Privacy Policy

Our privacy practices and discover how we use your information to change our world and help you have the best experience!

Effective Date April 1st 2024

Your privacy is important to us. We created this policy to let you know about the information we collect and process about awesome people like you that use our sustainable micro-mobility services, visit our websites, use our mobile apps, buy our products, or otherwise interact with us. It applies to you regardless of where you live, but if you live in certain countries or regions where additional or other terms may apply, see the Global Privacy – Supplemental Terms section of this policy.

When you read this policy (and we hope that you will), you will learn about the kinds of information we collect about you, how we use that information, when we might disclose your information to others, and your rights and choices regarding this information.

Before we get onto the good stuff, just keep in mind that when you read this policy that by “JACS,” “we,” “us,” or “our,” we mean JACS e-Bikes, LLC.

Also note that JACS may create de-identified, aggregated, or anonymized data from your information so that it is reasonably non-identifiable to you. Where we transform data in this way, it is not within the scope of this policy.

This policy does not apply to independent third parties that may collect or control your information separately from JACS like our business partners and retail sellers of our vehicles.

If you have any questions about this policy, please let us know by writing to us at JACSeBikes@gmail.com

What Information Do We Collect?

Information You Provide to Us

  • Contact Information. Before you take a ride on a JACS rental vehicle, participate in our surveys, contests, sweepstakes, and promotions, subscribe to our marketing updates, use our customer service, register for, or attend, an event, or when you register a JACS vehicle you purchased directly from us, you will be asked to provide certain basic personal contact information such as first name, last name, email address, and a mailing or postal address, phone number, and account information such as login and password. This information may also be provided to us by another person who organizes a group ride that includes you.
  • Government-Issued Identification. In many places where we offer vehicles for rent, rules require riders to be of a certain minimum age. To hire or employ you, we may be required to confirm your identity and eligibility for employment. We may ask you to provide your birthdate and driver’s license or other government-issued ID (which may indicate document numbers as well as birth date, gender, and photo).
  • Biometric Data. In many places where we offer vehicles for rent, rules require riders to be of a certain minimum age. We may use self-taken photographs or videos to determine if you meet any applicable minimum age requirement and we share it only with third parties as necessary to confirm the foregoing. We may also use biometric information, such as photographs, videos, or body mass to confirm that only one rider is utilizing our service. For more information, please see our Biometric Data Collection and Retention Policy.
  • Demographic Data. We also collect certain demographic data if you provide it to us including age, gender, preferred language, and current location. Note that we may also derive this data from your government-issued ID. See How Do We Use Your Information section below.
  • Payment Information. If you buy a product directly from us or rent a JACS vehicle, we will also ask for your payment information, such as a credit card, debit card, or another payment method, and your billing address. Note that JACS does not store your payment information; we use experienced and trusted third-party payment processors to collect and process your payments for us. We also ask for your Tax Identification Number in jurisdictions that require us to collect this information.
  • Feedback. If you respond to a survey about your experiences with us or offer opinions about our company, the micro-mobility industry, or other topics, we will maintain that information. Likewise, if you comment on blog entries, interact with us on social media, or participate in other JACS-sponsored forums, we collect that information, too. And, of course, we collect data when you call (such as a recording of the conversation) or write to us for help or seek other customer support services.
  • Job Applications. If you apply for a job with us, we will collect information from your application or resume.

Information We Automatically Collect

  • Device Information. When you visit our websites or use our mobile applications, we use cookies, pixels, log files, and other similar technologies to collect data about the computer or other device that you use. This systematic information includes device identifiers and other unique identifiers, browser type, browser language, operating system name, and version, device name, and model and version. We also collect information about how your device navigates our website or mobile applications like the referring and exit pages, dates and times you access, the length of time that you are logged into or browsed our sites, the links you click or features you use, software crash reports and a unique session identification number. Please see our Cookie Notice for more information.
  • Location and Vehicle Usage. When you rent a JACS vehicle using our app or visit our website, or connect your privately owned JACS vehicle to our app, we automatically collect and store location information from your device and from the vehicle you use:
    • Devices: We collect the location information (e.g., city, state, or postal code where available) associated with the IP address of the device you use to access the services, as well as, with your permission, your mobile device’s location information using GPS or Bluetooth (you can change your location/Bluetooth settings for your mobile device; however, certain features may not be available through the mobile application if you do so).
      • Vehicles: We collect the latitude and longitude of your vehicle in real-time. This information can be used to determine your device or vehicle’s current location, travel direction, and speed.

Information We Collect From Other Sources

  • Social Media Sites. When you interact with us or post content about us on social media platforms – like Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube, or Pinterest – we may collect certain information from your public profile as well as interests, “likes” and similar information you permit social media platforms to disclose in this way.
  • Referrals. We may invite our customers to introduce their friends to our services. If you choose to use our referral service to tell someone about our services, we will provide you with a template message and referral code to send to your friend. We will not collect the friend’s information unless they sign up to use the services with the referral code.
  • Sellers and Dealers. We receive information about you in connection with vehicle sales. For example, when you purchase a vehicle from an authorized JACS vehicle seller or dealer (“Dealer”), the Dealer discloses Contact Information with us, including your name and address, as well as the vehicle identification number and purchase information such as purchase date.

How Do We Use Your Information?

Products, Services, and Customer Support

We use Personal Information to provide, maintain, and improve our services, such as to:

  • Establish and maintain your account
  • Sell and deliver a vehicle to you that you have purchased from us
  • Confirm your identity
  • Verify your eligibility to rent a vehicle from us
  • Rent a vehicle to you
  • Troubleshoot and resolve your questions or concerns
  • Provide and operate our websites, mobile apps, and related features
  • Track our vehicles’ location and availability
  • Monitor vehicle health and statuses
  • Process payments you make to us
  • Provide services to you
  • Comply with our agreements with you

Consumer Marketing Messages and Other Communications

  • Communicate with you about:
    • vehicle rental, purchase, or use
    • questions, complaints, or issues you may have
    • changes to our policies
    • Your opinions about your experiences with us
    • Third-party marketing offers (subject to your consent where required by law)
    • Send to you information, news, updates, and offers about us or our services (subject to your consent where required by law)
    • Conduct data analyses to better predict content and marketing offers that may interest you
    • Personalize content, experiences, and marketing offers to you, including providing you reports, recommendations, and feedback based on your preferences
    • Provide more relevant ads to you

Research and Innovation

  • Improve vehicles, products, and services
  • Develop new vehicles, products, and services
  • Optimize or improve our products, services, and operations
  • Help us understand how our products and services can better meet the needs of our customers and cities through statistical, demographic, and marketing analyses of our products and services, app and website use, rider activity, vehicle routes, and demographic trends, for research, analytical, and statistical purposes

Business Operations and Legal Compliance

  • Manage and protect our networks, services, employees, and users
  • Detect, investigate, take action regarding, and prevent illegal activities, misuse, suspected fraud, or situations involving potential threats to the safety or legal rights of any person or entity
  • Comply with the law and fulfill lawful requests for information
  • Permit you to update, edit, and manage your content
  • Conduct research and perform data analyses to better understand our customers and how our vehicles, products, services, websites, and mobile apps are used
  • Create pseudonymous, anonymous, and aggregate information about our customers’ use of our vehicles, products, services, websites, and mobile apps
  • Use as evidence in litigation
  • Investigate, enforce, and prevent violations of our policies and terms (including this Privacy Policy, our Terms of Use, and Rental Agreement)
  • Establish, protect and defend our legal rights
  • Confirm your identity
  • Verify eligibility of job applicants

How Do We Disclose Your Information?

Affiliates and Subsidiaries

We disclose information among the companies within the JACS family of companies. Our “family of companies” includes companies related to us by partnership or ownership. We disclose information within our family as a normal part of business operations and to provide products and services.

Public Partners and Transportation Authorities

Because our services are sometimes offered through cities or other political/executive subdivisions or require government or administrative permission to operate in certain locations, our business partners may include governmental authorities, local (regional, provincial, city-level) administrations, local quasi-government entities like a city transit authority, and local public transport operators and appointed data aggregators (each a “public partner”).

We will disclose your information with public partners as may be required to operate in a particular city or location. Public partners may use this information to help improve, inform, or manage city planning activities, public transportation services, traffic congestion, or our vehicles or services (for example, for designating vehicle parking zones, issuing parking fines, or creating restricted areas where our vehicles may not go, like sidewalks) among other public interest purposes the public partner may determine. In some cases, sharing your information with our public partners may be required by law or regulation.

For some of these purposes, cities have adopted a standard data set called “Mobility Data Specification” (MDS), MDS standardizes communication and data-sharing between cities and private mobility providers, such as JACS. JACS may provide MDS data to public partners where we provide services. For more information about MDS please visit https://www.openmobilityfoundation.org/about-mds/

Other Third Parties

  • Service Providers. We use a variety of third-party service providers to help us run our business and perform functions on our behalf, such as professional services (like law firms, consultants, accountants, and tax advisors), hosting, billing and payment processing, delivering push notifications, providing customer service, helping us prevent fraud, securing our systems, delivering app features, etc. For example, we disclose your information with companies we’ve hired to provide customer support or assist JACS in protecting and securing our systems where access to your information is necessary to provide those services. And we could not provide our services without third parties that maintain, service, and manage our fleets of vehicles in all of the cities where we operate. In these cases, we require the third-party service provider to use adequate safeguards to protect the confidentiality of the information they receive and to use your information only for the purposes for which they have been granted access.
  • Business Partners. We disclose personal information with other companies that, among others, help us provide services to our customers, or reach potential customers with our marketing messages. Examples include:
    • Platform Operators: If you use our services through a third-party platform that manages its own fleet of JACS vehicles, we will also disclose your information with the platform operator to assist in operating the services.
    • Google ARCore: To help JACS locate vehicles at the end of a ride, an app uses Google Play Services for AR (“ARCore”) provided by Google. The use of ARCore within the app is governed by the Google Privacy Policy. At the end of a ride, you will be asked to use the JACS app and your personal device’s camera to record images of the place where you are leaving the vehicle. The image, your device’s estimated geolocation, and orientation, IP address, and other device information will be collected and processed by ARCore to identify the area where you left the vehicle. Google analyzes this data and returns to JACS information indicating the location of the vehicle.
    • Advertising and Digital Analytics Companies. Please see the Cookie Notice for a description of how we work with ad exchanges, channel partners, measurement services, and advertising and digital analytics providers like Facebook, Google, and other third-party ad companies.
    • Joint Marketing Partners. We disclose information with partners with which we offer co-branded services or engage in joint marketing activities.
    • Universities and Research Organizations. We collaborate with universities and researchers around the world to better understand important questions about micro-mobility services like how people use them, how they can be improved, and how they impact the climate. To help with this research, we may disclose your information with our research partners with your consent.

Law Enforcement Agencies, Courts, Regulatory Agencies, and Others

When we believe it is necessary, we will disclose personal information to:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
  • In the event of exigent circumstances, to help prevent the loss of life or serious injury or to protect the personal safety of our personnel, users of our vehicles, websites, mobile apps, or the public
  • Detect, investigate, or prevent fraud or privacy issues
  • Detect, investigate, prevent, stop, or remediate security incidents involving our computer systems or networks
  • Protect our rights or property, and those of our subsidiaries and affiliates, or others, including by enforcing our agreements, terms, and policies

Blogs and Social Media

When you interact with us or post content about us on social media platforms – like Facebook, Twitter, Google+, Tumblr, LinkedIn, YouTube, or Pinterest – any information that you submit through such features is not confidential and may be accessed by others. For example, if you submit a product review on one of our sites, we may display your review (along with the name provided, if any) on other JACS sites and on third-party websites. If you provide a comment on our blog, other blog readers will be able to review your comments, and if you interact with us on our social media pages, your comments will be publicly available. So, please take care when using these features. If you’d like to request the removal of information that we have posted about you, please contact us.

Parties to Corporate Transactions

We may transfer personal information as part of a corporate transaction like a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets. If a transfer for these reasons is subject to legal restrictions, we will comply with the law.

Cookie Notice

What is a “Cookie?”

Almost every website uses cookie technology. We are no exception. JACS uses cookies, web beacons, pixels, tags, social media plugins, and other similar technologies (some of which are operated by third parties) on our websites and other digital platforms to collect data (“Cookies”).

Cookies are small files that store Internet settings. A Cookie consists of a string of letters and numbers that uniquely identifies your device and collects information about your use of our website, and in some cases, other websites.

How does Cookie technology work?

The first time you visit a website, your device’s Internet browser will download the Cookies placed on the site and store them in your web browser (e.g., Chrome, Safari, Edge, etc.) The Cookie will collect information about your visit – things like what pages you visited, how the site performed, what ads you clicked, how you were brought to the site, account sign-on, or your preferences and settings – depending on the type of Cookie.

The next time you visit the same website with the same device, the Cookie, and the information stored in it, are sent back to the website (a first-party Cookie) or sent to another website if the Cookie is operated by a third party (a third-party Cookie). This exchange of information allows the website to know you’ve been there before and perhaps display more relevant information.

We use Cookie data to help us understand things like how many site visitors we had, how fast the pages loaded, or whether we had any performance issues, to record your preferences, personalize content and ads, and track information about the performance of our advertisements, among other purposes. We may combine this information with other information we collect from you.

What types of Cookies do you use?

Different Cookies serve different purposes. Based on the Cookie’s function and purpose, we divide them into five categories: Strictly Necessary, Performance, Functional, Advertising, and Pixels and Beacon. For more information about specific Cookies, including the identity of any third parties that receive Cookie data and the Cookie expiration dates, and to make choices regarding Cookies that are not strictly necessary, click on “Cookie Preferences” in the cookie banner on the webpage.

  • Strictly Necessary. Cookies that are “strictly necessary” ensure the performance of a website. Without strictly necessary Cookies, you would not be able to use this website as intended. For example, when you open a web page, you are shown a version that corresponds to the bandwidth of the Internet connection you are using, or when traffic is high, we can switch to another server. Because these Cookies are required for the website to operate, you may not opt-out or deactivate strictly necessary cookies.
  • Performance and Analytics. As the name suggests, performance Cookies collect information on how a website is used and how it performs. They tell us how many visitors we have, how they were referred to our site, how they move about on our site, whether visitors encounter error messages, how fast pages load, and measure the performance of our advertising, etc. This information helps us measure and improve the performance of our site. Performance Cookies do not save any information that permits the identification of the user and are only used to understand and improve the functionality of our websites. One of the performance Cookies we use is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). To learn more about Google’s analytics services and to learn how to opt-out of tracking of analytics by Google visit https://tools.google.com/dlpage/gaoptout/.
  • Functional. These types of Cookies enhance a website’s performance and functionality like saving details that have already been provided (e.g. user name, language choices, or your location so you don’t have to enter the information later) or enabling the playback of videos. Because functional Cookies collect anonymized information, they cannot track your movement on other websites.
  • Advertising. These Cookies may be set on our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They are based on uniquely identifying your browser and device. When your browser connects to a third-party advertising partner’s web server, the advertising partner is able to read (or set) its own cookies on your device and may collect information about your online activities over time and across different websites or online services. This information is used to show you ads across the Internet that are tailored to your interests. If you do not allow these Cookies, you will experience less targeted advertising.
  • Pixels and Beacons. Pixel tags (a/k/a web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to Cookies described above. You will find invisible pixel tags embedded on web pages or within emails. We, or our service providers, may use pixel tags, among other things, to track the activities of users of our websites or mobile apps, help manage content, measure ad performance and compile statistics about usage. We or our service providers also use pixel tags in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

How can I control or delete Cookies?

You have the right to choose whether to accept Cookies. Please note that if you choose to refuse Cookies you may not be able to use the full functionality of the website. Here are some ways to manage Cookies:

Web Browsers

  • Change your Cookie settings for at any time using the Cookie consent tool on the website.
  • Control Cookies by using the Cookie settings on your browser. Note that if you use your browser settings to block all Cookies (including strictly necessary Cookies) you may not be able to use or access our site.
  • Some browsers have incorporated features referred to as “Do Not Track” (DNT). DNT tells the websites you visit that you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals, however, you can still control Cookies by using the other options available to you as described in this section of the Cookie Notice.
  • If you accept some or all Cookies on the website you still have the option of setting your browser to notify you when you receive a Cookie, so that you may determine whether to accept it or not.

Mobile Devices

  • Apple and Android mobile devices each generate an advertising identifier that can be accessed by apps and used by advertisers in much the same way that Cookies are used on websites. Each operating system provides options to limit tracking and/or reset the advertising ID.

Email pixels/web beacons

  • You can disable pixels or web beacons in email messages through the settings of your email services to prevent the automatic downloading of images.

General advertising opt-outs

Many companies are members of industry advertising associations, which provide a simple way to opt out of analytics and advertising cookies, which help you make choices:

  • United States: Network Advertising Initiative and Digital Advertising Alliance
  • Canada: Digital Advertising Alliance of Canada
  • Europe: European Digital Advertising Alliance

For more information and to exercise your choices regarding Facebook and Google ads:

  • Facebook (more info: privacy policy; choices: ad preferences page)
  • Google/DoubleClick (more info: privacy policy; choices: ads help page)

You can also learn more about online advertising at www.aboutads.info/consumers and opt-out of interest-based advertising from many participating ad companies at the ad industry websites below:

  • United States: www.aboutads.info
  • Canada: www.youradchoices.ca
  • Europe: www.youronlinechoices.eu

Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see:

Please note that opting-out of advertising network services does not mean that you will not receive advertising while using our services or other services, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs.

Do-Not-Track. You may disable certain tracking on our websites, as discussed in this section (for example by disabling Cookies), and you may opt-out of certain third-party ad networks as described in this Section. For more information about Do-Not-Track signals, please visit https://allaboutdnt.com/.

Other Important Disclosures

Children’s Personal Information

JACS services are neither designed for nor targeted to children under the age of 13. If you are under the age of 13, do not provide your personal information through the JACS service platform. If you believe your child has impermissibly provided us with their personal information, please contact us, so that we can identify and delete their information.

Security and Retention

  • We use commercially reasonable administrative, technical, and physical security measures to protect personal information entrusted to us.
  • We retain the personal information we collect for as long as reasonably necessary to provide services to you and fulfill the other purposes for which we use your personal information such as to comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. For example, unless required for one of the other purposes mentioned, your account registration information, ride history, and payment history will be deleted or anonymized (so that it can no longer be associated with you) when you choose to delete your account.

Changes to this Policy

We will update this Privacy Policy when required by changes in the law, our products, and services, what personal information we collect, or how we use or disclose personal information. When we post changes to the Policy, we will change the “Effective Date” at the top of the Policy. If we make material changes, we will provide notice or obtain consent regarding such changes as may be required by law.

Contact Us

If you have any questions about this Privacy Policy, would like to exercise your rights regarding your information that we hold, or would like to raise a complaint with us related to your information, please reach out to us by email or phone:

JACSeBikes@gmail.com

218-234-6965

Do Not Sell or Share My Personal Information

We do not sell your personal data for monetary consideration. However, the use of some third-party cookies placed on our website and/or app may be considered “selling” personal information or “sharing” personal information for purposes of “cross-context behavioral advertising” under Minnesota law. We do share your web browsing activity and related technical information (like device identifiers) through cookies, pixels, and similar technology on JACS with online advertising services providers to deliver targeting of advertising to you on third party websites, applications, or services.  See our Cookie Notice section of this Privacy Policy for more information about our use of Cookies including how to opt-out.  Please note that to the extent you are accessing our webpages across multiple devices or platforms, or if you clear your browser settings, you may have to opt out again.

On this basis, in the preceding 12 months we have sold or shared:

  • Device identifiers, which includes internet protocol (“IP”) addresses, for non-monetary consideration as described above.
  • Internet or network activity, which includes information about visitors’ interaction with our pages, including information about the device’s web browser, page location, referrer, and a person using the website; cookie-specific data such as cookie ID; and button and field data, such as any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.