Privacy

Privacy

Also Customer Privacy Notice

Updated June 2026

Your privacy is and will always be enormously important to us. This Privacy Notice is designed to provide transparency into our data practices in a format that is easy to read and navigate. Please read the sections below to understand how Also, Inc. (“Also”, “we”, “us”, or “our”) collects, uses, shares, and safeguards your information in order to offer you the most seamless connected micro‑mobility experience imaginable.

This Notice applies to personal data we process in connection with our connected electric bicycles and other micro‑mobility vehicles (“Vehicles”), the Also mobile application (the “Also App”), our websites (including ridealso.com), firmware and over‑the‑air updates, cloud services, customer support and service operations, retail experiences and events, and any related offerings (collectively, the “Services”).

This Notice also includes additional disclosures for residents of the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland (together, “Europe”) under the General Data Protection Regulation (“GDPR”) and for California residents under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”).

Privacy From the Start

Also Vehicles are connected devices that generate ride, diagnostic, connectivity, and battery information. We build our products to be privacy‑conscious by default. Where feasible, we implement privacy‑preserving techniques such as data minimization, encryption, access controls, and logical separation between (a) operational data used to keep your Vehicle working and (b) information that directly identifies you.

Also Vehicles currently do not include cameras or microphones. We therefore do not capture continuous audio or video recordings. If future Vehicle models introduce cameras, microphones, or similar sensors, we will provide prominent notice, additional controls, and update this Notice.

Some features rely on connectivity and telemetry (for example, remote lock/unlock, theft recovery, ride history, diagnostics, and over‑the‑air updates). You are in control through app settings, device permissions, and account preferences. In certain cases, you may also request that we deactivate connectivity for your Vehicle, subject to the limitations described in the section “Opting Out of Connectivity & Telemetry.”

Topics in This Notice

  • Information We May Collect
  • How We May Use Your Information
  • Sharing Your Information
  • Choice and Transparency
  • California Privacy Disclosure (CCPA/CPRA)
  • Europe (GDPR) Disclosure
  • Protection of Personal Data
  • International Transfers
  • Updates to This Notice
  • Privacy Questions

Information We May Collect

We may collect three main types of information related to you or your use of our products and services:

  • Information from or about you
  • Information from or about your Also Vehicle
  • Information from or about your Also App and digital interactions

Depending on the products and services you request, own, or use, not all of the data types described below will apply to you.

When You Interact With Us Before Purchase

When you visit our websites, retail locations, attend an event, request information, participate in a test ride, or otherwise interact with us before purchase, we may collect information from or about you, your devices, or from third parties.

Categories of Data

Description

Purpose & Legal Basis (GDPR)

Contact Information

Name, address/region, email address, phone number, contact preferences

Respond to inquiries; provide requested information; schedule events/test rides (Consent or Pre‑contractual steps/Contract)

Communications & Interactions

Requests for information; calls/emails/chats; retail visits; event participation; test ride logistics and waivers

Communicate with you; confirm eligibility; administer events and experiences (Consent, Contract, or Legitimate Interests)

Network Activity Information

Device model; browser type; operating system; IP address; cookie IDs; approximate location derived from IP; pixel tags

Operate and secure websites/apps; debug; prevent fraud; improve user experience (Consent where required; Legitimate Interests)

Website Analytics & Personalization

If enabled: website usage, clicks, viewed pages, conversions via cookies, pixels, SDKs, and similar technologies

Measure performance; personalize content; marketing attribution; audience building (Consent; and/or Legitimate Interests where permitted)

Leads & Partner Referrals

Lead information received from partners, affiliates, dealers, or public sources

Business development; respond to requests; prevent fraud (Legitimate Interests; and/or Consent where required)

Information We Receive From Third Parties

We may receive information about you from third parties, including:

• Affiliates and subsidiaries
• Dealers, distributors, and retail partners
• Marketing and advertising partners
• Event and promotion partners
• Financing and leasing partners
• Payment processors
• Consumer research and survey providers
• Publicly available sources
• Business contact databases and lead-generation providers
• Social media platforms when you interact with our content
• Service providers acting on our behalf

We may combine information obtained from third parties with information we collect directly from you in order to provide Services, improve our products, prevent fraud, process transactions, personalize communications, and comply with legal obligations.

Cookies and Similar Technologies

Cookies are small files stored on your device. We use required cookies and similar technologies to provide the Services you request and to ensure our sites function properly. Where required by law, we use optional analytics and marketing technologies, including cookies, pixels, tags, software development kits (SDKs), retargeting technologies, advertising networks, social media advertising tools, and other similar technologies only with your consent. We also seek to honor browser‑based opt‑out preference signals recognized by applicable law (for example, global privacy controls where supported).

You can manage cookie preferences through our cookie banner (where available) and your browser settings. If you block cookies, some features may not work as intended.

We may use Google Analytics to help us understand how visitors use our websites and Services. Google Analytics may collect information such as IP address, browser type, device identifiers, pages visited, session duration, referring URLs, and interactions with our content. You can learn more about how Google collects and processes information by visiting:
https://policies.google.com/technologies/partner-sites

You may opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available at:
https://tools.google.com/dlpage/gaoptout

Global Privacy Controls

Where required by applicable law, we seek to recognize browser-based opt-out preference signals, including Global Privacy Control ("GPC"), as requests to opt out of certain forms of targeted advertising or sharing of personal information.

When You Are an Also Customer

If you purchase, lease, subscribe to, or use an Also Vehicle or Service, we may collect additional information from or about you, your Vehicle, the Also App, our service operations, and third parties (for example, payment providers and financing partners).

Also Account

Customers may create an Also Account hosted by us or our service providers. Through your account, you may access resources and manage certain settings.

  • Order status and purchase records
  • Registration information and warranty documentation
  • Payment method information (processed by payment processors)
  • Vehicle identifiers (e.g., serial number) and connectivity plan information (if applicable)
  • Service appointments, support interactions, and related documents
  • Preferences, consents, and connected‑service settings

Information from or about you

Categories of Data

Description

Purpose & Legal Basis (GDPR)

Order Information

Purchase details; agreements; delivery and registration documents; trade‑in information (if any)

Fulfill your request for products and services (Contract)

Government ID Data (where applicable)

Identity verification data you provide for financing, compliance, or fraud prevention (e.g., ID details)

Verify identity; comply with law; prevent fraud (Legal Obligation; Contract; Legitimate Interests; and Consent where required)

Financial Information

Payment method tokens; bank/credit account details provided to processors; financing/lease application information (if any)

Process payments and financing (Contract; Legitimate Interests for fraud prevention)

Customer Support Activity

Support tickets; call/chat logs; troubleshooting steps; theft recovery requests; outcomes

Provide customer service; improve satisfaction; prevent misuse (Contract; Legitimate Interests)

Safety & Incident Communications

Reports you submit about safety incidents, theft, or product defects

Investigate; comply with obligations; improve safety (Legal Obligation; Legitimate Interests)

Information from or about Your Also Vehicle

There are several categories of data generated by your Also Vehicle. The most common are (1) ride data, (2) diagnostic data, (3) battery and charging data, and (4) software, firmware, and connectivity data.

Ride Data

To support continuous performance, predictive maintenance, safety analysis, and improved functionality, your Vehicle may collect and process ride data related to the usage, operation, and condition of your Vehicle.

Examples of ride data may include speed, acceleration and braking signals, distance traveled, ride duration, motor output, component state signals, odometer readings, connectivity status, and safety‑related signals (such as traction or stability indicators, where available).

We use ride data to triage and fix potential issues, improve Vehicle reliability, deliver software and firmware updates, and improve our Services. Where feasible, ride analytics used for product improvement are aggregated or de‑identified.

When ride data may be accessed or linked

We may access, link, or process ride data with account information when:

  • You request service, support, or repairs (including remote diagnostics)
  • A safety event occurs (for example, a crash/impact detection event)
  • You request theft recovery or similar safety/security services
  • We detect a hardware or software issue that may be addressed through a software update or product advisory
  • You enable a feature that requires account‑linked telemetry (for example, ride history, geofencing, or fleet management)
  • You provide consent, or another lawful basis applies

Diagnostic Data

Also uses diagnostic logs to keep our Vehicles and Services up to date, troubleshoot problems, and make continuous improvements. We aim to collect the minimum diagnostic data necessary to help keep your Vehicle reliable, secure, and operating normally.

Diagnostics may include firmware logs, error codes, battery management system logs, connectivity interruptions, configuration parameters, and debugging reports. On certain events, diagnostic logs may be used to determine whether a problem can be addressed by an immediate or future software release.

Battery and Charging Data

To support battery longevity, safety, and performance, your Vehicle may collect battery and charging data such as charge level, charge cycles, charge rate, temperature, energy throughput, battery health metrics, and charging session timestamps.

We use battery and charging data to provide you with services, support warranty and safety obligations, analyze performance, and improve battery management over time.

Software, Firmware, and Connectivity Data

Your Vehicle may collect information related to firmware versions, update status, hardware configuration, network connectivity (Bluetooth/Wi‑Fi/cellular where present), and service availability. We use this information to deliver over‑the‑air updates, maintain security, ensure compatibility, and provide connected features.

Location Services

Your Vehicle and the Also App may use location to power features such as maps, navigation support (where available), ride history, geofencing, theft detection, and recovery services. Location services may use a combination of GPS, Bluetooth, IP address, Wi‑Fi, and cellular signals to determine location. When a Vehicle is reported stolen, location information may continue to be processed and shared with recovery service providers or law enforcement as necessary to assist in recovery efforts.

You can typically control location permissions through your mobile device settings and within the Also App. If you disable location permissions, certain features may not work (for example, ride tracking, theft recovery, or geofence alerts).

For safety and security, your Vehicle’s last known location may be used when you request recovery services or report theft, or when a safety event occurs, to assist response efforts.

Road and Infrastructure Analytics

To improve our products and plan service coverage, we may generate aggregated analytics based on ride patterns and general areas of usage. Where feasible, such analytics are derived using privacy‑preserving techniques and are not intended to identify you.

Safety Analysis Data

To help improve safety and reliability, we may collect and store limited Vehicle data associated with a Vehicle identifier in contexts such as:

  • Data about crashes or impact events (for example, high‑g events, sudden deceleration, or other safety triggers)
  • Data about remote services (for example, lock/unlock commands, theft alerts, recovery actions)
  • Data confirming the Vehicle is online and reporting current firmware versions and limited telematics
  • Data about issues that could materially impair safe operation
  • Data about firmware and software update installations and outcomes

We use this information to analyze incidents, improve safety, address defects, comply with legal obligations, and enhance reliability.

Also App and Connected Services

The Also App may allow you to:

  • View battery status and charging progress
  • Lock or unlock (where supported) and manage security settings
  • View location and ride history (where enabled)
  • Receive theft and safety alerts
  • Initiate firmware updates and view update status
  • Submit service requests and upload supporting materials

To detect and proactively fix issues related to app functionality, prevent unauthorized access or misuse, and improve user experience, we may collect general app usage information (for example, whether a command was successful or unsuccessful) and app performance logs.

Uploaded Content

The App may allow you to upload content such as photos (for example, when submitting a support request). We use uploaded content to fulfill your request and provide support.

Data Sharing Controls

Depending on region and configuration, controls may include options to:

  • Enable or disable location‑based features
  • Enable or disable optional analytics that help improve ride stability, battery management, and diagnostics
  • Manage marketing communications and cookie preferences
  • Manage third‑party integrations and revoke authorizations

If you enable optional analytics, your Vehicle and App may share limited telemetry with Also for analysis. We design optional analytics to use privacy‑preserving techniques where feasible.

Opting Out of Connectivity & Telemetry

Connectivity and telemetry enable many core features such as over‑the‑air updates, remote services, theft recovery, diagnostics, and improved safety. If you request that we deactivate connectivity for a Vehicle, we may still retain data previously collected and may still process limited information necessary for safety, security, legal compliance, fraud prevention, and warranty administration.

If you opt out of connectivity, the Vehicle may experience reduced functionality. For example, you may lose access to:

  • Over‑the‑air firmware and security updates
  • Remote services in the Also App
  • Real‑time diagnostics and proactive issue detection
  • Theft recovery and certain safety alerts
  • Certain usage insights or ride history features

If connectivity is disabled, we may not be able to notify you of issues in real time and some problems may go undetected until you seek service.

How We May Use Your Information

We may use the information we collect to:

Communicate with you

  • Respond to inquiries and fulfill your requests
  • Send administrative information, such as changes to terms or policies
  • Provide safety‑related information about your Vehicle or accessories
  • Conduct surveys and obtain feedback
  • Provide educational content and product information you request

Fulfill our products and services

  • Complete purchases, financing, delivery, and warranty registration
  • Process payments
  • Provide customer support and service operations
  • Monitor performance and provide connected services, including over‑the‑air updates
  • Diagnose, triage, and fix issues or concerns with products and services
  • Manage theft recovery or security features you enable

Improve and enhance development of our products and services

  • Research, develop, and improve Vehicles, batteries, firmware, and connected services
  • Analyze and improve safety and security of our products and Services
  • Perform analytics, audits, and forecasting
  • Detect, prevent, and investigate fraud, abuse, or security incidents

Other circumstances

  • Comply with legal obligations and respond to lawful requests
  • Establish, exercise, or defend legal claims
  • Analyze and investigate safety incidents and product defects
  • As otherwise permitted or directed by you

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including as described in this Notice, in service‑specific notices, or as required by law. Criteria we use to determine retention may include the nature of the data, our relationship with you, whether there is an ongoing contract, whether you have provided consent, and whether a legal requirement applies. We seek to retain personal data for the shortest period consistent with these purposes.

Collection and Use of Non‑Personal / De‑Identified Data

We may also collect, use, and share data that does not reasonably identify you (for example, aggregated or de‑identified analytics). We may use such data for operational, research, and product improvement purposes, subject to applicable law.

Sharing Your Information

We limit how—and with whom—we share personal data. We do not sell your personal data for monetary consideration. We may share personal data with service providers, business partners, affiliates, third parties you authorize, and others as required by law.

Our service providers, business partners, and affiliates

Categories of Recipients

Description

Reason for Sharing

Affiliates and subsidiaries

Companies owned or controlled by Also, or where we have a substantial ownership interest

To assist and fulfill Services on our behalf (Legitimate Interests; Contract)

Service providers and business partners

Vendors providing cloud hosting, analytics, customer support tools, communications, identity verification, security, and professional services

To operate and improve Services; outsource certain operations (Legitimate Interests; Contract)

Payment processors

Companies that securely process payments and handle fraud screening

Enable payment processing and prevent fraud (Contract; Legitimate Interests)

Connectivity providers (if applicable)

Network providers enabling Vehicle connectivity services

Provide connected features and connectivity (Contract; Legitimate Interests)

Professional advisors

Lawyers, auditors, accountants, consultants, insurers, financial advisors, and similar professional service providers

Obtain legal, accounting, auditing, insurance, compliance, and business advisory services (Legitimate Interests; Legal Obligation where applicable)

Third parties you authorize

Categories of Recipients

Description

Reason for Sharing

Financing institutions (if applicable)

Companies processing credit applications for financing or leasing

Confirm eligibility and process financing (Consent and/or Contract)

Fleet operators / employers (if applicable)

Organizations that manage Vehicles you use (e.g., employer fleet)

Administer fleet services and compliance (Authorized by law/contract)

Third‑party app developers (if applicable)

Developers of apps/services integrated via APIs

Share data you direct us to share to enable features (Consent)

Authorized repair centers (if applicable)

Independent service providers you choose

Facilitate service and repairs (Contract; Legitimate Interests)

Business and marketing partners

Companies that offer products, services, promotions, events, loyalty programs, referral programs, co-branded offerings, or other opportunities that may be of interest to customers

Administer promotions, measure campaign effectiveness, provide requested offerings, and support marketing activities (Consent where required; Legitimate Interests)

Other third parties as required by law or other circumstances

Categories of Recipients

Description

Reason for Sharing

Law enforcement and government authorities

Disclosure as required by law or when appropriate

Comply with applicable laws; protect safety and rights (Legal Obligation; Legitimate Interests)

Government incentive or program administrators (if applicable)

Programs requiring limited information for eligibility verification

Participate in programs you elect (Contract; Legitimate Interests; Legal Obligation where required)

Corporate transactions

Acquirers or counterparties in merger, acquisition, reorganization, or asset sale

Business continuity and due diligence (Legitimate Interests; Legal Obligation where applicable)

When we share personal data with service providers, they are required to follow our instructions and use personal data only to provide services to us.

Business and Promotional Partnerships

From time to time, we may collaborate with business partners to offer promotions, events, sweepstakes, contests, referral programs, financing opportunities, insurance products, charging services, mobility services, or other offerings. Where permitted by law and consistent with your preferences, we may share limited information necessary to administer these programs and fulfill your requests. We do not authorize partners to use personal data for purposes inconsistent with this Notice.

Choice and Transparency

We enable you to access and control the data we collect, use, and share. Depending on your region and product configuration, you can manage preferences through device permissions, in‑app settings, communication preferences, your Also Account, and cookie controls.

Marketing Communications

If you sign up for promotional communications, we may contact you by email, phone, text, or in‑app messaging where permitted. You can opt out of promotional emails by using the unsubscribe link, and you can manage preferences in your account settings where available. We may still send non‑promotional messages such as safety notices, billing updates, and policy changes.

If you provide your mobile phone number and consent where required, we may send transactional, service-related, safety, security, support, and marketing text messages.

Marketing text messages may include promotions, product announcements, event invitations, surveys, and other communications regarding our products and Services.

You may opt out of marketing text messages at any time by replying STOP to a message or by contacting us using the information provided in the "Privacy Questions" section. After opting out, you may continue to receive transactional or service-related messages necessary to provide products or Services you request.

Message and data rates may apply. Consent to receive marketing text messages is not a condition of purchase.

Privacy Requests and Identity Verification

To protect you and prevent fraud, we may need to verify your identity before processing certain requests. The information required will depend on the request and your relationship with us.

U.S. STATE PRIVACY RIGHTS

California Privacy Disclosure (CCPA/CPRA)

This section applies to California residents. Under California law, you may have rights to know, access, correct, delete, and opt out of the sale or sharing of personal information, and to limit the use and disclosure of sensitive personal information. We do not discriminate for exercising privacy rights.

Categories of Personal Information Collected, Sources, Purposes, and Disclosures

CPRA Category

Examples

Sources

Purposes

Disclosed To

Sold/Shared

Identifiers

Name, email, phone, account ID, device identifiers, IP address

You; App; Website; Service providers

Account, support, security, marketing, analytics

Service providers; affiliates; payment processors; support vendors

Not sold; may be shared for targeted ads via cookies if enabled

Customer records

Billing/shipping address, account credentials

You; Account

Provide Services; fraud prevention; compliance

Service providers; affiliates

Not sold; limited sharing only as described

Commercial information

Purchase/transaction history; warranty status

You; Account; partners

Fulfill orders; warranty; accounting; analytics

Payment processors; service providers; advisors

Not sold; not shared for targeted ads

Internet/network activity

Browsing/activity on our sites, clicks, app usage logs

Website; App; devices

Security; analytics; improve Services; marketing attribution

Analytics providers; advertising partners (if enabled); service providers

May be shared for cross‑context behavioral advertising if marketing cookies enabled

Geolocation data

GPS location, route history (if enabled)

Vehicle; App; device sensors

Ride tracking; theft recovery; safety; product improvement

Service providers; recovery partners (if applicable)

Not sold; not shared for targeted ads

Sensory data

None by default (Vehicles currently have no cameras/microphones)

Inferences

Preferences or patterns derived from usage

App; Vehicle; Website

Improve Services; personalization; fraud prevention

Service providers; affiliates

Not sold; may be shared if derived from ad cookies and you enable marketing cookies

Sensitive personal information (SPI)

Precise geolocation (if enabled); government ID for verification (if collected)

You; Vehicle; App

Provide Services; prevent fraud; comply with law; security

Verification vendors; service providers; authorities (as required)

Not sold; not shared for targeted ads

Do Not Sell or Share

We do not sell personal information for money. We may “share” certain personal information (such as online identifiers) for cross‑context behavioral advertising if you enable marketing cookies or similar technologies. Where required, we provide a method to opt out of such sharing.

How to Exercise California Rights

You may submit a request to know, access, correct, delete, or opt out by contacting us as described in the “Privacy Questions” section. You may also use an authorized agent where permitted by law. We may request additional information to verify your identity.

ADDITIONAL U.S. STATE PRIVACY RIGHTS

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws, including but not limited to Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other jurisdictions that may enact similar laws.

Depending on your state of residence and subject to applicable exceptions, you may have the right to:

  • Confirm whether we process your personal data.
  • Access personal data we maintain about you.
  • Correct inaccuracies in your personal data.
  • Delete personal data we maintain about you.
  • Obtain a portable copy of certain personal data.
  • Opt out of targeted advertising.
  • Opt out of the sale of personal data, if applicable.
  • Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable.
  • Limit the use or disclosure of sensitive personal information where provided by law.

Appeal Rights

Residents of states that provide an appeal right may appeal a decision we make regarding a privacy rights request. To submit an appeal, please contact us using the information provided in the "Privacy Questions" section and include "Privacy Rights Appeal" in the subject line. We will review your appeal and respond within the timeframe required by applicable law.

How to Exercise additional U.S. State Rights

You may submit privacy requests by contacting us as described in the “Privacy Questions” section. You may also use an authorized agent where permitted by law. We may request additional information to verify you or your authorized agent’s identity.

Response Timing

We will respond to verified privacy requests within the timeframe required by applicable law. If additional time is necessary, we will notify you as permitted by law.

Europe (GDPR) Disclosure

If you are located in Europe, Also processes your personal data as a controller for the purposes described in this Notice. Legal bases we may rely on include: your consent; necessity for performance of a contract; compliance with a legal obligation; protection of vital interests; and legitimate interests that are balanced against your rights and interests.

Your GDPR Rights

  • Access your personal data
  • Correct inaccurate or incomplete data
  • Request deletion (erasure) in certain circumstances
  • Restrict processing in certain circumstances
  • Object to processing based on legitimate interests or direct marketing
  • Data portability for data you provided to us
  • Withdraw consent at any time (where processing is based on consent)
  • Lodge a complaint with your data protection authority

Automated Decision‑Making

We do not intend to use automated decision‑making that produces legal or similarly significant effects on you without providing appropriate notice and choices. If we introduce such processing, we will update this Notice and provide additional information as required by law.

Protection of Personal Data

We use administrative, technical, and physical safeguards to protect personal data, taking into account the nature of the data and the threats posed. Safeguards may include encryption in transit, secure cloud infrastructure, access controls, monitoring, and authentication protections.

No transmission or storage system can be guaranteed to be 100% secure. If you believe your interaction with us is no longer secure, please contact us using the information in the “Privacy Questions” section.

Third‑Party Services and Links

This Notice does not address, and we are not responsible for, the privacy or data practices of third parties, including third‑party apps, operating systems, wireless service providers, social media platforms, or websites that may be linked from our Services. If you choose to connect a third‑party service, that service’s privacy policy governs its processing.

Children’s Privacy

Our Services are not directed to individuals under the age of sixteen. We do not knowingly collect personal data from children under 16. If you believe a child has provided us personal data, please contact us and we will take appropriate steps.

International Transfers

Also operates internationally. Your information may be transferred to, stored in, and processed in countries other than your country of residence. Where required, we use appropriate safeguards such as Standard Contractual Clauses and implement technical and organizational measures designed to protect your data.

Updates to This Notice

From time to time, we may develop new capabilities, features, or offer additional services that require changes to this Notice. When we do, we’ll update the “Updated” date at the top of this Notice. We may also provide additional notice (such as email or in‑app messaging) where appropriate.

Privacy Questions

For privacy questions or comments, to opt out from certain services, or to submit a data privacy request, please contact us:

  • Email: privacy@ridealso.com
  • Mail: Also, Attn: Privacy, 450 Lambert Ave, Palo Alto, CA 94306

When contacting us, please include sufficient information for us to understand and respond to your request. We may request additional information to verify your identity.