The website

www.chilli-proscooter.com is operated by Micro Mobility Systems AG (hereinafter „Micro“). The data protection declaration explains transparently how we collect, process and use personal data at Micro. We consider the careful handling of customer data to be one of our most important obligations. Therefore, we continuously strive to make adjustments in order to improve the protection of our customers‘ personal data.

What data is processed about me?
We process personal data on different occasions and for different purposes. This usually happens when you interact with us, e.g. when you order goods from us. We also attach great importance to adapting our offers to your individual needs. To this end, we process behavioral and, where applicable, transactional data, for example, when you create a customer account, register for one of our other services or navigate our website. On this basis, we make assumptions about your preferences, which enables us to offer or display offers that are likely to be of interest to you.

How do I benefit from data processing?
There are many benefits to processing your data. On the one hand, we can respond to your individual needs and concerns in customer support. On the other hand, we make shopping easier for you by making it easier to find those products online from our extensive range that you buy frequently or that are particularly relevant to you. Through our data processing, you also benefit from a personalized shopping experience, for example, through customized offers and discounts tailored to your shopping habits. Thanks to the processing of your personal data, we can continuously improve our offer and provide you with more attractive assortments and optimized products and services.

To whom will my personal data be disclosed?
Internally, your personal data will be passed on to and used by internal company departments. Outside the company, your data will only be passed on to selected service providers and partners. As a rule, personal data is processed on our behalf and in accordance with our instructions. However, some of our partners also process personal data independently or in cooperation with us.

Is my data secure?
We attach great importance to the appropriate protection of your data and take comprehensive security measures to ensure that your personal data is protected against unauthorized access. We continuously improve our security measures and adapt them to the current state of the art.

Who can I contact if I have questions?
If you have any questions about our processing of your personal data, please feel free to contact us at info@micro.ms. For more information on how you can exercise your rights in connection with your personal data, please refer to our privacy policy.

PRIVACY POLICY

1. What is this privacy policy about?
2. Who is responsible for data processing?
3. For whom and for what is this privacy policy intended?
4. What personal data do we process?
5. Where does the personal data come from?
6. For what purposes do we process personal data?
7. On what legal basis do we process personal data?
8. To whom do we disclose personal data?
9. How do we disclose personal data abroad?
10. How do we use profiling?
11. Do we make automated individual decisions?
12. How do we protect personal data?
13. How long do we process personal data?
14. What rights do you have in connection with the processing of your personal data?
15. How can you contact us?
16. Changes to this privacy policy

1. What is this privacy policy about?
Data protection is a matter of trust, and your trust is important to us. Therefore, we would like to inform you in this data protection declaration about how and for what purpose we collect, process and use your personal data.

Among other things, you will learn in this data protection declaration:

• which personal data we collect and process;
• for what purposes we use your personal data;
• who has access to your personal data
• what benefits our data processing has for you;
• how long we process your personal data
• what rights you have with regard to your personal data; and
• How you can contact us.

We have aligned this privacy policy with both the Swiss Data Protection Act and the European General Data Protection Regulation (GDPR). The GDPR has established itself worldwide as a benchmark for strong data protection. However, the applicability of the GDPR depends on the individual case.

2. Who is responsible for data processing?
The company that decides whether a particular data processing will be carried out, for what purpose it will be carried out and how it will be designed is responsible for this data processing under data protection law. Micro („we“ or „us“), is generally responsible for data processing under this privacy policy.

3. Who and for what is this privacy policy intended?
This data protection declaration applies to all persons whose data we process (in each case „you“), regardless of how you contact us, e.g. in an online store, on a website, in an app, in a branch, by telephone, via a social network, at an event, etc.. It applies to the processing of personal data already collected as well as personal data collected in the future.

Our data processing activities may in particular affect the following categories of persons, insofar as we process personal data in the process:

• Visitors to our websites;
• Holders of a customer account;
• customers in our online stores and branches;
• other persons who use our services or who come into contact with our offers;
• Users of our online services and apps;
• Visitors to our premises;
• People who write to us or otherwise contact us;
• Recipients of information and marketing communications;
• Participants in contests and sweepstakes;
• Participants in customer events and public events;
• Participants in market research and opinion polls and customer surveys;
• Contact persons of our suppliers, customers and other business partners as well as organizations and authorities; and
• job applicants.

Please note that additional information about our data processing may be contained in the contractual terms and conditions for specific services (such as General Terms and Conditions, Terms of Use or Conditions of Participation). For more information on the collection and processing of personal data in connection with the use of our websites, mobile apps and social media presences, in particular with regard to cookies and similar technologies, please also consult our cookie information.

4. What personal data do we process?
„Personal data“ is information that can be associated with a specific person. We process a variety of personal data, which are divided into different categories. For guidance, we have listed the main categories below. However, it is possible that we may also process other personal data in individual cases.

4.1 Master data
Master data is the basic data about you, such as title, name, contact details or date of birth. We collect master data in particular when you create a customer account with Micro. However, we also collect Master Data when you enter a contest or sweepstakes, for example, or register for a newsletter.

Master data includes, for example

• Salutation, first name, last name, gender, date of birth;
• Address, e-mail address, telephone number and other contact data;
• Customer numbers (e.g. for participants in a loyalty program);
• Payment information (e.g. deposited means of payment, bank details, billing address);
• User name and profile picture;
• Information on the use of our online platforms (e.g. whether you are registered with Micro);
• Details of associated websites, social media profiles, etc.;
• Details about affinities and interests, language preferences, etc.
• Information about your relationship with us (customer, visitor, supplier, etc.);
• Information about related third parties (e.g. contact persons, recipients of services or representatives);
• Settings regarding receipt of advertising, newsletters subscribed to, etc.
• Information about your status with us (inactivity or blocking of a customer account, house bans in stores, etc.);
• Details regarding participation in contests and sweepstakes;
• Information on participation in events;
• Details of titles and function in the company for contacts and representatives of our business partners;
• Date and time of registrations.

4.2 Contract data
Contract data is personal data that is generated in connection with the conclusion or execution of a contract, e.g. information on the conclusion of the contract, acquired claims and receivables or information on customer satisfaction. We conclude contracts primarily with customers and business partners and job applicants. If you make use of offers from us on the basis of a contract, such as the purchase of products or the use of services, we generally also collect behavioral and transaction data.

Contractual data includes, for example, information on

• about the processing and administration of contracts (e.g. contact details, delivery addresses, deliveries made or failed, and payment information);
• in connection with customer service and assistance with technical matters;
• about our interactions with you (if applicable, a history with corresponding entries);
• about claims and acquired entitlements and benefits (e.g. vouchers);
• about defects and complaints, as well as adjustments to a contract;
• about customer satisfaction, which we can collect by means of surveys;
• in connection with a job application, e.g. curriculum vitae, references, qualifications, certificates, interview notes, etc. (which may also contain personal data of third parties);
• on interactions with you as a contact person or representative of a business partner;
• in connection with security checks (e.g. checking for fraudulent actions on orders) and other checks with regard to the establishment or continuation of a business relationship.

4.3 Communication data

Once you contact us, whether through customer service or through a written or telephone inquiry, we process the communication content exchanged as well as information about the nature, timing and location of the communication. In certain situations, we may also ask you for proof of identity to verify your identity.

Communication data are e.g.

• Name and contact details such as postal address, email address and telephone number;
• Content of emails, written correspondence, chat messages, social media posts, comments on a website, phone calls, video conferences, etc.;
• Responses to customer and satisfaction surveys;
• Details about the nature, time, and possibly location of the communication;
• Proof of identity, such as copies of official identification documents;
• Boundary data of the communication.

We would like to point out that telephone and video conference calls with us may be recorded. If you do not consent to us recording such conversations, you have the option at any time to terminate the conversation and contact us by other means, for example by e-mail.

4.4 Behavioral and transactional data
When you use our offers, make use of our services or make purchases from us, we generally collect data about your usage. This applies, for example, when you store in our online store, are active in our communities or use our websites and apps. If you are acting as an agent for a third party, personal data may also relate to that third party, such as family members for whom you are shopping.

Behavioral and transactional data includes, for example, the following information, insofar as it is available to us on a personal basis:

• about your behavior in online stores (ordered and abandoned shopping cart, watch lists, viewed items, search terms and results, type of payment method, selected delivery method, etc.);
• about your behavior in the Micro Communities (information in your profile, e.g. points and awards earned through gamification, interaction with other members and content, e.g. by means of „follow“ or „like“; ratings, questions and answers about products and other content, discussion posts, etc.);
• about your purchases in stores (e.g., where, how often, what and at what prices you purchase, as well as the type of payment method and delivery method selected);
• about your attendance at our events (e.g. date, place and type of event);
• about your participation in contests, sweepstakes and similar events;
• about your behavior on websites;
• About your installation and use of our mobile apps;
• about your use of electronic communications from us (e.g., whether and when you opened an email or clicked on a link);

You can also use some of our offers anonymously, such as purchases in our stores without registering. However, on our websites and apps, behavioral and transactional data may be associated with your profile even if you are not logged in at the time of visiting the websites or using the app.

4.5 Preference data
We want to tailor our offers and services to our customers in the best possible way and therefore also process data about your interests and preferences. For this purpose, we can link behavioral and transaction data with other data and evaluate this data on a personal and non-personal basis. This allows us to draw conclusions about characteristics, preferences and likely behavior, for example your affinity for certain products and services.

In particular, we can form segments, i.e., groups of people who show similarities with regard to certain characteristics. Preference data can be used in a person-related manner, for example to show you relevant advertising that might interest you. But this data can also be used in a non-person-related manner, for example for market research or product development.

4.6 Technical data
When you use our websites, our apps or other electronic offers, we collect certain technical data such as your IP address or a device ID. Technical data also includes the logs in which we record the use of our systems (log data). In some cases, we may also assign a unique identification number to your end device (tablet, PC, smartphone, etc.) (an ID), e.g. by means of cookies or similar technologies, so that we can recognize it. You can find more details about this in our cookie information.

Technical data typically includes information such as IP address, device and browser type, pages visited or search queries. We may use such data for various purposes, such as to improve our offerings and services, to troubleshoot problems with the website or app, or to prevent fraud or abuse. However, we generally do not use technical data to draw direct conclusions about you, unless you have created a customer account or registered for other offers. In this case, we can link technical data with your master data and thus draw conclusions about your person.

The technical data include

• The IP address of your device and other device IDs (e.g. MAC address);
• Identification numbers assigned to your device by cookies and similar technologies (e.g. pixel tags);
• Information about your device and its configuration, e.g. operating system or language settings;
• Information about the browser you use to access the offer and its configuration;
• Information about your movements and actions on our websites and in our apps;
• Information about your internet provider;
• Your approximate location and the time of use;
• system-side records of accesses and other processes (log data).

Please also note our cookie information for the processing of technical data.

4.7 Image and sound recordings
We regularly take photos, videos and audio recordings in which you may appear, e.g. when you attend an event, have contact with our customer service or participate in a video conference. In doing so, we may receive information about your behavior in the relevant areas. Image and sound recordings include, for example:

• Photos, videos and sound recordings of customer events and public events (e.g. promotional events or sponsoring events);
• Photos, videos and sound recordings of courses, presentations, training sessions, etc.;
• Recordings of telephone and video conference calls (e.g. in customer service or customer consultation).

5. Where does the personal data come from?

5.1 Provided data
As a rule, personal data is provided by the data subjects themselves, for example by submitting data or communicating with us. In particular, this involves master data, contract data and communication data. Preference data is also often provided to us by the data subjects themselves.

For example, they provide us with personal data themselves in the following cases:

• You create a customer account;
• You participate in a sweepstakes or contest;
• You contact our customer service;
• You register for other offers, for example our newsletter.

The provision of personal data is usually voluntary, i.e. you are usually not obliged to provide us with personal data. However, we must collect and process those personal data that are necessary for the processing of a contractual relationship and the fulfillment of associated obligations or are required by law, such as mandatory master and contract data. Otherwise, it is not possible for us to conclude or continue the relevant contract.

If you provide us with data about other persons (e.g. family members), we will assume that you are authorized to do so and that this data is correct. Please also make sure that these other persons have been informed about this privacy policy.

5.2 Collected data
We may also collect personal data about you ourselves or by automated means, for example when you shop with us, use our offers or make use of our services. This often involves behavioral and transactional data as well as technical data (e.g. the time at which you access our websites).

We independently collect personal data about you in the following cases, for example:

• You order a product from one of our online stores;
• You visit one of our websites or use one of our apps;
• You make a purchase in one of our stores, disclosing your customer account;
• You click on a link in one of our newsletters or otherwise interact with one of our electronic promotional communications.

Furthermore, we can also derive personal data from already existing data, such as by evaluating behavioral and transactional data. Such derived personal data is often preference data.

For example, we can analyze the behavioral and transactional data generated by purchases in our online stores and make assumptions about your personal interests, preferences, affinities and habits based on this data. By collecting and analyzing derived personal data, we can tailor our offers and information to your individual needs and interests. In this way, we can send you an individual selection of offers that are relevant to you.

6. For what purposes do we process personal data?

6.1 Communication
Our goal is to respond to your individual concerns. For this reason, we process personal data for communication with you, for example, to respond to inquiries and to maintain the customer relationship. In particular, we use communication and master data and, if the communication takes place within the framework of a contractual relationship, also contractual data. We may also personalize the content and timing of messages based on behavioral, transactional, preference and other data.

The purpose of the communication includes in particular:

• the answering of inquiries;
• contacting you with questions;
• customer service and customer care;
• communicating with you in connection with product recalls (e.g., we may contact you directly if we know you have purchased a product that is subject to a recall);
• The delivery of other notifications (e.g., order status information);
• authentication, e.g. when using our online services;
• quality assurance and training;
• all other processing purposes, insofar as we communicate with you for this purpose (e.g. contract processing, information and direct advertising).

6.2 Contract processing
We would like to offer you the best possible service. For this purpose, we process personal data in connection with the initiation, administration and processing of contractual relationships. Examples of this are the delivery of orders, the provision of services, mediation of purchases and services, building our communities, running loyalty programs or organizing competitions. The execution of contracts may also include the agreed personalization of services. For this purpose, we use in particular master data, contract data, communication data, behavioral and transaction data, and preference data.

The purpose of contract processing generally includes everything that is necessary or appropriate to conclude, execute and, if necessary, enforce a contract.

This includes, for example, processing:

• to decide whether and how (e.g. with which payment options) we enter into a contract with you;
• To provide contracted services, such as delivering goods, providing services, and providing features (including personalized service components);
• to provide customer services and survey customer satisfaction;
• to build and operate micro communities and gamification;
• to run and manage loyalty programs, e.g., to bill and credit earned entitlements and benefits (e.g., promotional vouchers and action codes);
• to determine, notify and, if necessary, publish the winners of contests and sweepstakes;
• to invoice our services and generally for accounting purposes;
• to check the suitability of job applicants and, if necessary, to prepare and conclude the employment contract;
• to check whether we are willing and able to cooperate with a company, and to monitor and assess its performance;
• to prepare and execute transactions under company law, e.g. company acquisitions and sales;
• to enforce legal claims arising from contracts (legal proceedings, etc.);
• to administer and manage our IT and other resources;
• to store data within the scope of retention obligations;
• to terminate and cancel contracts.

6.3 Information and marketing
Our goal is to present attractive offers to you. For this reason, we process personal data for relationship management and marketing purposes, such as the delivery of written or electronic communications and offers and the implementation of marketing campaigns.

Communications and offers may also be personalized in each case in order to send you only information that is likely to be of interest to you. For this purpose, we use in particular master data, contract data, communication data, behavioral data and transaction data as well as preference data, but also image and sound recordings.

This may include, for example, the following communications and offers:

• Newsletters, promotional emails, in-app messages and other electronic messages;
• Advertising brochures, magazines and other printed materials;
• Advertising messages and spots on screens and other advertising spaces;
• Delivery of promotional coupons and promotional codes;
• Invitations to events, sweepstakes and contests.

If you do not wish to receive contacts from us for marketing purposes, you may opt out at any time. For newsletters and other electronic communications, you have the option to unsubscribe from the corresponding service via your customer account or an unsubscribe link in the communication.

We personalize our communications to tailor information specifically to your individual needs and interests and to present you with offers that are relevant to you. This allows us, for example, to send you a customized selection of relevant products or present you with online content tailored to your needs. Personalization also helps you to quickly and easily find the products you are looking for in our extensive online offering. In general, aligning our activities with the needs of our customers enables us to simplify processes such as purchases or sales so that you can achieve your goals more quickly and efficiently.

6.4 Market research and product development
We want to continuously improve our offers and make them more attractive for you. For this reason, we process personal data for market research and product development. In particular, we use master, behavioral, transaction and preference data as well as communication data and information from customer surveys, polls and studies as well as from other public sources such as the media or the Internet. Where possible, we use pseudonymized or anonymized data for these purposes.

Market research and product development include in particular:

• conducting customer surveys, polls and studies;
• the further development of our offers (e.g. design of the product range, choice of location, pricing and action planning, etc.);
• assessing and improving the acceptance of our offers and our communication in connection with offers;
• the optimization and improvement of the user-friendliness of websites and apps;
• the development and testing of new offers;
• the testing and improvement of our internal processes;
• statistical evaluations, e.g., to evaluate information about our customers‘ interactions with us on a non-personal basis;
• assessing the supply situation in a particular market and the behavior of our competitors;
• market monitoring, e.g., to understand and respond to current developments and trends.

6.5 Security and prevention
The security of your data and our systems is our highest priority. For this reason, we also process personal data for security purposes, to ensure IT security, for the prevention of theft, fraud and abuse, and for evidence purposes. This may include all categories of personal data mentioned in section 4, in particular also behavioral and transactional data as well as image and sound recordings. We collect, analyze and store this data for the aforementioned purposes.

The purpose of security and prevention includes, for example:

• making and analyzing (manually and automatically) video recordings to detect and prosecute criminal acts;
• carrying out spot checks to verify the correct recording and payment of goods in our stores;
• issuing house bans and administering house ban lists;
• Analyzing behavioral and transactional data to identify suspicious patterns of behavior and fraudulent activity;
• the evaluation of system-side records of the use of our systems (log data);
• the prevention, defense, and resolution of cyberattacks and malware attacks;
• Analyzing and testing our networks and IT infrastructures, as well as system and error checks;
• Controlling access to electronic systems (e.g., user account logins);
• Documentation purposes and creation of security copies.

6.6 Compliance with legal requirements
In order to comply with legal requirements and to prevent or detect violations, we process personal data. This includes compliance with legal obligations, the receipt and processing of complaints and other reports, the implementation of orders issued by a court or authority, and measures to detect and clarify abuses. This may concern all categories of personal data mentioned in section 4.

Compliance with legal requirements includes in particular:

• The implementation of health and protection concepts;
• clarifications about business partners;
• receiving and processing complaints and other reports;
• conducting internal investigations;
• ensuring compliance and risk management;
• Disclosing information and documents to authorities if we have a factual reason to do so (e.g., because we ourselves are an aggrieved party) or are legally obligated to do so;
• cooperating with external investigations, e.g. by a law enforcement or regulatory authority;
• ensuring the legally required data security;
• the fulfillment of disclosure, information or reporting obligations, e.g. in connection with supervisory and tax obligations, e.g. archiving obligations and for the prevention, detection and clarification of criminal offenses and other violations.

In all cases, we may be subject to both Swiss law and foreign regulations. In addition, we are also bound by self-regulatory, industry and other standards relating to our own „corporate governance“ or official directives.

6.7 Legal Compliance
We want to be able to enforce our claims and defend ourselves against claims by others. For this reason, we process personal data to protect our legal interests. This includes the enforcement of claims in or out of court and the defense against claims before authorities in Germany and abroad. Depending on the circumstances, we process different personal data such as contact details and information about processes that have led or could lead to a dispute.

The purpose of legal defense includes in particular:

• the clarification and enforcement of our claims, which may also include claims of companies affiliated with us and of our contractual and business partners;
• Defending claims against us, our employees, our affiliates and our contractual and business partners;
• the clarification of litigation prospects and other legal, economic and other issues;
• participating in proceedings before courts and authorities in Germany and abroad. For example, we may preserve evidence, clarify litigation prospects, or file documents with a government agency. It may also be that authorities request us to disclose documents and data carriers containing personal data.

6.8 In-house administration and support
Our goal is to make our internal operations efficient. For this reason, we process personal data for Micro’s internal company administration. In particular, we process master data, contract data and technical data, but also behavioral and transaction data as well as communication data.

Internal company administration includes in particular:

• the management of IT and real estate;
• the accounting department;
• the archiving of data and the management of our archives;
• the training and education, e.g. when we evaluate recordings of telephone, video or other communications;
• the central storage and management of data;
• the review or execution of corporate transactions such as company acquisitions, and sales;
• the forwarding of inquiries to the appropriate authorities;
• the sale of receivables, where we provide the acquirer, for example, with information on the reason for and amount of the receivable and the behavior of the debtor;
• in general, the review and improvement of internal processes.

7. On what legal basis do we process personal data?
Our processing of personal data is based on various legal bases, depending on the purpose of the data processing. In particular, we may process personal data if the processing:

• is necessary for the performance of a contract with the data subject or for pre-contractual measures (e.g. the review of a contract application);
• is necessary for the exercise of legitimate interests, for example when data processing is a central part of our business activities;
• is based on consent;
• is necessary for compliance with domestic or foreign legal provisions.

We have a legitimate interest in particular in the processing for the purposes described in section 6 above and in the disclosure of data in accordance with section 8 and the objectives associated with each of these. The legitimate interests in each case include our own interests and the interests of third parties.

These legitimate interests include, for example, the interest in

• to supply products and services to third parties (e.g. to persons receiving gifts);
• to provide good customer service, to maintain contacts and to communicate with customers also outside of a contract;
• advertising and marketing activities;
• to get to know our customers and other people better;
• improving products and services and developing new ones;
• internal company administration;
• fighting fraud, for example in online stores, and preventing and investigating crimes;
• protecting customers, other persons and data;
• ensuring IT security, especially in connection with the use of websites, apps and other IT infrastructure;
• ensuring and organizing business operations, including the operation and further development of websites and other systems;
• in the management and development of the company;
• in the sale or purchase of companies, parts of companies and other assets;
• in the enforcement or defense of legal claims;
• in compliance with Swiss and foreign law and internal rules.

8. To whom do we disclose personal data?

8.1 Within the company
We may share personal data that we have received from you or from third party sources with internal departments of our company. Such disclosure may serve various purposes, such as supporting internal company administration. This includes personalization of marketing activities, development and improvement of products and services, and measures to prevent theft, fraud and abuse.

This may involve, for example, the following data disclosures:

• All categories of personal data mentioned in section 4 for the administration and processing of contractual relationships, in particular in connection with products and services involving the performance of several departments;
• Master data, contract data, communication data, behavioral and transaction data, and preference data, as well as findings from customer surveys, polls, studies, and image and sound recordings for market research and product development, to the extent that a personal reference to such data is necessary;
• Master data, contract data, communication data, behavioral and transaction data, preference data as well as image and sound recordings for the delivery and personalization of offers, communication and marketing activities;
• Master Data, Contract Data, Communications Data, Behavioral and Transactional Data, and Preference Data for fraud and abuse prevention;
• Master data, behavioral and transactional data, and image and sound recordings for theft prevention and evidentiary purposes;
• Security-related information for security and legal compliance purposes;
• Information to assist in law enforcement.

8.2 Outside the company
If we use services of companies outside Micro Mobility Systems AG, we are entitled to pass on your personal data to these companies. As a rule, these service providers process personal data on our behalf as so-called „order processors“.
Our order processors are obliged to process personal data exclusively in accordance with our instructions and to take appropriate data security measures. With some service providers, we are jointly or they are independently responsible for data processing. We ensure that data protection is guaranteed throughout the processing of your personal data by selecting suitable service providers and corresponding contractual agreements.

This involves, for example, services in the following areas:

• Forwarding and logistics, e.g. for the shipment of ordered goods;
• Advertising and marketing services, e.g. for sending notices and information;
• Warranty and return services, e.g. for repair in case of defects.
• Business administration, e.g., accounting or asset management;
• Payment services;
• Fraud prevention services that payment service providers perform under their own responsibility. Corresponding procedures are only applied if you are already a customer of the respective payment service provider. More detailed information is then available in the privacy policy of the respective service provider;
• IT services, e.g. services in the areas of data storage (hosting), cloud services, sending e-mail newsletters, data analysis and refinement, etc.;
• Consulting services, e.g. services provided by tax consultants, lawyers, management consultants or consultants in the field of personnel recruitment and placement.

There is also the possibility that we pass on personal data to other third parties, for example for their own purposes, if you have given us your consent or if we are legally obliged or entitled to pass on the data. In such cases, the recipient of the data is an independent data controller under data protection law.

This includes, for example, the following cases:

• the information on product recalls.
• the transfer of receivables to other companies;
• the examination or execution of transactions under company law, such as company acquisitions and sales;
• the disclosure of personal data to courts and authorities in Switzerland and abroad, e.g. to law enforcement authorities in the event of suspected criminal acts;
• the processing of personal data in order to comply with a court order or official directive or to assert or defend legal claims or if we consider it necessary for other legal reasons. In doing so, we may also disclose personal data to other parties to the proceedings.

We would like to point out that our websites and apps include third-party tools that are able to collect data independently. Please also refer to our cookie information.

As a rule, we are not subject to any professional confidentiality obligation, as is the case, for example, with banking or medical confidentiality. However, if you believe that certain personal data is subject to a duty of confidentiality, please let us know so that we can review your request.

9. How do we disclose personal data abroad?
We generally process and store personal data within Switzerland and the European Economic Area (EEA). However, in some cases, we may disclose Personal Data to service providers and other recipients outside of these regions or have Personal Data processed outside of these regions, generally in any country in the world. The countries concerned may not have laws that ensure the same level of protection for your personal data as in Switzerland or the EEA. However, if we transfer your personal data to such a country, we will ensure the protection of your personal data in an appropriate manner.

One means of ensuring adequate data protection is, for example, the conclusion of data transfer contracts with the recipients of your personal data in third countries that ensure the necessary data protection. These include contracts that have been approved, issued or recognized by the European Commission and the Federal Data Protection and Information Commissioner, so-called standard contractual clauses. An example of the data transfer contracts we typically use can be found here. Please note that such contractual arrangements may partially compensate for weaker or missing legal protection, but cannot completely exclude all risks (e.g., of government access abroad). In exceptional cases, the transfer to countries without adequate protection may also be permissible in other cases, e.g. based on consent, in connection with legal proceedings abroad or if the transfer is necessary for the performance of a contract.

10. How do we use profiling?
The term „profiling“ refers to the automated processing of personal data to analyze personal aspects or to make predictions, for example by analyzing personal interests, preferences, inclinations and habits or predicting likely behavior. Profiling can be used, in particular, to identify preference data.

Profiling is a common process, e.g., in automated processing

• of master data, contract data, behavioral data and transaction data for purchases in our online stores and stores;
• of behavioral and transactional data as well as technical data in connection with our websites and apps;
• of data in connection with visits to events, or participation in contests, sweepstakes and similar events;
• of communications data, such as your response to promotional and other communications;
• of other behavioral and transactional data.

Profiling helps us do this, for example,

• to continuously improve our offerings and better align them with individual needs;
• to present our content and offers to you in a way that is tailored to your needs;
• to provide you, as far as possible, only with advertising and offers that are likely to be relevant to you;
• to better assist you with customer service;
• to decide which payment options are available based on a credit check.

Within the scope of our online store, we carry out profiling by evaluating your shopping behavior and assigning you to certain interests on this basis. These interests can be formed both permanently and on a case-by-case basis and relate, for example, to your purchase motive. With the help of this profiling, we can, for example, send you relevant product suggestions via newsletter.

Profiling is also carried out in connection with your customer account by evaluating your usage and purchasing behavior on our websites and apps as well as in our online store. This enables us to provide you with an individual user experience and to make tailored offers according to your interests.

To improve the quality of our analyses and forecasts, we may also link personal data from different sources as a basis for profiling, e.g. data collected via various of our services. This may also involve the use of self-learning algorithms (certain programming in computer programs).

You can object to profiling in certain cases as described in section 14.

11. Do we make automated individual decisions?
„Automated individual decisions“ are decisions that are fully automated, i.e., without human influence, and that have legal consequences for the data subject or otherwise significantly affect him or her. We generally do not do this, but will inform you separately should we use automated individual decisions in individual cases. If you do not agree with the automated decision, you have the right to request a human review of that decision.

12. How do we protect personal data?
To ensure the security of your personal data and to protect it from unauthorized or unlawful processing, loss, accidental loss or alteration, unauthorized disclosure or access, we take appropriate technical and organizational security measures. However, as with all companies, data security breaches cannot be completely ruled out, as certain residual risks are unavoidable.

Security measures of a technical nature include, for example, the encryption and pseudonymization of data, logging, access restrictions and the storage of backup copies. Organizational security measures include, for example, instructions to our employees, training and controls. In addition, we require our order processors to take appropriate technical and organizational security measures.

13. how long do we process personal data?
We process and store your personal data,

• as long as it is necessary for the purpose of the processing or purposes compatible with it, in the case of contracts usually at least for the duration of the contractual relationship;
• as long as we have a legitimate interest in storing it. This may be the case in particular if we need personal data to enforce or defend claims, for archiving purposes and to ensure IT security;
• as long as they are subject to a legal obligation to retain them. For certain data, for example, a ten-year retention period applies. For other data, shorter retention periods apply in each case, e.g. for recordings from video surveillance or for recordings of certain processes on the Internet (log data).

In some cases, we also ask for your consent to store personal data for a longer period of time (e.g., for job applications that we want to keep pending). After expiration of the above-mentioned periods, we will delete or anonymize your personal data.

We are guided by the following retention periods, for example, although we may deviate from these in individual cases:

• Customer account: Personal data is stored for the duration of the customer account. If a deletion of the customer account is ordered, the data will be deleted at the latest after 30 days following a review of outstanding claims as well as other relevant points that prevent immediate deletion.
• Contracts: We generally retain master and contract data for ten years from the last contract activity or from the end of the contract. However, this period may be longer if this is necessary for reasons of evidence, legal or contractual requirements or for technical reasons. Transaction data related to contracts is generally retained for ten years.
• Technical data: Cookies are usually stored for between a few days and two years, unless they are deleted immediately after the end of the session.
• Communication data: Emails, messages via contact form and written correspondences are usually kept for ten years.
• Image and sound recordings: The retention period varies depending on the purpose. This ranges from a few days for security camera recordings to several years for reports on events with pictures.
• Job applications: We generally delete job application data within six months of completing the application process. With your consent, we may keep your application pending with a view to possible subsequent employment.

14. What rights do you have in connection with the processing of your personal data?
You have the right to object to the processing of your personal data, in particular if we process your personal data on the basis of a legitimate interest and the other applicable conditions are met. In addition, you can object at any time to the processing of your personal data in connection with direct marketing (e.g. promotional e-mails). This also applies to profiling, insofar as this is connected with such direct marketing.

Insofar as the respective applicable requirements are met and no legal exceptions apply, you also have the following rights:

• the right to request information about your personal data stored by us;
• the right to have incorrect or incomplete personal data corrected;
• the right to request the deletion or anonymization of your personal data;
• the right to request the restriction of the processing of your personal data;
• the right to receive certain personal data in a structured, common and machine-readable format;
• the right to revoke consent with effect for the future, insofar as processing is based on consent.

Please note that these rights may be restricted or excluded in individual cases, e.g. if there are doubts about the identity or if this is necessary to protect other persons, to protect interests worthy of protection or to comply with legal obligations. In such cases, however, we will always inform you transparently and explain the reasons for any restriction or exclusion.

You can exercise the most important of the above rights via our contact form. If you have a customer account, you can correct your master data stored there (e.g. your address) at any time. In addition, you can unsubscribe from newsletters and other promotional emails by clicking on the appropriate link at the bottom of the email. You can also contact us in accordance with section 15 if you wish to exercise any of your rights or if you have any questions about the processing of your personal data.

If you have concerns that we are not processing your personal data in accordance with the law, you can contact a competent supervisory authority at any time and lodge a complaint. The supervisory authority will then investigate your complaint and, if necessary, take measures to ensure compliance with data protection regulations.

The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commiccioner (FDPIC).

15. How can you contact us?
If you have any questions about this privacy policy or the processing of your personal data, you can also contact us as follows:

Micro Mobility Systems AG
Bahnhofstrasse 10
8700 Küsnacht
Switzerland

(+41) 044 910 11 22
info@micro.ms

16. changes to this privacy policy
This Privacy Policy may be amended over time, in particular if we change our data processing practices or if new legislation becomes applicable. We will actively inform persons whose contact details are registered with us of such changes in the event of significant changes, if this is possible without disproportionate effort. In general, the data protection statement in the version current at the start of the processing in question applies to data processing in each case.

Last changes: 23.05.2023

INFORMATION ABOUT COOKIES AND SIMILAR TECHNOLOGIES

1. What is it about?
2. Who is responsible for data processing?
3. What is log data?
4. What are cookies and similar technologies?
5. How to disable cookies and similar technologies?
6. What types of cookies and similar technologies do we use?
7. How do we use cookies and similar technologies from other companies?
8. How do we use social media sites?
9. Changes to this cookie information

1. What is it about?
This Cookie Information describes how and for what purpose we collect, process and use personal and other data when using our websites and Mobile Apps – especially in connection with cookies and similar technologies. We use the term „websites“ for simplicity, but the term also includes Mobile Apps.

For more information about our handling of personal data, please see our privacy policy.

2. Who is responsible for data processing?
Micro is responsible for the processing of Personal Data in accordance with this Cookie Information. If you have any questions about this Cookie Information or the processing of your personal data, please feel free to contact us as follows:

Micro Mobility Systems AG
Bahnhofstrasse 10
8700 Küsnacht
Switzerland

(+41) 044 910 11 22
info@micro.ms

3. What is log data?
For technical reasons, every time you use our websites, certain data is automatically generated and temporarily stored in log files, also known as log data. This is, for example, the following technical data:

• IP address of the requesting end device,
• Information about your Internet service provider,
• Information about the operating system of your end device (tablet, PC, smartphone, etc.),
• Information about the referring URL,
• Information about the browser used,
• date and time of access, and
• content accessed when visiting the websites.

This data is processed with the aim of enabling the use of our websites (e.g. connection establishment), ensuring their functionality, guaranteeing system security and stability, optimizing our Internet offering and performing statistical evaluations.

The IP address is evaluated together with the other log data and, if necessary, other data that we have in order to clarify and ward off attacks on our IT infrastructure or other unauthorized or abusive use of our websites. If necessary, this data will be used in the context of criminal proceedings to identify the persons concerned and to take legal action against them.

4. What are cookies and similar technologies?
When you visit our websites, your browser automatically stores files called cookies on your terminal device. These cookies contain a unique identification number (ID) that allows us to distinguish individual visitors from others, but usually without identifying them. Depending on the intended use, cookies may contain further information, e.g. about pages visited and the duration of the visit. We use both session cookies, which are deleted when the browser is closed, and persistent cookies, which remain stored for a certain period after the browser is closed (usually between a few days and two years) and are used to recognize visitors on a subsequent visit.

In addition, we may use similar technologies such as pixel tags and other technologies to store data in the browser. Pixel tags are small images or program code that are not normally visible and are loaded by the server. This allows the server operator to obtain certain information, such as whether and when our web pages were visited. Most browsers also support other technologies for storing data in the browser, similar to cookies, which we may also use (e.g. „web storage“).

5. How can cookies and similar technologies be disabled?
You have the option of setting your browser to block certain cookies or similar technologies or to delete existing cookies and other data stored in the browser. You can do this in the settings of your browser. You can also enhance your browser with software (so-called „plug-ins“) that blocks tracking by certain third parties. You can find out more about this in the help pages of your browser (usually under the heading „Privacy“). Please note that blocking cookies and similar technologies may result in our websites no longer functioning to their full extent.

6. What types of cookies and similar technologies do we use?
We use the following types of cookies and similar technologies:

• Essential cookies: Essential cookies are required in order to use a website and its functions. These cookies ensure, for example, that you can switch between pages without losing the information entered in a form or the products placed in a shopping cart.
• Performance cookies: Performance cookies collect information about how a website is used and enable us to perform analyses, e.g. which pages are most popular and how visitors* move around a website. These cookies are used to simplify and accelerate the visit to the website and generally improve the user experience.
• Functional cookies: Functional cookies allow us to provide advanced functionality and display personalized content. These cookies allow us, for example, to save information you have already provided (e.g. language selection) or to show you products you might also like based on articles you have viewed.
• Marketing cookies: Marketing cookies help us and our advertising partners to address you on our websites and on websites of third parties with advertisements for products or services that may be of interest to you, or to display our advertisements during your further internet use after visiting our websites.

7. How do we use cookies and similar technologies from other companies?
Our cookies and/or similar technologies used may originate from both us and third party companies, especially when we use features provided by third parties. These third parties may be located both inside and outside the European Economic Area (EEA) and Switzerland, provided that appropriate safeguards are in place to protect the privacy of your personal data.

For example, we use analytics services to evaluate how you use our websites in order to optimize and personalize them. Cookies and similar technologies from third-party providers also enable them to target you with individualized advertising on our websites or on other websites and social networks that also work with that third party and to measure how effective advertisements are (e.g., whether you arrived at our websites via an advertisement and what actions you then take on our websites).

It is possible that certain third-party providers may be able to view and store some of the usage of the relevant website. This information can be combined by the respective provider with similar data from other websites. The behavior of certain users can thus be recorded across multiple websites and across multiple end devices. The respective provider may also use this data for its own purposes, e.g. for personalized advertising on its own websites and on other websites that it supplies with advertising. If users are registered with the provider, the provider can assign the usage data to the relevant person. The processing of such personal data is carried out here by the provider under its responsibility and in accordance with its own data protection provisions.

7.1 We use these services:

Google Analytics
On our websites, we use Google Analytics, an analysis service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA, USA) and Google Ireland Ltd. (Google Building Gordon House, Barrow St, Dublin 4, Ireland; both together „Google“, whereby Google Ireland Ltd. is responsible for the processing of personal data). Cookies and similar technologies are used to collect certain information about the behavior of individual users on or in the relevant websites and the end device used for this purpose (tablet, PC, smartphone, etc.) (e.g. how often you have opened our websites, how many purchases have been made or what your interests are, as well as data about your end device used, such as the operating system). You can find more information about this under this link.

We have adjusted the configuration of the service so that the IP addresses of visitors to our websites are shortened by Google within Europe to avoid tracing. Google provides us with reports and acts as a processor in this context. However, Google also uses certain data for its own purposes and may create cross-device reports with data from users who have activated personalized advertising.

If you are logged in to your Google account and visit our website, Google may be able to draw conclusions about your identity and create personal profiles based on the data collected. In addition, Google may link the collected data to your Google account. Information on Google Analytics privacy can be found here, and if you have a Google account yourself, you can find more details here.

Facebook Custom Audiences
Our websites may use the so-called „Facebook Pixel“ and similar technologies from Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland („Facebook“). We use these technologies to display the advertising (Facebook Ads) commissioned by us only to users on Facebook and on the partners cooperating with Facebook (so-called „Audience Network„) who have shown an interest in us or whose characteristics correspond to those that we transmit to Facebook for this purpose (e.g. interest in certain topics or products that are apparent from the websites visited; „Custom Audiences“). With the help of these technologies, we can analyze the effectiveness of Facebook ads for statistical and market research purposes by checking whether users* were redirected to our website after clicking on a Facebook ad (so-called „conversion measurement“). You can find more information about this here.

Together with Facebook, we are responsible for the exchange of data that Facebook collects or receives via the pixel or similar functions. This is for the purpose of displaying advertising information that matches users‘ interests, improving ad delivery, and personalizing features and content. However, we do not share responsibility for the further processing of this data.

Google Tag Manager
On our websites, we use the Google Tag Manager to collect data on user behavior and forward it to our analysis tools. The Google Tag Manager does not have access to the data, but merely collects it. Since the Google Tag Manager itself does not process any personal data, the explanations regarding the respective tracking services and the usage guidelines of the Google Tag Manager apply. You can find further details here.

Bing Universal Event Tracking
Bing Universal Event Tracking (UET) allows us to track and analyze visitor behavior on our websites. This provides valuable information to measure conversions, optimize return on investment (ROI), and better understand the target audience. Through UET, companies can also accurately track visitor behavior on the website, such as the number of visits to a page, dwell time, and clicks on specific links.

Facebook Domain Insights
Facebook Domain Insights is a tool that allows us to analyze the performance of our websites on Facebook. It shows us how many people visit our websites and how they interact with them. It also provides insights into how much users pay when they click on Facebook ads linked to our websites. Facebook Domain Insights allows us to compare the performance of our different pages and find out which ones are performing better than others. It is also an important tool to evaluate the overall performance of our websites.

US Privacy User Signal Mechanism
We use the US Privacy User Signal Mechanism on our websites to allow users to give or withhold consent to the processing of their personal data. This mechanism can be implemented in a variety of ways, such as an opt-in or opt-out system that allows the user to choose which data may or may not be processed.

Usercentrics
By using Usercentrics software, we can customize our websites and consent forms to meet your legal requirements. This software allows us to personalize, monitor and manage consent forms to ensure that all users give the necessary consent to process their data. It also provides users with the ability to better control their data by allowing them to modify or revoke their consent at any time.

Wallee
App-wallee is a provider of online payment solutions and acts as a payment service provider. The cookies associated with this domain support the optimization of payment processing and the maintenance of session information. In addition, cookies are used with a focus on security to protect against cross-site request forgery (CSRF) attacks. They store a unique token that is checked when forms are submitted to verify the authenticity of the request. Likewise, cookies are used to store the user’s preferred language or language settings on a website. This ensures that the content is displayed in the language chosen by the user.

Hotjar
Hotjar is a web analytics tool that provides information about user behavior on a website. The domain static.hotjar.com is used to provide static resources relevant to Hotjar’s tracking and analytics features. This domain is closely associated with Hotjar and provides JavaScript files necessary for Hotjar’s tracking and analytics services. Another domain associated with Hotjar, in.hotjar.com, is used to collect and process user behavior data for analytics and feedback purposes. It serves as a platform for displaying dynamic content such as surveys or feedback widgets that can be displayed on websites to engage with users.

Hotjar uses cookies to track user sessions on websites for analytics purposes. These cookies play a role in identifying a user’s first visit to a website and are used for analytics and tracking. They also indicate whether a user is included in the data sample used to generate analytics reports. Hotjar cookies are crucial for monitoring user sessions on websites and are essential for Hotjar’s analytics capabilities. Some Hotjar cookies specifically track the duration of a user’s session on a website for analytics purposes.

8. How do we use social media appearances?
We have the ability to operate our own presences on social networks and similar third-party platforms, such as Facebook fan pages. If you communicate with us via such presences or comment on or redistribute content from us, we collect corresponding information and process it in accordance with our privacy policy. We reserve the right to check content before or after it is published and, if necessary, to remove it without notice if this is technically possible, or to report it to the provider of the relevant platform. If rules of decency and conduct are violated, we may also report the user account in question to the provider of the platform for blocking or deletion.

When you visit our social media sites, data, such as information about your user behavior, may be transmitted directly to or collected by the respective provider. This data may be processed together with other information already known to the provider, for example for marketing and market research purposes or to personalize the platform content. Further information on data processing by social network providers can be found in the privacy policies of the respective platforms.

9. Changes to this cookie information
This Cookie Information may be adapted over time, especially if we change our data processing practices or if new legislation becomes applicable. In general, the Cookie Information in the version current at the start of the processing in question will apply to data processing in each case.

Last changes: 23.05.2023