Effective Date: March 1, 2021
Personal information is information that can be used to identify you (whether alone or in combination with other information), and may include:
Additional information is collected about users of REVER’s apps and products. For more details, please click here.
The Companies collect your personal information through various means, including when you directly provide information to us and when we automatically collect information about you through your use of the Services. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use certain features of the Services.
We may collect personal information you provide directly to us, including:
In addition to information you provide to us, the Companies and our agents, vendors, and consultants (collectively “Service Providers”), as well as other third parties may collect information automatically about our Services and how you use them. Examples of the types of personal information that may be collected automatically when using the Services include:
Cookies and Tracking Technologies:
We use Hotjar to help us understand and analyze how visitors use the Services, and to improve the Services. Hotjar may collect the following types of information from users of our website:
We may use your information in various ways to serve you better as a customer and provide an improved online experience. The table provided below outlines how and why we use your personal information:
We may aggregate and/or de-identify your Personal Information so that it can no longer be linked to you. We may use and share aggregated/de-identified information for any purpose at our sole discretion.
In addition to the uses described above, REVER’s apps and products process personal information in ways that differ from the other Comoto brands. For more details, please click here.
The following describes our policies with respect to the sharing of your personal information with others.
We may share your personal information as follows:
REVER helps riders find the best roads and trails, map and plan their routes, connect with each other, and track their riding activities anywhere in the world—even without cell service. In addition to the other information practices described in this Policy, REVER collects and processes:
In addition to the other uses of personal information discussed elsewhere in this Policy, REVER uses the personal information of its members to operate and customize the REVER app and website, help its members evaluate and improve their riding/driving experience, and assist members with vehicle maintenance and security. For example, REVER uses your personal information to suggest routes, challenges, events or communities that may interest you, or members that you may want to follow. REVER may also use information about you to target ads to you.
When you join the REVER community, your profile and activities are set to be viewable by everyone by default. Your name, profile information, photos, videos, routes, members you follow, members who follow you, communities you belong to, and the vehicles for which you use REVER may be accessed by REVER members and non-members or viewable on publicly accessible REVER pages, unless you modify your settings to restrict such disclosures.
REVER provides tools that allow you to limit the sharing of some of this information. For example, you can change the visibility of the activities you upload to REVER, and can choose whether to invite your contacts to view your location and activities using REVER LiveRIDE.
REVER members may choose to share their activities with their contacts via text, email, or on social media applications like Facebook, Instagram, and Twitter. If you link your REVER account to third-party social networks and share your activities, your personal information (including your location) will be viewable on such third-party platforms. You should use caution when sharing information with third parties and carefully review the privacy practices of such third parties.
REVER also enables sharing with third parties offering integrated features on the REVER app, such as challenge sponsors. If you click on a third-party link, you will leave our platform and the sponsor may be able to identify that you visited their platform from REVER. Information collected by these third parties is subject to their terms and policies.
The Companies offer various communities and forums across the Services, as well as the ability to provide reviews of the products and services we sell. We offer several features that allow users to connect and communicate in public or semi-public spaces as part of the Services. You do not have to use these features, but if you do, please use common sense and good judgment when posting in these communities or sharing your personal information with others.
Please be aware that any personal information you choose to submit in any communities, forums, or reviews can be read, collected, or used by others, or could be used to send unsolicited messages to you. We may engage our Service Providers to assist in providing community services to you. The Companies generally do not control or remove content from public forums or communities on their websites (though we reserve the right to do so in our sole discretion). Your posts may remain public if you subsequently close your account(s) with the Companies.
Despite our safety and privacy controls, we cannot guarantee that you will not encounter inappropriate or illegal conduct from other users when using the Services. You can help us to make our websites (including public forums) welcoming for all users by reporting any offensive or unwelcome conduct to us.
Our Services are not intended for children nor targeted to children under the age of sixteen (16). Our Companies do not knowingly collect personal information from children under the age of 16. If we learn that we possess information from a child under the age of 16, we will delete such information in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws. If you are a parent or guardian and you believe that your child under the age of 16 has provided us with personal information without your consent, please contact us at firstname.lastname@example.org.
You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in every commercial email we send, or (if you have an account with us) by logging into your account and changing your preferences, or by sending us a request to unsubscribe at email@example.com. If you opt-out of receiving marketing email communications, we may still send you email messages related to your account with us, including specific transactions or our services. Unsubscribing yourself from our marketing communications will not affect our service to you.
You have the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you have shared with us. Once you have opted-in, we may send you text messages (i) regarding your account; (ii) to investigate or prevent fraud; and (iii) to alert you in the event of an emergency. We may send you text messages and alerts using autodialed technology. We will not contact you via text messages or alerts for marketing purposes without your prior express written consent. You do not have to opt-in to text messages and alerts to use and enjoy our websites and Services. If you opt-in, standard text messaging charges may apply. For more information regarding our text messaging and alerts, please contact us at firstname.lastname@example.org or 1-877-792-9455.
You may choose to opt-out from our text messages and alerts at any time using any reasonable means. To directly opt-out, send us a text message from your mobile phone with the word STOP, STOP ALL, END, QUIT, CANCEL or UNSUBSCRIBE, and we will unsubscribe you from text communications. Once you opt-out, you will not receive any additional text messages via your mobile phone. Please keep in mind that if you opt-out of receiving text messages and alerts we may not be able to contact you with important messages regarding your account. However, if there is an emergency or account question, we will make every attempt to contact you in other ways, such as by email or on a landline phone.
The Companies do not currently have the technology to automatically respond to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. If you are a California resident who wishes to delete your personal information, please see the instructions for submitting such requests, below.
Third-parties, such as Google Analytics, may collect data that relates to you on our websites, across time, and over other websites. Third-parties’ responsiveness to do-not-track signals is governed by their privacy policies. You also may limit certain tracking by disabling cookies in your web browser. For more information on Do Not Track, please visit https://allaboutdnt.com.
The following describes the categories of personal information that we may collect about data subjects in the United Kingdom, the EU and the EEA, the purposes for which we may process the personal information, and the legal bases for such processing. In the case of personal information that we do not obtain directly from you, the source and specific categories of that data are also described:
You may have the following rights:
You can inquire about your Personal Information and how we process it, and obtain further information on the above data subject rights by contacting our Data Protection Officer using the details set out below.
Data Protection Officer
You may have the following rights:
4020 S 26th St
Philadelphia, PA 19112
Attention: Privacy - Data Subject Privacy Request
We will respond to most requests within thirty (30) days of receipt. We will contact you if an extension period is required to respond. We may ask for additional information to verify your identity and understand your request. There may be exceptions and limitations related to your request. We may, for example, charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, we may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice law enforcement, interfere with pending or future litigation, etc. In all cases, you have a right to file a complaint with the appropriate Supervisory Authority.
We have implemented appropriate and reasonable physical, technical, and administrative safeguards to help prevent unauthorized access to, use of, and disclosure of, your personal information. However, there is no perfect security. We cannot guarantee the security of your personal information. You are responsible for maintaining the secrecy of any credentials used to access your account with us and you should report suspected unauthorized activity to us immediately.
The Companies specifically reserve the right to terminate your access to the Services and any contract you have with the Companies in the event we learn or suspect you have disclosed your account or password information to an unauthorized third party.
The Companies are global business based in the United States. We and our affiliated companies have offices and facilities in the United States, and we transact business in the United Kingdom, Germany, France, Spain and many other EU countries as well as other jurisdictions throughout the world.
We may transfer your personal information to recipients in countries whose laws may not provide the same level of data protection as your country. When we do so, we will ensure that there are adequate safeguards in place to protect your personal information and to comply with our legal obligations.
If you are a resident of California, your right to submit certain requests relating to your personal information is described below. Please note that when submitting a request, you will be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the process described below.
California residents have the right to opt out of the sale of their personal information. To exercise this right, please submit a request through our Do Not Sell My Personal Information form found on our homepage, call us at 1-877-792-9455, or email us at email@example.com
If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:
(1) The categories of personal information we have collected about you
(2) The categories of sources from which we have collected your personal information
(3) The business or commercial purpose why we collected or, if applicable, sold your personal information
(4) The categories of third parties with whom we shared your personal information
(5) The specific pieces of personal information we have collected about you
(6) The categories of personal information that we have shared with third parties about you for a business purpose
(7) The categories of personal information that we sold about you and the categories of third parties who received your personal information in the sale
(8) A list of all third parties to whom we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes
Please note that due to the different requirements of the applicable laws, our response times may vary depending on the specific type(s) of information sought. We respond to all verifiable requests for information as soon as we reasonably can and no later than legally required.
California residents also have the right to request that we delete your personal information collected or maintained by us. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers (such as Google Analytics) that may have collected personal information about you through our websites to delete your personal information from their records. There may be circumstances where we cannot delete your personal information or direct service providers to delete your personal information from their records. For example, if we need to: (1) retain your personal information to complete a transaction or provide services; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug or repair errors; or (5) comply with a legal obligation. You may submit a request to delete your personal information by calling us at 1-877-792-9455, emailing us at firstname.lastname@example.org, or submitting a completed form available here. In connection with submission of your request, we will take steps to verify your identity as outlined below, and you will need to verify your identity before action is taken.
Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates, and to prevent unauthorized access or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of personal information provided to verify your identity, the nature of our business relationship with you, and available technology for verification.
We will generally try to avoid requesting additional information from you for the purpose of verification, but we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by law.
The following generally describes the verification processes we use:
Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity, but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
Verification by Authorized Agent. You may designate an authorized agent to make the requests above on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the process described above.
If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.
If you choose to exercise any of the privacy rights conferred by the California Consumer Privacy Act of 2018, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing our services to you, charge you different prices or provide a different level or quality of services to you unless those differences are related to the value of your personal information.
Under Nevada law, Nevada residents who have purchased goods or services from us may opt-out of the “sale” of “covered information” as defined by Nevada law to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your personal information are not sales under Nevada law, so no opt-out is required.
If you have any comments or questions about how we collect and use your personal information, communications can be submitted to our postal address, via email to email@example.com, or by telephone to 1-877-792-9455.
Comoto Holdings, LLC
4020 S. 26 Street
Philadelphia, PA 19112
The Policy now applicable to REVER addresses access, deletion, and rectification rights for individuals on a jurisdiction-by-jurisdiction basis, rather than the blanket approach of the old REVER policy. This includes new sections dedicated to California and the EU. Individuals who reside in a jurisdiction that does not provide such rights may not be able to access, delete or otherwise limit the use of their personal information.
Most of the other terms will be familiar to Comoto customers but are stated differently or differently organized compared to the previous REVER policy. Please feel free to reach out to us should you have any questions.