Gemini Electric Mobility Co., Privacy Policy Last updated January 31, 2021 Gemini Electric Mobility Co. ("we" or "Gemini") is committed to protecting your privacy and informing you about how your information is used. This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of information that is collected through our website, mobile application, and any other mobile or online service owned and offered by Gemini (our “Service”). Personal Information We Collect From You We collect personal information from you in order to provide our Service and offer you a personalized, useful, and efficient experience. The categories of personal information we collect can include: Identifying Information You provide us information about yourself, such as your name, age, address, email address, university or other affiliation, and password, when you register for an account with the Service. We may also collect a copy of your driver’s license and billing and payment information if you utilize our Service. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses. We may also retain any messages you send through the Service. You may provide us information in user content you post to the Service. Payment Information Gemini collects users’ personal payment information, including information stored on outside services that users may use with Gemini, such as PayPal. By submitting payment information and/or linking a Gemini account with an outside payment service such as PayPal, users authorize Gemini to access and use this information in order to provide users with, and accept payment for, the Service. This allows Gemini to both confirm a User's identity and provide users with seamless, hassle-free transactions. Gemini uses Stripe to process payments from users related to transactions passed on our platform. By utilizing the services of Gemini or otherwise agreeing to Gemini's privacy policy, users authorize Stripe to collect, use, retain, and disclose their personal data in accordance with Stripe's privacy policy, located at Driver's Record We check your driver's record to make sure you and your car meet Gemini safety standards. By registering with Gemini, you authorize us to access your driver's record from state DMVs, RMVs, and other applicable entities, and this authorization extends to Gemini throughout the entire time you use our Service, so that Gemini may re-check your records from time to time. You also authorize said entities to release this information to Gemini. Vehicle History and Inspection If you own a vehicle that is used on Gemini, we may inspect the vehicle, collect information identifying the vehicle (like a license plate number, VIN), and obtain a vehicle history report to make sure the vehicle is safe for you and other drivers to use. By registering with Gemini, you authorize us to obtain this information, and you authorize applicable entities such as DMVs, RMVs, inspection companies, and auto mechanics to release such information to Gemini. Social Media When you interact with our Service through various social media, such as when you log in through Facebook or when you like or post a comment to our Facebook page or interact with us on other social media, we may receive information from the social network, such as your profile information, profile picture, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and, if necessary, adjust your privacy settings on thirdparty websites and services before linking or connecting them to Gemini’s Service. We use personal information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages and push notifications, and permit you to communicate with others on the Service or on social media or invite others to join the Service. We may also use information to provide personalized content, including advertising. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see Your Choices Regarding Your Information below. Usage Information We Collect The location of all Gemini cars you use is tracked by GPS (or equivalent), cellular, WiFi, Bluetooth, or similar technologies. Location information is shared in limited ways. We monitor the location of all cars to provide our Service, to prevent theft, and to allow us to locate you in case of accident, emergency, lock-out, etc. to the extent allowed under, and in accordance with, applicable laws. We may maintain location data in order to aggregate trends and metrics and may share de-identified and/or aggregate location and movement data with third parties for advertising, research, analytics, and other purposes to the extent allowed under, and in accordance with, applicable laws. We may share location information in some instances as described below. As a user, you acknowledge and understand that dashboard cameras, mileage and location tracking devices, and other similar devices may be installed in the cars listed on Gemini. Use of Cookies and Other Technology to Collect Information When you visit our website or use our mobile app or Service, we and our business partners may collect certain information about your computer or device through technology such as cookies, web beacons, log files, or other tracking/recording tools. The information we collect through the use of tracking technologies includes but is not limited to IP address, browser information, referring/exit pages and URLs, click stream data and information about how you interact with links on the website, mobile app, or Service, domain names, landing pages, page views, and cookie data that allows us to uniquely identify your browser and track your browsing behavior on our site. We may also use clear gifs or other technology in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. Some or all of this data may be combined with other personally identifying information described above. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. We may work with third parties to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time. When you access our Service by or through a mobile device, we may receive or collect and store a unique identification number associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID or other identifier), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude), WiFi location, or similar information regarding the location of your mobile device. We use or may use the data collected through these technologies to: (i) remember information so that you will not have to re-enter it during your visit; (ii) provide custom, personalized content and information, including advertising; (iii) identify you across multiple devices; (iv) provide and monitor the effectiveness of our Service; (v) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (vi) diagnose or fix technology problems; and (vii) otherwise to plan for and enhance our service. Calls and text messages We enable users to call or text Gemini representatives for support related inquiries. To provide this functionality, Gemini and our third-party service provider receive some information regarding the calls or texts, including the date and time of the call or text, and the content of the text messages. We may also use this information for customer support services (including to resolve disputes between users), for safety and security purposes, and to improve the Service. Carrier Consent You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose to the Gemini and its third-party service providers your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, solely to verify your identity and prevent fraud for the duration of your use of the Services. Telephone Consumer Protection Act (TCPA) Consent Notwithstanding any current or prior election to opt in or opt out of receiving calls or SMS messages (including text messages) from us, our agents, representatives, affiliates, or anyone calling on our behalf, you expressly consent to be contacted by us, our agents, representatives, affiliates, or anyone calling on our behalf for any and all purposes arising out of or relating to your Service, at any telephone number, or physical or electronic address you provide or at which you may be reached. You agree that we may contact you in any way, including SMS messages or text messages, calls using prerecorded messages or artificial voice, and calls and messages delivered using auto telephone dialing system or an automatic texting system. Automated messages may be played when the telephone is answered, whether by you or someone else. In the event that an agent or representative calls, he or she may also leave a message on your answering machine, voice mail, or send one via text. You consent to receive SMS messages (including text messages), calls and messages (including prerecorded and artificial voice and autodialed) from us, our agents, representatives, affiliates or anyone calling on our behalf at the specific number(s) you have provided to us, or numbers we can reasonably associate with your account (through skip trace, caller ID capture or other means), with information or questions about your use of the Service. You certify, warrant and represent that the telephone numbers that you have provided to us are your contact numbers. You represent that you are permitted to receive calls at each of the telephone numbers you have provided to us. You agree to promptly alert us whenever you stop using a particular telephone number. Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You also agree that we may contact you by email, using any email address you have provided to us or that you provide to us in the future. We may listen to and/or record phone calls between you and our representatives without notice to you as permitted by applicable law. For example, we listen to and record calls for training and quality monitoring purposes. How We Share Your Information We may share your personal information in the instances described below. For further information on your choices regarding your information, see Your Choices Regarding Your Information below. Gemini may share your personally identifiable information with third party vendors, consultants or other service providers that perform services on our behalf or otherwise help provide the Service to you, under reasonable confidentiality terms. We may share your information in connection with any company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party. or in the event of bankruptcy or related or similar proceedings. We may share your personal information with others with whom you communicate on the Service and any information that you post or share publicly on our website or service. Any personal information or content that you voluntarily disclose for posting to the Service, such as user content, becomes available to the public, as controlled by any applicable privacy settings. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. Other brands owned or controlled by Gemini, and other companies owned by or under common ownership as Gemini, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy. We may share license plate information with governmental agencies to ensure compliance with local parking rules and restrictions, to respond or settle a citation issued during a trip, or in accordance with a parking program or partnership operated with a governmental agency. We may use personally identifiable information to investigate damage claims connected to trips taken and/or cars listed on our Gemini, and we may disclose personally identifiable information to a third party in connection with processing such claims under reasonable confidentiality restrictions. We may also disclose personal information if we believe it to be reasonably necessary to (i) satisfy any applicable law or regulation and comply with legal process, such as search warrant, subpoena or court order, or other government request served on us or on our affiliates; (ii) to enforce our Terms of Service, Vehicle Key Use Terms, or any other Gemini policy, including to investigate potential violations thereof; (iii) take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, or to protect the security or integrity of our site; and (iv) to exercise or protect the rights, property, or personal safety of Gemini, our users, or others. Typically, our policy is not to share personal information and location data with governmental agencies, except as pursuant to a search warrant, subpoena, court order, or as otherwise compelled to do so by legal process, though there may be circumstances in which we may disclose such information without such legal process if we reasonably believe such disclosure is necessary to protect the health and safety of an individual, prevent or mitigate the harm of crime or illegal activity, or other compelling circumstance. We will use our best effort to provide you notice of a law enforcement request for your personal information before we release such information, unless we are not permitted to do so. Sharing of Your Information with Business Partners; Expanded Service We may use information about you in partnership with outside companies in the course of providing you with additional services related to Gemini, such as ride-sharing, charging or parking benefits. When you purchase, register, or otherwise express interest in a product or service offered by a third party through Gemini or sponsored on our site, you consent to our sharing of your personal information with those parties. When you choose to participate in rewards programs, contests, discount offers, or other programs that involve third parties, you authorize Gemini to share your personal information with those parties, who may use such information in accordance with their own privacy policies. In these cases we will only share the information reasonably needed to provide you with service. Information that is shared with third parties is subject to the privacy policies of those parties, which may differ from Gemini's privacy policies. Sharing and Using Aggregate or Anonymized Information We may aggregate, anonymize, or otherwise strip data of all personally identifying characteristics and may share that anonymized and/or aggregated data with third parties, in a manner that cannot reasonably identify any individual. For example, we may share de-identified location data and location history with third parties that analyze location and movement trends, and we may share information that would identify a particular as well as the driving history, and general demographics of the drivers (i.e., gender and age bracket) of that car in order to analyze, develop and improve our partner programs. Your Choices About Your Information Profile and Data Sharing Settings You can change your account information and preferences at any time by logging onto your account. Communications We will not sell your contact information to third parties for marketing purposes. We may communicate with you via in-app notifications, email, SMS text, or other method. You control when and how (e.g. email, SMS, etc.) you would like to receive messages, and you may be able to opt-out of receiving certain types of messages. We may send you notifications of activity on the Service to the email address you give us, in accordance with any applicable privacy settings. For instance, if you are a car owner, we will send you information about your car's rental status. You can turn these notifications off or modify how often and in what form you receive them. Gemini may send you other messages in the course of operation of our Service, such as updates about Service changes and new features, and important news that may impact your use and enjoyment of Gemini. These communications may contain banners, ads, or promotional material provided by third parties. If you click on the third party link, you will be taken to that service, and your information will thereafter be subject to that party’s privacy policy. You may be able to optout of receiving promotional emails by clicking the “unsubscribe” button at the footer of promotional email communications. Note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account. By providing Gemini your email address, you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. Third Party Tracking and Advertising We may share, or we may permit third party ad networks, social media companies, and other third party services to collect information about the browsing behavior of our users of Service through cookies, social plug-ins, or other tracking technology. We may permit third party online advertising networks to collect information about your use of our Service over time, including location information, so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites or services, or on other devices you may use. Typically, the information is collected through cookies or similar tracking technologies. You may be able to “opt out” of the collection of information through cookies or other tracking technology by actively managing the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete, disable, and/or limit the use of cookies or other tracking/recording tools. Depending on your mobile device, you may not be able to control all tracking technologies through your device settings. You may also be able to limit interest-based advertising through the settings on your browser or device. For example, you may be able to opt-out of some interest-based advertising on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may opt-out of some of this tracking, you may wish to visit the Network Advertising Initiative’s online resources, at and/or the DAA’s resources at You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting and downloading the mobile AppChoices app. If you have any questions about third party tracking and advertising, you can contact us directly at Data Retention Following termination or deactivation of your account, Gemini may retain your information for a commercially reasonable time for backup, archival, or audit purposes, or to maintain and improve the Service -- for instance, for the safety of other users, we may need access to information about cars you have used in case one of those cars is in an accident. We may maintain location information and other usage data for record-keeping and analytics purposes. Furthermore, Gemini may retain and continue to use indefinitely all information (including user content) contained in your communications to other users or posted to public or semi-public areas of the Service after termination or deactivation of your account. Please contact us at if you wish to delete your account information from our systems, though we may not be able to delete all information, as noted in this Privacy Policy. Privacy Rights for users who are California Residents Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”) allows users who are residents of California to submit a request to Gemini (a “CCPA Request”) for access to the pieces and categories of personal information, if any, that Gemini has collected about them. Information that Gemini provides in response to CCPA Requests shall, to the extent feasible, be in a readily usable format. Gemini shall specify the purposes for collecting the information, and the types of third parties with whom the information has been shared. Users who are California residents may also submit a CCPA Request to Gemini for the deletion of their information. However, Gemini may be required to retain certain information in order to comply with other applicable laws, detect or prevent fraud, collect any fees owed, resolve disputes, assist with or process claims, troubleshoot problems, assist with any investigation, comply with audits and investigations, enforce its Terms of Service and associated policies, and take other actions reasonably necessary, permitted, or required by applicable law. Users who are residents of California may submit a CCPA Request to Gemini by logging into their Gemini account and submitting a ticket. In response to a CCPA Request, Gemini will verify that the request has been submitted by a user associated with the account to which the request relates. In connection with this verification process, users may be asked to provide governmentissued identification to Gemini. Users who are residents of California may designate an authorized agent to submit a CCPA Request on their behalf. To do so, the authorizing user must submit to Gemini the user’s government-issued identification, the authorized agent’s government-issued identification, and a valid power of attorney signed by the authorizing user. Users who submit CCPA Requests will not be charged different prices or provided different levels of service as a result of submitting such requests. How We Protect Your Information Gemini cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information and for controlling access to your email communications from Gemini, at all times. Children's Privacy Protecting the privacy of young children is especially important. For that reason, Gemini does not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register as users. If you are under 18, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us here. Links to Other Websites We are not responsible for the practices employed by websites linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website's own rules and policies. Please read over those rules and policies before proceeding. Notification Procedures It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on the Service, as determined by Gemini in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification, as described in this Privacy Policy. Changes to Our Privacy Policy If we change our privacy policies and procedures, we will post those changes on the Service to keep you aware of what information we collect, how we use it, and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. For any questions on this privacy policy, please contact us by submitting a support request here.