Privacy Policy

I. OUR PRIVACY PRACTICES

This Notice describes Cowboy's practices with respect to your personal information, including personal information you provide or we collect when you interact with our Site. References in this Notice to “we,” “us,” or “our,” are references to Cowboy Inc., unless otherwise indicated. This Notice only applies to our customers in the United States. Use of our international websites are subject to their respective data protection notices or policies.

Please read this Notice carefully. When you use the Site, you agree to the use of your personal information by Cowboy as outlined in this Notice.

This Notice is subject to change at any time, including in response to changes in law or to ensure its accuracy. If we make changes, the revised notice will be posted or transmitted to you. Please check for revisions to this Notice frequently, especially before you provide us with Personal Information. Use of the Site after this Notice is updated indicates your acknowledgment and consent to the revised Policy.

Our products are not directed to consumers under the age of 18. No one under the age of 18 may provide any Personal Information to or on the Site. If you are under 18, do not use or provide any information on the Site, make any purchases through the Site, use any of the features of the Site or provide any information about yourself to us. We will delete that information and associated account if we learn personal information from a child under 18 has been provided to us or on the Site. If you believe we might have any information from or about a child under 18, please contact us at hello@cowboy.com, and we will work promptly to remove the data from our system.

II. WHAT PERSONAL INFORMATION WE COLLECT?

The chart below describes the categories of personal information (“Personal Information”) we collect. Please note the chart below lists the types of Personal Information we collect in each category based on relevant state laws. To request specific information about your Personal Information, please see “How Do You Exercise Your Rights?” below. Personal Information does not include publicly available information from government records and de-identified or aggregated consumer information (i.e. information that does not specifically identify you).

III. WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect your Personal Information directly from you when you purchase a Cowboy product or service, enroll in a Cowboy program, including a test ride or mobile repair, or when you interact with us on our Site. We may also receive some of your Personal Information from third party sources, such as when someone you know registers your email address for you to receive special promotions from us (e.g., through our “Referral Program”) or when you register to test drive e-bikes with one of our partners.

IV. HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the above categories of data for the following purposes:

• To remember your choices and manage your account.

• To answer and manage your requests (e.g., when you request information, subscribe to our newsletter, file a complaint, or process privacy requests).

• To manage your account, e-bike and other purchases. This includes to book a test ride, purchase theft insurance, or enroll you in Cowboy Mobile service; process your payment, facilitate delivery, or arrange repairs; processing of your name/e-mail/bike reference/private key in order to activate your personal Cowboy account and to start/stop the bike; identifying the location of your bike in order to allow you to track and record the duration/distance/speed of the rides with your bike; to provide bike maintenance and repair service, and to process returns; and to identify the location of your bike to support retrieval functionality.

• To compile a profile of you and your use of your bike. This profiling has no effect on you, except to the extent that it allows you to benefit from improvements we make to our Site, products and services.

• To send you direct marketing communications of our and our partners' products/services, based upon your preferences, interests, and profile.

• To address our compliance and legal obligations, and exercise our legal rights.

• To anonymize the Personal Information to conduct further research and development of our products and services (e.g., statistics about sales, market analysis, and statistics about the users and use of our products and services).

• In connection with a proposed sale, merger, or reorganization of our business, or part of it.

V. HOW DO WE SHARE YOUR PERSONAL INFORMATION?

We do not sell, trade, or rent your Personal Information.

We share the Personal Information that we collect with the following categories of recipients:

In particular, during each 12 month period of operation, Cowboy has shared or plans to share the above categories of Personal Information for a business purpose.

VI. WHAT ARE YOUR RIGHTS AND CHOICES?

You may exercise the following rights and choices with regard to our use of your Personal Information:

VII. HOW DO YOU EXERCISE YOUR RIGHTS?

Contacting Us. If you would like to exercise any of these rights provided under applicable law or under this Notice, you can contact us at: hello@cowboy.com, or use our mobile app. Only you or an authorized agent acting on your behalf may make a request related to your Personal Information rights. To enable us to verify your identity (and if applicable, your agent's authority to make the request on your behalf) and process your request, you must:

• Provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent acting on your behalf; and

• If you have an authorized agent make a request, provide sufficient information that allows us to verify that the agent is your authorized representative.

Identity Verification. During the verification process, we will initially try to match the information you provided against information known to us. If we need additional information, we may contact you or your authorized agent by email or telephone number to obtain sufficient information that allows us to reasonably verify you are the person about whom we have collected Personal Information. We will be unable to fulfill your request if we cannot verify your identity or sufficiently differentiate you from another customer, or cannot confirm an agent's authority to act on your behalf.

Response timing and formatting. We will try to respond to you verifiable consumer request within 45 days after we receive it. If we reasonably require more time (up to 45 additional days) to respond to your request, we will notify you in writing via email of the extension and the reason for the extension within 45 days after we receive your initial request.

Any disclosure we provide to you will cover the 12-month period preceding our receipt of your verifiable consumer request. We will provide this disclosure to you in writing through your Cowboy account, or if you do not maintain a Cowboy account (we will never require you to make an account for the purposes of exercising your right to know or your right to deletion), we will provide the requested disclosure to you through mail or email.

Fees. We will not charge you a fee to process and respond to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If we determine your request warrants a fee, before completing your request, we will inform you of why we made that decision and provide you with a cost.

Opting out of marketing communications. You may choose to provide us with your email address to allow us to send you marketing materials, including our newsletter and promotional offers. You can stop receiving promotional emails by following the unsubscribe instructions in the email you receive. If you decide not to receive promotional emails, we may still send you service-related communications.

Do not track signals. Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we do not respond to Do-Not-Track browser settings or signals at this time. For information about Do Not Track, visit www.allaboutdnt.org.

Third-party marketing. California Civil Code sections 1798.83-1798.84 (the Shine the Light Act) entitles California residents to request disclosure regarding Personal Information sharing with affiliates and/or third parties for marketing purposes. If you are a California resident and you would like to request a copy of this notice, please contact us at hello@cowboy.com with the subject line “Request for California Privacy Information” or write us at hello@cowboy.com.

Unauthorized Use. If you become aware of any unauthorized submission of information to us, including children's information, please inform us using the contact information listed below so that we may delete it.

VIII. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

For Personal Information that we collect and process for the purposes described above, we typically retain such Personal Information for so long as it is necessary to fulfill the purposes outlined in this Notice and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.

IX. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

The security of your Personal Information is important to us. We use reasonable and appropriate technical, physical, and organizational or administrative security measures to protect your Personal Information from accidental or unlawful disclosure or access, taking into account the state of the art, costs of implementation, and risk. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. As a result, while we will strive to protect your Personal Information, we cannot and do not guarantee or warrant the absolute security of any of your Personal Information. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. We will not be and are not liable for disclosures of your Personal Information due to errors in transmission, networks that we do not control, or unauthorized acts of third parties.

X. HOW SHOULD YOU CONTACT US WITH QUESTIONS?

If you have any questions about this Notice, the practices on our Site, your dealings with our Site, or otherwise, or wish to exercise your rights or choices under this Notice or rights under applicable law with respect to our processing of your Personal Information, you may contact us at the following addresses:

45 Pleasant Street Unit 1, Newburyport, 01950, MA

or send us an email at hello@cowboy.com.