Last Updated: May 11, 2016

Caroom Oy. (“Caroom”, “we”, “our” or "us") respects the privacy of its users (“User(s)” or “you”). This Privacy Policy is to inform you what information we collect when you visit our website at http://caroom.fi (the “Site”) and to our downloadable mobile application (the “Service”).

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Service available at http://caroom.fi/caroom-terms-of-service which this Privacy Policy is incorporated thereto by reference (together, the “Terms”).

BY ACCESSING THE SITE AND/OR SERVICE AND/OR USING THE SITE AND/OR SERVICE, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE "PRIVACY POLICY"), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SERVICES.

1. Information We May Collect

We may collect two types of data and information from our Users. The first type of information is non- identifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from which we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while Users are using the Service. Non-Personal Information which is being gathered consists of technical information and behavioral information, and may contain, among other things, the activity of the User on the Service, identity and operation system and browser, type of mobile device, and operating system version, User’s screen resolution, duration of usage of the Service, User’s ‘click- stream’ on the Site, keyboard language, etc.

The second type of information is individually identifiable information (“Personal Information”). This information may, in itself or taken together with additional information available to Caroom, identify an individual, or may be of a private and/or sensitive nature. Personal Information we collect includes: username, email address, phone number, your geo-location, your travel habits (such as routes, times of travel from one destination to another), your home address, office address or other favorite destinations, public transportation lines, stations and/or routes you may have saved or searched for, User’s search history on the Service, User’s most-used routes and stations, all User-generated data, User’s reports and reviews regarding the Service, your in-app settings, your rank and user profile including your nickname and avatar, in-app usage scores (“points”) you receive for using the Services, Advertising ID, User IP address, and any additional information which the User actively chooses to provided.

The geo-location information we collect includes detailed location and route information, including GPS signals and other information sent by your mobile device for which the Service is installed and currently activated. Caroom uses this location and route information to create a detailed location history all of public transit trips.

We collect such information via your use of the Service and through information which you voluntarily provide and/or upload to the Service as further described in this Privacy Policy below, for purposes of providing the Service, enhancing the User's experience and personalizing the Service and security purposes as further detailed below and.

In the event that you create a Caroom Account via Facebook, Google+ or other social networks Caroom may also have access to your public profile, which includes your name, gender, age group and residency.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information is deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of the Terms.

HOW WE COLLECT INFORMATION ON OUR USERS

There are two main methods we use:

(1) Use of the Service. We collect Non-Personal and Personal Information when you access or use the Service. In other words, we are aware of your usage of the Service and may gather, collect and record the information relating to such usage. We also collect Non-Personal and Personal Information derived from information we receive from third party services and providers we work with.

(2) Voluntarily Provided. We may collect Personal Information which you voluntarily provide when you use the Service. We may also collect information provided via your social network account in the event that you voluntarily choose to create a Caroom Account via such third party social networks (like Facebook or Google+).

HOW WE USE YOUR INFORMATION

Your information is collected for purposes: (i) to provide you with and to operate the Service, including for statistical and research purposes and creation of aggregated anonymous data; (ii) to personalize the Service and content provided to you, to customize your experience with the Services and to enable you to retrieve your information; (iii) to develop, improve and customize the Service, the experience of other users and the offering available through the Service; (iv) to be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints and collect feedback; (v) to send you updates, notices, announcements, and additional information related to the Services (vi) to be able to reply to User online queries or governmental agencies’ requests; (vii) for customization and improvement of the Service’s accuracy and interface; (viii) to use such information for Caroom’s commercial purposes; (ix) to display or send to you marketing and advertising material when you are using the Services, including in accordance with the section titled 'Direct Marketing' herein and (x) to comply with any applicable rule or regulation.

SHARING INFORMATION WITH THIRD PARTIES

Caroom will not share any Personal Information it collects with any third party. Notwithstanding, Caroom may disclose Personal Information in the following cases: (i) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (ii) to enforce this Privacy Policy and/or the Terms of Service, including investigation of potential violations thereof; (iii) to communicate with its Users regarding ours service; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to User's support requests; (vi) respond to claims that any content available on Caroom’s Service violates the rights of third- parties; (vii) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (viii) to protect the rights, property, or personal safety of Caroom, its Users, or the general public; (ix) when Caroom is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; or (x) to collect, hold and/or manage your Personal Information through Caroom’s authorized third party service providers, as reasonable for business purposes, which may be located in a country other than the country of your residency or location, that may not have the same data protection laws as your jurisdiction; (xi) pursuant to your explicit approval prior to the disclosure; (xii) cooperate with third parties for the purposes of adding operational features to the Service, enhancing and personalizing the User's experience, monetization and commercialization; or (xiii) to authorized third party service providers solely for the purpose of providing you with the Service.

For avoidance of doubt, Caroom may transfer and disclose or otherwise use Non-Personal Information or information which is linked to anonymous random identifiers or information that is aggregated in a non- identifiable way, at its own discretion.

DELETION OR MODIFICATION OF PERSONAL INFORMATION

Caroom retains Personal Information for a such period of time as is necessary in order for Caroom to be able to use the Personal Information for the purposes described in this Privacy Policy and for the purpose of providing its Services. If for any reason you wish to modify or delete your Personal Information please contact us at: support@caroom.fi and we will make reasonable efforts to modify anonymize or delete any such Personal Information pursuant to any applicable privacy laws.

THIRD PARTY SOFTWARE/SERVICE

While using the Service we may be using third party software and/or service for various needs, inter alia, in order to collect and/or process the information detailed herein (the “Third Party Service Provider”). Note that these are independent software and/or service providers and Caroom does not take any liability about the information collection policies of these providers, or about any kind of issue, legal or otherwise, relating thereto. Third Party Service Provider’s includes without limitation, Microsoft Azure Web Services, whose privacy policy is available at https://www.microsoft.com/en-us/privacystatement/OnlineServices/Default.aspx; IBM Cloud Services https://www.ibm.com/privacy/details/us/en.

Caroom may also provide additional transit-related services, including on-demand transit services, provided by its Third party operational service partners (as they may evolve from time to time at at Caroom’s discretion). Such Third Party Providers’ services, are all subject to respective terms of use and privacy policies.

CREATING AN ACCOUNT USING SOCIAL NETWORKS

By signing onto Caroom using your social network account (such as your Facebook account), you agree to provide Caroom with information (including personal information) obtained from the social networks, for the purposes provided under this Privacy Policy. In the event that you create a Caroom Account via your Facebook or Google social network account, Caroom may have access to your public profile, which includes your name, gender, email address, photo, age group and residency.

Your use of social networks to create your account is subject to the privacy policies and term of use of such third party social networks.

DIRECT MARKETING

You hereby agree that we may use your contact details for the purpose of informing you regarding our products and Services, which may interest you, and to send to you other marketing material, transmitted to the email address or to the mobile device. You may withdraw your consent contacting us at: support@caroom.fi. We may permit, solicit or contract certain other companies to conduct advertising campaigns on the Services. In addition, Caroom may display advertisements via the Services. Such advertisements that you see when accessing the Services may be targeted on the basis of your geographic location and language. It is clarified that Caroom is not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable in connection thereof.

SECURITY

We take a great care in implementing and maintaining the security of Caroom's Service and its User's Personal Information. Caroom employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. We do not, however, guarantee that unauthorized access will never occur.

CHANGES TO THE PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the Service and any information collected therein. Caroom reserves the right to change this policy at any time, so please re-visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the Site. Such substantial changes will take effect seven (7) days after such notice was provided on our Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Updated” date and your continued use of the Services after the Last Updated date will constitute acceptance of, and agreement to be bound by, those changes.

ADDITIONAL INFORMATION AND CONTACT US

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: support@caroom.fi and we will make an effort to reply within a reasonable timeframe.

By contacting Caroom you warrant and agree that you are free to do so, and that you do not provide Caroom with information, which violate any third party intellectual rights (the “Information”). Without degrading from the aforesaid, all rights, including intellectual property, arising from your communication with us will be owned by Caroom and will be considered as Caroom’s confidential material. It is clarified that any use of the Information, will be done in Caroom’s sole discretion, and Caroom is not obligated to use all or part of this Information.