:

• Identification Data: first name, last name, gender, age, birthday, and Account name and passwords.
• Contact Details: e-mail addresses, mobile phone number, and postal addresses.
• Physical Attributes: height, weight and heartbeat.
• Gogoro EeyoTM and Device Information: 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.
• Riding Information: distance, duration, location, speed, RPM, kcal, time, pedal cadence, input torque, output torque, and regen status.
• Payment Information: information to make your payment to us either by credit card or other electronic payment methods.
• Automatically Collected Information: certain information may be automatically collected by us when you use our Services, such as your Internet protocol (IP) address, device and advertising identifiers, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, information about the links you click and pages you view within the Services, and other standard server log information.

3.     Why We Process Your Personal Data and the Lawful Bases for Such Processing:

We collect and use your personal data for the following purposes based on the following lawful bases:

• To provide the Eeyo™ Service: We collect and process your personal data in order to provide you with the Eeyo™ Service, including informing you of updates to the Eeyo™ Service. We conduct this processing of your personal data to perform our contract with you as described in the Eeyo™ Terms of Use, on registration, or otherwise as notified by us to you from time-to-time. 
• To provide aspects of the Eeyo™ Service: Where you provide your explicit consent, we will also process information about your physical attributes or location. 
• To manage your account with us and perform our internal administrative work: We will process your personal data for our user account management purposes, including to facilitate and improve our provision of the Eeyo™ Service to you, to establish and maintain your Account, as well as to ensure the security and proper functioning of your Account, of our website and of the Eeyo™ mobile application, including for the purposes of fraud prevention. 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 contract with you, for our legitimate interests, or for our compliance with applicable laws and regulations. 
• To send you event invitations and other marketing information: With your consent, we will send you invitations to events that we host, co-host, or sponsor, and other marketing information. 
• To host or co-host events: If you choose to register for an event that we host or co-host, we will use your personal data for the purpose of organizing and holding the event, based on your consent or our legitimate interests. 
• To collect payments:  If you provide us with financial information, we process your information to verify such information and to collect payments to the extent necessary to complete a transaction and perform our contract with you. 
• To fulfil legal obligations: We process your personal data when we cooperate with public, governmental or regulatory authorities based on our legal obligations under applicable laws. 
• To defend ourselves against legal claims: Where we are required to participate in any litigation which affects our business, we will 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.

4.     How We Process Your Personal Data:

We will process your personal data manually and using our IT systems.  Where you provide your explicit consent, we will use artificial intelligence technology and algorithms to analyze the data that we collect in order to facilitate your cycling activities.  The artificial intelligence technology will create a profile for you and analyze your biking activities through the personal data we collect from you, in order to determine the proper power to facilitate your biking activities.  For example, the output of the riding power from the Gogoro EeyoTM will 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 will also provide you with the weather or battery forecast by analyzing your location data.

5.     How Your Personal Data are Collected:

We will collect your personal data directly from you when you sign up for the Account and during the course of our interaction with you and your use of the Eeyo™ Service.

6.     To Whom We Will Disclose Your Personal Data:

 We will not share your personal data with others, except when:

• we share your personal data with our group companies or our vendors, suppliers, or service providers for purposes related to our performance of the Eeyo™ Service, management of your Account or as otherwise required to manage our business;
• we are required to do so under applicable laws, for example, where we are required to share your personal data with law enforcement agencies, courts, other government authorities or other third parties 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;
• during the course of business restructuring or similar circumstances (for example, where our business is subject to an acquisition, merger or financing) to the extent necessary to facilitate the restructuring; or
• we work with an outsourced service provider, such as data analysts, IT managed service providers, event service provider or co-host.
• We use outsourced service providers to assist us with the following:
• Analytics: to monitor and analyse user traffic, to assess the popularity of specific functions and to keep track of your behavior when using the Eeyo™ Service, including for marketing and advertising purposes over time and across different services and devices.
• Infrastructure monitoring: to monitor the use and behavior of Eeyo™ Service components for performance assessment, maintenance and troubleshooting purposes.
• Hosting and backend infrastructure: to host data that enables the Eeyo™ Service to function.
• Payments: to provide us with the infrastructure and services through which the payment transaction may be completed.
• Event service providers: which manage events on our behalf.

7.     Transfer of Data

In providing the Eeyo™ Service, managing your Account and otherwise in managing our business we may transfer your personal data outside of the EU, including to the recipients described in section 6. 

Where we transfer your personal data to countries outside of the European Union 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.

We 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 15 of this Policy.

For your information, please note that the Taiwan government is in the process of applying for an adequacy decision from the European Union. As a result, we need your explicit consent of this Policy before you register for the Account to transfer your personal data to Taiwan

8.     How Long We Retain Your Personal Data

We will retain your personal data for as long as it is needed in order for us to provide the Eeyo™ Service to you or as otherwise necessary for the purposes set out in this Policy.

For example, we will retain your personal data until you choose to delete your Account, however we may continue to retain your Contact Details for a period in order to defend ourselves against legal claims or to comply with applicable laws and regulations.

We will delete your personal data once the relevant retention period expires.

For more information on the retention periods applicable to the data collected, please contact us using the details at section 15 of this Policy.

9.     Use of your Physical Attributes information

For certain Eeyo™ Service, we would need to process your physical attributes information, such as information relating to height, weight and heartbeat.  As a result, we need your explicit consent of this Policy to process this kind of personal information in the manner described in section 4, 5, 6 ,7 and 8 of this Policy before you register for the Account.

10.  Your Rights over Your Personal Data

Under European data protection laws, you have the following rights in relation to your personal data.  To exercise these rights, please contact us using the details at section 15 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 make any required corrections to it. 
• Right to delete: You may have your personal data erased/deleted from our database 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 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: 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. 
• 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 laws or 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 are subject to the requirements and conditions provided by the applicable law, and in particular the GDPR.  We may not be in a position to action certain of your requests, for example, where to do so would impede a criminal investigation.

If you reside in France, you also have the right to provide instructions on the handling of your personal data after your death.

11.  Consequences of Not Providing Personal Data to Us

If you do not provide us with your personal data which are required for the registration of the Account, we will not be able to provide you with the Eeyo™ Service. If you register for an Account 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 services.  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 the Eeyo™ Service.

12.  Cookies Policy

We and our partners use tracking technologies such as cookies on our web 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 services.

We reserve the right to make changes to this Cookies Policy, which is hereby incorporated as part of the Eeyo™ Privacy Policy, at any time and for any reason.  We will alert you about any changes by updating the “last updated” date of the Eeyo™ Privacy Policy.  Any changes will become effective immediately upon posting the updated policy on our web site and you waive the right to receive specific notices of each such change.  You are encouraged to periodically review this Cookies Policy to stay informed of updates.  You will be deemed to have accepted the changes by your continued use of our web site after the change is posted.

By agreeing to this Eeyo™ Privacy Policy, you hereby consent to the use of this technology across the web.  You can change your mind and change your consent choices at any time by altering the settings within your browser settings. If you choose to reject the use of this technology, the only tracking technology we will use is a very small cookie to memorize your choice regarding the cookie policy.

13.  California Users

During the preceding twelve (12) months, Gogoro has collected, used, and shared the categories of personal information described above in this Policy.  For example, depending on the services 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.

We do not, and will not without your consent, sell your personal information to third parties.  We do disclose personal information for business purposes, including but not limited to services performed on our behalf, to provide advertising on the Eeyo™ Service and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”), and to protect against fraud and malicious activity. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through the Eeyo™ Service.  The information practices of these third parties are not covered by this Policy.

California residents may request access to, deletion, and portability of their personal information in accordance with applicable law by contacting us as set forth in section 15 of this Policy.  We will not discriminate against you for exercising your rights, although some of the functionality and features on the Eeyo™ Service may change or no longer be available to you. Any differences in the Eeyo™ Service are related to the value provided. 

Once we receive your request, we may verify it through your Account 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.

14.  Amendments to this Policy

We will update this Policy from time to time on both our web site and the Eeyo™ mobile application. We will inform you with reasonable notice by e-mail or by notification through the Eeyo™ mobile application and/or our web site in the event of any material change to this Policy.  Such updated Policy shall take effect thirty (30) days after such amended Policy is posted on our web site or the Eeyo™ mobile application or otherwise notified to you.

15.  Contact Us

If you would like to exercise your rights as set out in section 10 of this Policy, or if you have any questions or suggestions about this Policy, please contact us at the following e-mail/postal address:

E-mail Address: contact@gogoro.com

Postal Address: No. 33, Dinghu Road, Guishan District, Taoyuan City, Taiwan

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