Your personal information and how we collect it is something we take very seriously here at RatelTech Yazılım A.Ş. The policies below are applicable to data and information collected when you use the RatelTech Yazılım A.Ş. network of websites, including SCOOTABLE software (including any versions optimized for viewing on a wireless or tablet device); all email newsletters published or distributed by RatelTech Yazılım A.Ş.; all apps published by RatelTech Yazılım A.Ş., including the “Scootable” app; activate a Scootable vehicle (“Vehicle”) or use any other services made available by RatelTech Yazılım A.Ş. (“Service”) and all other interactive features and communications provided by RatelTech Yazılım A.Ş. (“App”), however accessed and/or used, that are operated by us, made available by us, or produced and maintained by us and our related companies (collectively “Scootable” or “we”, “us”, or “our”). We have established this privacy policy (“Privacy Policy”) to let you know the kinds of personal information we may gather during your use of this App, why we gather your information, what we use your personal information for, when we might disclose your personal information, and how you can manage your personal information.

Please be advised that the practices described in this Privacy Policy apply to information gathered online through our App, through our websites and otherwise by our customer service personnel. It does not apply to information that you may submit to organizations to which we may link or who may link to us or information that we may receive about you from other organizations.

By using our App, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the App. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of our App following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to personal information already in our possession, we will provide you with notice of the modifications or amendments.

If you have any questions about this Privacy Policy or don’t see your concerns addressed here, you should contact us by email at [email protected]

WHAT INFORMATION ABOUT ME IS COLLECTED AND STORED?

We collect two basic types of information from you in conjunction with your use of the App, personal information and non-personal information. Personal information is information that you supply to us, as described more fully below, i.e., when you use our Services, obtain a subscription, complete a survey, register on the App, upload content, participate in a community, or provide your email address. Personal information is any information that can individually identify you and includes, among other things, your name, email address, telephone number, postal address, credit card, billing and contact information. Non-personal information includes information that does not personally identify you, but it may include tracking and usage information about your location, demographics, use of the App and the Internet.

Personal Information

As a general matter, you can browse the App without submitting your personal information to us. However, there are a number of circumstances in which you may supply us or our agents with your personal information. The following lists the most common ways in which we may collect your personal information:

• Registration for an account on the App
• Use of the account through the App, including rental of a Vehicle
• Payment information submitted to Scootable when renting a Vehicle
• Registration for an event sponsored by Scootable
• Profile information that You provide for Your user profile
• Social media information that you authorize
• Certain location data, as described below
• Uploading Content to the App
• Submitting an application to work at Scootable
• Participation in surveys, contests, or sweepstakes

Sign up to receive alerts or other information via email, text or instant message from Scootable Request for customer service, support requests or other assistance

App related communications, e.g. account verification; technical notification

Participation in communities, commenting to blog entries and participation in other forums Submission of content or other data and information on any part of the App that permits it

Any other place on the App where you knowingly volunteer personal information Non-Personal Information

In addition, when you interact with the App, we may collect certain information that does not identify you individually and our servers may automatically keep an activity log of your use of our App (“Non-Personal Information”). Generally, we collect and store the following categories of Non-Personal Information:

Non-identifiable demographic data such as age, gender, and five digit zip code as part of collecting personal information

Device information about your computer, browser, mobile device, or other device that you use to access the App. This information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information. Analytics and usage information about your use of the App, including GPS routes, and status of GPS chips.

Device information about the Scootable Vehicle, including timestamps, battery status.

Additional “traffic data” and log files such as time of access, date of access, software crash reports, session identification number, access times, and referring App addresses.

Other information regarding your use of the App.

Collection of Your Source IP Address/Location Information

We collect and store location information about you on the App and associated with your account that you volunteer on the App or enable through the App or your device. We will collect location information regarding the location of the Scootable Vehicles, the routes taken by these Vehicles, and the rental status of these Vehicles. We will not collect any location information that you do not volunteer or enable, but you must agree to provide certain location information in order to use the Service. We also collect and store your device’s source IP address which may disclose the location of your device at the time you access the App. Collection of Personal Information From or Through Social Media Sites or Using Your Social Media Logon

When you interact with any Service Provider page or account on a social media platform, such as Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube, or Pinterest, we may collect the personal information that you make available to us on that page or account including your account ID or “handle”. However, we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such personal information that we are permitted to collect by these social media platforms. If you publish your social media profile on our Service, we may collect personal information that you make available as part of that profile.

Collection of Information From Other Sources

We also may collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify, update information contained in our records and to better customize the App for you. We may also collect Personal Information from credit reporting agencies to, for example, determine your creditworthiness, credit score, and credit usage, in accordance with applicable laws.

Collection of Personal and Non-Personal Information Through Surveys and Promotions

From time to time We may provide You with the opportunity to participate in sweepstakes or other promotions on our Service, which might be sponsored or conducted by a third party. If you participate, We will request certain personally information from You. Participation in these sweepstakes and promotions are completely voluntary and You therefore have a choice whether or not to disclose this personal information. The requested personal information typically includes contact information. If there is a third party sponsor involved please make sure to review that party’s privacy policy.

Collection of Third Party Personal Information Through Tell-A-Friend Feature

We may from time to time conduct a referral service to introduce people you know to our Apps and Service. If you choose to use our referral service to tell someone about our Apps and Service or a discount on the Apps and Service, we will ask you for your contact’s name and email address. We will automatically send your contact a one-time email inviting him or her to visit our App. We store this information for the purpose of sending this one-time email and tracking the success of our referral program. Your contact may contact us at [email protected] to request that we remove this information from our database.

Use of Cookies and Other Tracking Technologies

Like many websites and mobile applications, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use cookies to monitor traffic, improve the App and make it easier and/or relevant for your use. Like many Apps, we use cookies, web beacons and similar technologies to record your preferences, track the use of our Apps and your exposure to our advertisements. We may also use these technologies to monitor traffic, improve the Apps and make it easier and/or relevant for your use. If you delete your cookies or if you set your browser or device to decline these technologies, some features of the App may not work or may not work as designed.

We use both “session” cookies and “persistent” cookies. We do not use flash cookies, web storage, web beacons or other technology that tracks your browsing history across multiple Apps.

We use cookies for the other purposes set out below:

We use cookies to remind us who you are and to find your account information in our database when you access a Service so you do not need to log in at every visit. This helps us to provide you with service tailored to your specific needs and interests. A cookie is created when you register for a Service.

We use cookies to determine the browser the visitor uses so the Apps can be designed to work properly with the most common versions of different browsers.

We use cookies in conjunction with sending you email newsletters.

Advertisers that place ads on the App may use cookies.

We use cookies in conjunction with analysis of your use of our App and generate analytics regarding our App.

We use cookies to estimate our audience size. Your browser is given a unique cookie that helps us determine whether yours is a repeat visit or a first visit.

We also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Apps. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Apps, compile reports on the Apps’ activity, and provide other services related to Apps activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring App. The Apps do not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google visit Google Analytics site.

We may partner with third party advertising companies to better provide advertisements about our goods and services that may be of interest to you. These third party advertisers may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Apps. They may collect information about your online activities over time and across different Apps and other online services. They may use this information to provide you with interest-based advertising or other targeted content. These online advertising partners do not have access to or use your name, address, e-mail address, telephone number or other personally identifiable information from us, without your consent. They may, however, use persistent identifiers to anonymously track your Internet usage across other Apps in their networks beyond these Apps. While we restrict their further use of such information, such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us.

How Do We Use Your Information?

We use the information we learn from you to help us personalize and continually improve your experience on the App. We may use your Personal and Non-Personal Information in the following ways:

• General Uses
• To provide the Scootable Service to you as you request
• To track the Vehicles
• To upload your content to our App as you request
• To permit you to update, edit, and manage your content on our App
• To communicate with you about your account or transactions with us (including service related announcements) and send you information about features and enhancements on our App
• To communicate with you about changes to our policies
• To communicate with you about your comment to a blog post
• To personalize content and experiences on our App, including providing you reports, recommendations and feedback based on your preferences
• To disclose anonymized Personal Information, to disclose statistics and analytics and other details regarding the use of our App.
• To optimize or improve our products, services and operations
• To automatically update the App on your device
• To detect, investigate, and prevent activities that may violate our policies or be illegal
• To perform statistical, demographic, and marketing analyses of users of the App
• Use of Your Location Information

Specifically, we use your location information to:

• Track the use of the Scootable Vehicles
• Personalize content on our App, including providing you reports, recommendations and feedback based on your preferences
• Optimize or improve our products, services and operations
• Detect, investigate, and prevent activities that may violate our policies or be illegal
• Perform statistical, demographic, and marketing analyses of users of the App and their purchasing patterns

Combination of Your Personal Information

We use the information from one portion of the App on other portions of the App or elsewhere in our network of Apps, and other interactive features, or in reports and analysis, all of which are owned and operated by Scootable, and we may combine information gathered from multiple portions of the App into a single customer record or analysis or report. We also use and/or combine information that we collect off-line or we collect or receive from third party sources to enhance, expand, and check the accuracy of your customer records.

Who Do We Provide Your Information To?

Except as disclosed in this Privacy Policy, we do not disclose information about your Personal Information collected online to any companies not part of Scootable or its parent, subsidiaries or related entities. In no event will we sell or rent your Personal Information as part of a customer list or similar transaction.

Business Partners, Sponsors and Third Parties

We may share your Personal Information with our sponsors and other business partners from time to time. You may withdraw your consent to our sharing of your Personal Information with business partners and third parties at any time by following the opt- out process described below.

Third-Party Agents

We have third party agents, subsidiaries, affiliates and partners that perform functions on our behalf, such as hosting, billing, push notifications, storage, bandwidth, content management tools, analytics, customer service, fraud protection, etc. These entities have access to the Personal Information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the App.

Emergency Situations

We may also use or disclose Personal Information if required to do so by law or in the good- faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the App; (b) protect and defend our rights or property, the App or our users, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the App or the public. This includes exchanging information with other companies and organizations for fraud protection.

What Steps Are Taken To Keep Personal Information Secure?

We are concerned about ensuring the security of your Personal Information. We exercise great care in providing secure transmission of your information from your device to our servers. Personal Information collected by our App are stored in secure operating environments that are not available to the public. Our security procedures mean that we may occasionally request proof of identity before we disclose your Personal Information to you. Please understand, however, that while we try our best to safeguard your Personal Information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

How Can We Transfer Your Personal Information?

Your information collected through the App may be stored and processed in the Turkey or any other country in which Scootable, its Clients, Affiliates or service providers maintain facilities. Scootable, its Clients, Affiliates, or service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the Turkey or other regions with laws governing data collection and use that may differ from US law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. Wherever your personal information is transferred, stored, or processed by Scootable, Scootable will take reasonable steps to safeguard the privacy of your personal information. By registering for and using the App you consent to the transfer of information to the Turkey or to any other country in which Scootable, its Clients, Affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

How Long Do We Keep Your Information?

Following termination or deactivation of your account, Scootable, its Clients, Affiliates, or its service providers may retain information (including your profile information) and user Content for a commercially reasonable time for backup, archival, and/or audit purposes. If you have any questions about termination or deactivation of your account, please contact us directly at [email protected]

What Happens When I Link To or From Another App?

This App may contain links to other Apps operated by third parties. Please be advised that the practices described in this Privacy Policy for Scootable do not apply to information gathered through these other Apps. We are not responsible for the actions and privacy policies of third parties and other Apps.


Assignment

We may change our ownership or corporate Scootable while providing the App. We may also sell certain assets associated with the App. As a result, please be aware that in such event we may transfer some or all of your information to a Scootable acquiring all or part of our assets or to another Scootable with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring Scootable or the merged Scootable will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Changes to This Policy

As our App continues to develop, we may add new services and features to our App. In the event that these additions affect our Privacy Policy, this document will be updated appropriately. We will post those changes prominently so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. We do, however, recommend that you read this Privacy Policy each time you use our App in case you missed our notice of changes to the Privacy Policy. We will not, however, materially change our policies and practices to make them less protective of Personal Information we have previously collected from you without your express consent.

WHAT ARE YOUR CHOICES AND HOW DO YOU OPT-OUT?

We believe you should have choices about the collection, use and sharing of your information. Although you cannot opt-out of all data collection when you visit our Apps, you can limit the collection, use and sharing of your personally identifiable information.

Collection of Personal Information. All personally identifiable information is provided on a voluntary basis. If you do not want Scootable to collect such information, you should not submit it to the App. However, doing so will restrict your ability to access some content and use some of the functionality of the App.

Emails and Other Communications. If you would like to alter the type of communications you receive from us, including opting out of promotional communications from us, you may do so at any time by updating the communication preferences specified in your account profile through the App. Please note that this may affect your ability to access certain products and services, and we may continue to send non-promotional communications such as staffing confirmations, surveys, and other information about your use of the Service. If you refer others to us using our email functionality, please note that they may choose not to receive any promotional emails from us in the future by following the opt-out instructions in the email invitation.

Tracking. You also have choices to limit some tracking mechanisms that collect information when you use the App. Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. If you choose to decline cookies, certain features of our App, including the App themselves, may not function properly or remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.

Please note that while you may opt out of online behavioral advertising and other targeted advertising served by participating companies through App you may still see other types of advertising on the App, it just may not be as relevant or targeted to your interests.

Accessing and Correcting Your Information. If you have an account with Scootable, you may review and change your information by logging into your account and editing your profile. Be advised that we may not be able to delete your Personal Information without also deleting your user account. You will not be permitted to examine the Personal Information of any other person or entity and may be required to provide us with Personal Information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete Personal Information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.

INTERNATIONAL USERS

The information discussed in this Privacy Policy that is collected outside of the Turkey  is controlled by Scootable. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within Scootable, trusted service providers, and trusted business partners in countries other than your country of residence, including the Turkey, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If you are an EU data subject, if we provide any information about you to any such non-EEA members of our group or third party information processors, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EU and other data protection laws to govern the transfers of such data.