Global privacy statement

Privacy is about more than just protecting you when you share your personal information when you use our products and services, or when you use our websites. Privacy is also about our obligation to collect, use and disclose this information only for the purposes we’ve explained to you.

Exro is committed to protecting the confidentiality of your personal information and abiding with privacy regulations in all countries where we operate and conduct our business.

Our privacy commitment is about more than complying with applicable privacy laws. It’s about doing the right thing and respecting your right to have the information you share with us protected and responsibly handled. 

Our three essential promises to you are —

  1. We use Client data to deliver on our Purpose
  2. We do not sell Client data
  3. We inform Clients about why we collect and use their data

Our Global Privacy Statement (“Statement”) applies to all our wholly owned subsidiaries and operations worldwide. We always strive to be more transparent about our privacy practices. This Statement provides an overview of how we collect, use and protect personal information belonging to anyone that interacts with us including clients, business partners or other third parties in our global business activities. 

This Statement applies when you connect with us through our call centres and other communication channels. We also provide more detailed information about your interactions with us when you visit our authorized websites, mobile apps and other electronic platforms (“Digital Properties”). 

It’s our global commitment to use only fair and legal means to collect your information. We use it in a legal, respectful and fair manner. We comply with local laws and regulatory requirements in each country we operate in. For information about our local privacy practices, you can read our local policies below.

Local Privacy Policies

Please click below to read the privacy policies for specific countries where Exro currently offer services.

United Kingdom & Europe

Canada

United States Californian Residents

Personal information

Personal Information or data means information about an identifiable individual. This includes factual or subjective information from which an individual’s identity can be reasonably determined. It also includes data points that when combined with other information could identify an individual. This may be your contact, health, financial or lifestyle information, or feedback you provide through surveys. It doesn’t include aggregate or anonymous data because that information does not identify an individual.

What personal information we may collect from you
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We collect personal information from you that’s necessary to:

  • deliver products and services
  • enhance your experience and interactions with us
  • manage our business operations
  • fulfil our legal and security obligations 

You don’t have to provide personal information to use our Digital Properties unless a particular feature requires it. Here are some situations that will require you to provide personal information:

  • accessing your account online or through a mobile app 
  • signing up for a newsletter 
  • applying for a product online

We maintain appropriate procedures to ensure that personal information in our possession and the information we exchange with our service providers and agents is accurate and kept up to date. As permitted by applicable law, you can request to access and correct your personal information. 

Children’s information

We don’t knowingly collect information from or market products and services directly to children under the age of majority. We only collect information about children from parents or legal guardians when they are covered under their policies or assigned as beneficiaries.

What other data we collect through our Digital Properties
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We collect and analyze data related to your use of our Digital Properties to evaluate and improve functionality, user experience and the effectiveness of our advertising and marketing activities. 

We may also share aggregated, anonymous data with third parties. This data cannot directly identify you.  

We may combine some of the data we collect through our Digital Properties with other data we have about you for analytics.

Examples of the data we collect for this purpose may include: 

  • your IP address
  • your device information such as your operating system, browser version and screen resolution 
  • your approximate location  
  • how you arrive at our Digital Properties (i.e. traffic sources)
  • whether you are a new or repeat visitor
  • what pages on our Digital Properties you view 
  • how long you stay on our Digital Properties
  • what links you clicked on 
  • whether you viewed any videos  
  • what you search for on our Digital Properties
  • information you have voluntarily provided through surveys and forms on our Digital Properties

We use this data to improve your digital experience: 

  • evaluate and enhance site performance, user experience and functionality
  • gather insights that will help us improve our products and services
  • increase the relevancy of marketing campaigns
  • make our content easier to find in both internal and external search engines
How we safeguard your information
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We maintain technical and organizational safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. We limit access to those who have a business need to know. We want to provide our website visitors with more information that may be helpful to them. That’s why some of our websites contain links to other websites that are not affiliated with or maintained by us. We are selective about the websites we link to, but we don’t monitor or manage the privacy practices of these third-party websites. As a result, we can’t assume any responsibility for the data collection policies and procedures of these websites.

How we use your data

We are committed to providing you with meaningful information about the purposes for which we use your personal information.

How we use your information
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Some examples of how we use your personal information:  

Delivering products and services 

  • manage your accounts and provide administrative support
  • understand your needs and suitability of our products
  • provide you with updates on your accounts, products and services
  • investigate complaints and respond to inquiries

Enhancing your experience and interactions with us 

  • personalize and improve your experience while using our Digital Properties
  • better understand your interest in our products and services 
  • better understand your preferences, needs and how you use our Digital Properties
  • deliver targeted and personalized marketing 

Managing our business operations

  • analyze and improve our internal business processes
  • develop products and services
  • determine effectiveness of our marketing and advertising 
  • evaluate and improve the functionality of our Digital Properties

Fulfilling security and legal obligations 

  • confirm your identity to make sure no one else is accessing your information, enhance digital security, implement risk management programs and procedures to protect against fraud, errors or misrepresentations
  • meet regulatory or contractual requirements

We may need to use your information in other ways, as required by law. If we need to use your information for any other purposes, we will do so only with your consent.

Why we share your information
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We are responsible for protecting the confidentiality of all personal information in our possession. That includes information transferred to third parties performing services on our behalf such as our agents, service providers or our affiliates, along with our reinsurers. When third parties store or process your information outside the country where it was collected, we follow all local laws. In those cases, the processing of your personal information may be subject to the laws of those other countries. We always require that these third parties protect your personal information consistent with our privacy policies and practices and comply with relevant laws.

We are careful what information we share and why. We aim to limit the personal information we share with third parties to what is needed for the service they provide.

Here are some of the services third parties provide:

  • providing cloud hosted digital solutions and advanced technologies
  • facilitating marketing campaigns, surveys and market research activities

In some cases, laws require us to share information with regulators or government agencies.

What are your basic privacy rights?
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We inform you why we collect, use and share your personal information. In some cases, we may request your express consent for the use of your personal information. You have a choice to withdraw your consent for processing of your personal information. Sometimes, this is not possible because of legal or contractual requirements. Withdrawing your consent may limit our ability to provide you with a full range of services. Here are some of the choices you may have depending on your jurisdiction: 

  • You may request not to receive marketing and other commercial messages.
  • You may choose to communicate with us and provide your information using multiple channels: digital, telephone or regular mail.
  • You have a number of options to manage cookies. If you choose to delete or refuse cookies, or choose not to share certain device information, some functionalities on our Digital Properties may not be available to you. 

Digital Properties Explained

Our use of cookies and other tracking technologies
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Our Digital Properties may use cookies and other tracking technologies, such as pixel tags and web beacons. Here are some of the ways we use these technologies:

  • help us better understand how our websites and mobile apps are being used 
  • measure the effectiveness of our advertising and marketing activities 
  • support our security and fraud prevention efforts

A cookie is a small file of data that a website or mobile app sends and stores on your device. The next time you visit our website or mobile app, we may use the information stored in your cookie to make your visit easier. A cookie doesn’t tell us your identity unless you have chosen to provide it to us. Cookies can’t access information or files from your device.

There are two types of cookies: session cookies and persistent cookies.

  • A session cookie is erased when you close your Internet browser and leave our website or mobile app. 
  • A persistent cookie is a file that remains on your device when you close your Internet browser. Only the website that created the cookie can read it when you revisit that site.

Cookies can be used to identify a visitor only if the visitor has used a website's login feature. Sometimes you may ask us to save your access ID for use the next time you visit our website or mobile app. In that case, we’ll use a cookie or a mobile secure storage to store your access ID in an encrypted format on your device. The website or mobile app will recognize you the next time you visit and sign in. In this way, we can recall your preferences and provide a more customized experience.

Persistent cookies have expiry dates and are automatically deleted from your device after that date. You can also clear your stored cookies through your browser preferences on your device. Unless you have settings that disallow cookies, the next time you visit our website or mobile app, a new cookie will be added. 

You can set your website browser to notify you when you receive a cookie, so you can decide whether to accept or reject it. You can also use your device settings to control whether certain information is collected, such as geolocation or certain device information. You may choose not to accept cookies or not to provide location and other device information. In those cases, you may notice some digital services may not function effectively

Our use of data analytics
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We use advanced data analytics technologies such as Google analytics so we’re able to: 

  • make better decisions about our business processes 
  • offer you more relevant products and services
  • personalize interactions through all our communication channels 

We use multiple data points collected through various business lines and communication channels to understand your needs.  

We use your information for analytics in a respectful and fair manner 

Advanced analytics helps us be more relevant to you and conduct our business in a more efficient way. We also use analytics insights to innovate and implement new technologies and automation.

Vehicle Data Collection and Usage

SEA Electric commercial vehicles are equipped with a Geotab® fleet management device that generates vehicle and diagnostic data which by default is accessible, and may be collected, by Exro. Exro does not associate such vehicle data with any individuals but simply with the VIN of the vehicle for servicing, safety recall, and R&D purposes.

We collect vehicle data (e.g., vehicle performance, usage, operation, condition and health, charging station use, utilization, charge rate, battery analytics, and VCU software, service, and maintenance logs) to provide maintenance services, facilitate repairs, fulfill customer requests, convey important safety-related information, improve the quality of our new and existing products and services, and fulfill our contractual obligations.

The fleet owner of any Vehicle may opt-out and decide to no longer allow Exro to collect vehicle data by emailing us at legal@exro.com. Please note, that this will negatively impact the ability of Exro to service such vehicles, provide over-the-air updates. 

We may only share vehicle data information with our affiliates, insurance companies, dealers, R&D/manufacturing/channel partners, and any successor entities. We may also use and disclose vehicle data when disclosure is necessary or appropriate or when the law requires (e.g., subpoenas, court orders, law enforcement, etc.). 

From time to time, we make material changes to this vehicle data-related Privacy Policy. When we do so, we will revise the date of this Policy on our website and may provide you with additional direct notice by email or over-the-air update. Such changes shall be effective and supersede the above terms on the date we post them on our website.