Privacy Policy

Effective Date: January 1, 2024

1. Introduction

Discover Your Mobility Inc. d/b/a Discover My Mobility ("DMM") is committed to protecting your privacy and complying with applicable data protection laws. This Privacy Policy outlines how DMM collects, uses, discloses, and safeguards information about you in connection with our Services, website, and other interactions with you. We also describe the choices you have regarding your information.

2. Our Services

DMM provides a comprehensive range of mobility solutions, including scooters, wheelchairs, and other mobility aids. We are dedicated to helping individuals with mobility challenges lead more independent lives. Our Services, accessible through https://www.discovermymobility.com, include the sale, rental, and servicing of mobility equipment, as well as resources and support for our customers.

Our Services also allow you to connect your DMM account to third-party services (“Third-Party Services”) available via our platform. The collection of your information by these third parties is governed by the Third-Party Services’ privacy policies and terms. We recommend you carefully review their privacy policies and terms as DMM is not responsible for Third-Party Services.

We rely on you to comply with applicable privacy laws when collecting, using, or disclosing information about individuals through the Services, including obtaining any necessary consents and providing any necessary notices. If we receive any questions or complaints regarding your use of the Services, we will direct the request to you for further assistance.

Our Services are not intended for use by children and should only be accessed by individuals who are at least 18 years old and are using the Services for business purposes.

3. Information Collection

We collect information about you as reasonably necessary for the following activities:

• Using our Services: We collect the following information when you use our Services:
  • Account information: Your contact and profile information, including your name, email address, organization name and address; your preferences such as language, time zone, and the types of communications you would like to receive from us; and image (if you choose to provide this). We may also obtain this information if you choose to use a login service to create or access your account.
  • Billing and other payment information: If you sign up for a paid service or purchase a Third-Party Service, including payment method details such as credit card number.
  • The Services you have acquired from us, including the type of plan, number of team members, and transaction information related to the Services.
  • Content: Your profile information you choose to connect to the Services. For example, your login profile information may include your username.
  • Logs, usage, and support data: Log data, which may include your IP address, the address of the web page you visited before using the Services, your browser type and settings, your device information (such as make, model, and OS), the date and time when you used the Services, information about your browser configuration, language preferences, unique identifiers, and cookies.
  • Usage data and analytics: This may include the frequency of login and the different types of activity undertaken by users, such as frequently accessed areas of the Services.
  • General Location information: Such as IP address and the region in which you are located when you are logging in and using the Services in accordance with the settings on your device.
  • Customer support questions, issues, and general feedback that you choose to provide.
• Surveys, events, marketing, and other activities: We collect information related to surveys, contests, events (such as webinars and in-person events), which includes:
  • Contact information: Your name, email address, telephone number, organization name, and address.
  • Participation, attendance, feedback, and opinions.
• Other interactions:
  • Social media: Your messages, posts, and other interactions with our brand and social media accounts.
  • Email interactions and analytics: Information on how you engage with our emails such as email open and click rates, whether a link is clicked, which web pages are visited after opening the email, the type of browser and email clients you use, and general location (i.e., country and region) information.
  • Teleconference, videoconference, and other meetings: Your preferences, feedback, opinions, and business needs.
  • Accessing resources (e.g., videos, whitepapers, or case studies) on our website: Your name and contact information, and engagement analytics such as the type and frequency of resources accessed, viewed, and downloaded.

4. How do we use your information?

We use your information for the purposes described below:

Providing and securing our Services

We need to identify and authenticate our users to ensure, for example, that only those authorized users are able to use the Services for their organization and to make changes to their accounts.

• We use information that you provide when signing up to set up your account, process payments, contact you regarding the Services, and manage your account.
• We use your contact information and information related to your request to respond to your inquiries, manage our contract with you, respond to your questions and requests, and send you updates and information about the Services.
• We use logging and other data, such as general location information—for example, the IP address of your browser or device—to help us manage the performance, security, and compliance of the Services.
• Where you have chosen to share your specific location information, we use this information to provide location-based features and to use any functionality that relies on location information.
• We analyze usage information, your feedback, support queries, and survey responses to identify issues and help us understand how you use the Services so that we can make improvements to our Services.

Communicating with you

We use your contact information, where appropriate, to send you information about our Services, events, marketing communications (consistent with your preferences—see “Marketing emails, advertising, and website browsing” below), and job opportunities.

We use email statistics such as open rates to assess the effectiveness of and to make improvements to our communications. We also use engagement analytics to better understand your needs so that we can provide the information and services that would be more suitable for you.

Improving our websites and applications

We use information about you to help us understand usage patterns and other activities on our websites and applications so that we can diagnose problems and make improvements, including enhancing usability and security.

We also use website personalization software to help us present information on our websites that may be more relevant to you, such as displaying resources applicable to your industry or organization size.

If you choose to provide information about you, your usage of our Services, and other feedback during telephone calls and other interactions to our customer support and sales teams, we may use, monitor, and record this information for training purposes, to make improvements to our internal sales and marketing processes, and to improve our Services.

5. What are your rights regarding the information about you?

Services information

When using our Services, you may access, update, or correct most of your Account information by logging in to your account to edit your profile or organization record.

• If you have requests that cannot be carried out by logging in to your account, such as accessing additional information or deleting information about you, please email our team. Please note that we may need to retain certain information about you for as long as you maintain an account for our Services to provide you with our Services for record-keeping purposes, for payment processing, to comply with our legal and regulatory obligations, to resolve disputes, or to enforce the applicable terms and conditions TO T&Cs or other agreements in place between you (or your organization) and DMM (the “Terms of Service”).
• Requests to access, correct, update, or delete your information can be made in writing to our team and will be handled within thirty (30) days unless they are unusually extensive or complex, in which case we will advise you of the expected timeline for handling your request.
• You can contact our Support team for other general requests about your account by your preferred method listed here.

Marketing emails, advertising, and website browsing

For marketing communications, you may opt out of marketing communications sent by DMM by contacting our team. Please note that if you are a DMM user, unsubscribing from marketing communications will not affect product-generated DMM emails sent in connection with your use of our Services.

DMM participates in interest-based advertising (where you may have visited our websites or another website which allows us to display advertising relating to our Services).

6. Who has access to your information?

DMM does not rent or sell your information. We restrict access to your information to authorized employees, and we do not share your information with third parties except in the circumstances explained below.

Employees and Authorized Contractors

Our employees and authorized contractors may need to access information about you when they require this information to perform their job. For example, a customer support representative would need access to your account to validate your identity and respond to your question or request; our email communications team would need access to your contact information to ensure this information is sent correctly and any unsubscribe requests are properly managed; and our security staff would need to review information to investigate attempted denial of service attacks, fraudulent account activity, or other attempts to compromise the Services.

All our employees and contractors are required to agree to maintain the confidentiality and protect the privacy of your information.

Service Providers, Authorized Resellers, and Partners

We will share limited information about you with authorized service providers we use for marketing services, communicating with you, managing our customer database, the provision of professional services, and providing and managing the Services (including hosting data centers, securing our Services, and payment processing).

• We limit the number of service providers who are permitted to process your Content for the purpose of assisting us in delivering the Services. We refer to these service providers as "subprocessors."
• Where you have purchased a service from an authorized reseller or partner, we may provide information about you to (and may receive information about you from) the reseller or partner as necessary to support your use of the service you purchased.
• When sharing your information with any of the above service providers, resellers, and partners, we ensure they agree to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and only use your information to carry out the Services and your requests.

Social Networks and Third-Party Services

Where you are using our Services or if you authorize a Third-Party Service to access your account, you are agreeing to provide information about you to the Third-Party Services under their respective terms and privacy policies.

Customer Organizations

Where your employer or an entity has purchased Services on your behalf, we may disclose information about you, such as your name and email address, and some usage information, including whether a user has logged in to the Service, frequency of login, time spent using the Services, to assist your employer or the entity in managing its use and maximizing the value of the Services.

Successor and Affiliated Entities

We may share information about you among DMM-controlled affiliates and subsidiaries, and they will protect your information in a manner that is consistent with this Privacy Policy and where applicable, in accordance with the privacy policy specific to the entity.

We may also disclose your information as part of a corporate transaction, such as a merger or sale of assets. If we do, we will inform such entities of the requirement to handle your information in accordance with this Privacy Policy or inform you that you are covered by a new privacy policy.

Law Enforcement, Government Agencies, and Professional Advisors

We may need to disclose information about you where we believe that it is reasonably necessary to comply with a law or regulation, or if we are otherwise legally required to do so, such as in response to a court order or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands.

In addition, we may disclose information about you if we believe it is necessary to investigate, prevent, or take action: (a) against illegal activities, fraud, situations involving potential threats to our rights or property (or to the rights or property of those who use our Services), or to protect the personal safety of any person; or (b) regarding situations that involve the security of our Services, abuse of the Services infrastructure, or the Internet in general (such as voluminous spamming or denial of service attacks).

We also use professional advisors, including lawyers and accountants, and may be required to disclose information about you when engaging them for their services and as necessary for audits, financial and other regulatory reviews.

7. International Data Transfers

Under the General Data Protection Regulation (GDPR) and other data protection laws, information about you may only be transferred from your region to other regions if certain requirements are met. For instance, under the GDPR, information about you may be transferred from the European Economic Area (EEA) to outside the EEA if adequate data protections are in place. Our Services are managed by DMM’s headquarters in the United States.

DMM also uses third-party service providers such as managed hosting providers, credit card processors, and technology partners to provide the software, networking infrastructure, and other services required to operate the Services. These third-party providers may process or store personal data on servers outside of the EEA, UK, and Switzerland, including in Canada or the US. We rely on adequacy and standard contractual clauses to ensure that information about you is lawfully transferred under EU law. In this case, we have implemented supplementary measures as outlined in the section “How do we safeguard your information?”

The third-party service providers we use to help us deliver the Services and which process your Content are referred to as “subprocessors.”

8. How do we safeguard your information?

DMM maintains industry-standard security safeguards to protect your information. This includes ensuring our employees receive appropriate security and privacy training and guidance so they are aware of the measures they need to implement to protect your information.

Access controls

We have access controls in place to limit access to your information to those who need it to perform their jobs. For example, information about you may be provided to our customer support specialists to help you with your requests. Individuals who are permitted to handle your information must adhere to confidentiality obligations.

Encryption

We encrypt data in transit and at rest where appropriate to ensure that your information is kept private.

Service provider reviews

We undertake service provider security and privacy reviews to ensure that service providers follow our stringent requirements to safeguard your information. We also enter into data protection agreements with our service providers.

Payment information

All payment information is fully encrypted and handled only by PCI-certified organizations.

9. How long do we retain your information?

We retain your information as long as required to provide the Services requested by you, for record-keeping purposes, to comply with our legal obligations, resolve disputes, and enforce the terms for the Services. After it is no longer necessary for us to retain information about you, or otherwise upon your request, we will dispose of it in a secure manner or anonymize the information.

Aggregated data is used by DMM for analysis, product improvement, and troubleshooting purposes.

10. DMM’s Roles under the GDPR and UK Data Protection Laws

Depending on the situation and the type of data involved, DMM may act as a data controller or a data processor.

DMM as a data controller

DMM acts as a data controller when we are:

• Collecting information from you to set up and administer your DMM account (for example, Account information such as your name and email address);
• Monitoring usage information on our website;
• Managing your contact and other related information to send marketing Services and other communications to you;
• Responding to a support or general inquiry; and
• Recruiting individuals for job opportunities.

Legal bases for processing when DMM is a data controller

The legal bases for processing information about you include:

• Your consent (for example, when you have provided your information to sign up for an account; or you have provided your employment history when applying for a job). Where we rely on your consent to process personal data, you have the right to withdraw your consent at any time.
• It is necessary to perform a contract (for example, we may need your information to fulfill our obligations of providing Services to you under the terms relevant to the Services you have acquired).
• Legitimate interest (for example, to provide, maintain, and improve the Services for you, to maintain the security of the Services, and to attract new customers to maintain demand for the Services).
• In some cases, we may have a legal obligation to process your personal data to comply with relevant laws (for example, processing payroll and tax information to comply with relevant employment and tax legislation); or processing is necessary to protect your vital interests or those of another person (for example, obtaining health-related information during a medical emergency).

Your rights when DMM is a data controller

Where DMM is acting as a data controller, you may have the following rights:

• Right to object to processing: You may request that DMM stops processing information about you (for example, to stop sending you marketing communications).
• Right to restrict processing: You may request that we restrict processing information about you (for example, where you believe that this information is inaccurate).
• Right to data portability: You may request that we provide you with information DMM has about you in a structured, machine-readable, and commonly used format, and you may request that we transfer this information to another data controller.
• If you would like assistance on any of the above requests, please email our Team with details of your request so that we may consider how we can help you.

DMM as a data processor

Where you are using our Services and making decisions about the personal data that is being processed in the Services, you are acting as a data controller, and DMM is acting as a data processor.

There are certain obligations under the GDPR that you have as a data controller, including being responsible for managing Content on the Services. As a data processor, DMM will only access and process Content to provide you with the Services in accordance with your instructions (which you provide through the Services), the Terms of Service, and applicable laws. As part of delivering the Services, we may process Content to further improve the Services, such as enhancing usability and developing new features.

11. Your California Privacy Rights

If you are a consumer as defined in the California Consumer Privacy Act (CCPA), the following provisions apply to you. Definitions of terms are set out in the CCPA.

Information about your Personal Information

The categories and specific types of personal information collected and sources from which personal information are collected are set out ?

• The business and commercial purposes for collecting personal information are set out ?
• The categories of third parties with whom your information is shared are set out ?

Your Rights

The right to know about the personal information collected about you: You have the right to request that DMM disclose the categories and specific pieces of personal information we have collected about you.

The right to have your personal information deleted: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

The right not to be discriminated against for exercising your consumer rights under the CCPA: DMM will not discriminate against you for exercising any of your CCPA rights.

• You may exercise your rights by emailing our Privacy team. If your organization requires a CCPA addendum, please email us your customer details (organization name and plan information) with your request here.
• While we disclose personal information to service providers for the purpose of managing our relationship with you (e.g., distributing marketing communications) and providing the Services, we do not sell your personal information.

12. Changes to this Privacy Policy

We may make changes to this Privacy Policy at any time to reflect updates to our Services, applicable laws, and other factors. We will include a prominent notice on our website and/or our Services if we make any material changes, but we encourage you to stay informed by reviewing this policy periodically.

13. How to Contact Us

If you have any questions, concerns, or feedback, please email our Privacy team and Privacy Officer/Data Protection Officer at mary.globalada@gmail.com; or send a letter to:

Discover Your Mobility Inc.

11055 E. 9 Mile Road

Warren, MI  48089

Attn: Privacy Team

If we are unable to resolve your concerns, you also have the right to contact your local data protection authority.

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