Retrospec Privacy Policy

Effective Date: January 1, 2026

This Privacy Policy ("Privacy Policy") describes how Retrospec, our subsidiaries, and our affiliates ("Retrospec," "we," "us," or "our") collects and processes your personal information in connection with:

• The www.retrospec.com website and any other Retrospec-operated websites;
• The Retrospec mobile application (the "App"), available for download on the Apple App Store and Google Play Store;
• Social media platforms, content, functionality, and all related services (collectively, the "Service").

This Privacy Policy does not apply to the processing of personal information by third parties.

By accessing or using any part of the Service — including visiting our website, downloading or using the App, submitting information to us, or purchasing our products — you understand and consent to our collection and use of your personal information as described herein. If you do not agree, do not use the Service.

1. INFORMATION WE COLLECT

Personal Information

We collect several types of information that may be defined as "Personal Information," "Personally Identifiable Information," or "Personal Data" under applicable law, including:

• Identifiers such as your name, address, email address, telephone number, social networking accounts, account name, IP address, and similar identifiers;
• Billing information, including credit card data and other financial information;
• Commercial information, such as records of products or services purchased, obtained, or considered;
• Internet or network activity, such as browsing history, search history, and interactions with the Service or advertisements;
• Geolocation data, such as your proximate or precise physical location;
• Mobile device data, including device type, unique device ID, IP address, mobile operating system, browser type, and other diagnostic data;
• Camera and photo library data, if you grant the App permission to access these features;
• Push notification tokens, if you opt in to receive push notifications.

How We Collect Your Personal Information

We collect Personal Information from the following sources:

• Account creation and maintenance – information you provide when creating or updating your account;
• Purchases – information needed to process and fulfill orders;
• Communications – information you provide when contacting us via email, the App, or third-party platforms;
• Newsletter sign-up – email address, name, and mailing address;
• Surveys – any information provided in response to optional surveys;
• Automatic collection – usage data, IP addresses, and information collected via cookies, SDKs, and tracking technologies as you use the Service;
• Third-party services – information received from vendors, platform providers (including Apple and Google), and other partners;
• Directly from you – any other information you choose to provide.

Mobile-Specific Data Collection

When you use the App, we additionally collect:

• Device permissions – depending on features used, the App may request access to your camera, photo library, location services, contacts, or notifications. You can manage permissions at any time in your device settings (iOS: Settings > Privacy; Android: Settings > Apps > Retrospec > Permissions);
• App usage analytics – screen views, session duration, in-app actions, and crash/error reports;
• Push notifications – if you opt in; you may opt out at any time through your device notification settings;
• Advertising identifiers – your device's IDFA (iOS) or GAID (Android), with your consent where required, for advertising and analytics purposes.

eBike Diagnostic Tool Data Collection

If you use the eBike diagnostic features within the App, we collect the following additional data to operate, maintain, and improve those features:

• Account information – credentials and profile details used to authenticate and associate diagnostics with your device;
• Device diagnostics – technical data about your eBike's components, systems, and operational status, collected via Bluetooth or other connectivity methods;
• Firmware data – information about your eBike's current and available firmware versions, used to deliver and verify firmware updates;
• Crash logs – records of eBike system errors, faults, or unexpected shutdowns, used to identify and resolve reliability issues;
• Location data – your precise or approximate location, collected only if you explicitly enable location features within the App.

This data is retained only as long as necessary for operational and legal purposes. We use encryption and administrative safeguards to protect all eBike diagnostic data. We do not sell this data. It may be shared with service providers (such as our eBike diagnostic platform partner) under contractual safeguards consistent with this Policy. Disputes arising from use of the eBike Diagnostic Tool are governed by the arbitration provisions in Retrospec's Terms of Service.

2. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar tracking technologies — including mobile SDKs, web beacons, tags, and scripts — to track activity and store certain information. You can instruct your browser or device to refuse cookies, though doing so may limit certain features of the Service. For more information, visit www.aboutcookies.org.

Technologies we use include:

• Site Management & Session Cookies – to maintain your session so you are not unexpectedly logged out;
• Personalization Cookies – to recognize repeat visitors and remember preferences;
• Persistent Cookies – to identify returning users and restore previously entered information;
• Security Cookies – to authenticate users and protect data from unauthorized access;
• Advertising Cookies – to deliver targeted advertisements relevant to your interests;
• Flash Cookies – used by certain video features; managed separately from browser cookies (see Macromedia Flash settings);
• Social Media Plug-ins – enabling sharing with platforms such as Facebook and Twitter, which may place cookies and track interactions.

3. GEOGRAPHIC LOCATION INFORMATION

If you use location-enabled features of the Service, we may collect and process information about your precise geographical location (e.g., GPS signals from your mobile device). We and our service providers may use this to deliver personalized, location-based services, content, and advertisements. You can enable or disable location access at any time in your device or browser settings. Disabling location access may limit certain features.

4. DEVICE INFORMATION

We collect information such as your Media Access Control (MAC) address, device type, screen resolution, operating system version, browser type and version, and app version. We and our service providers may also collect and use unique device identifiers to serve content and advertisements.

5. USAGE DATA

Usage Data is collected automatically and may include your IP address, browser type and version, pages or screens visited, time and date of visits, time spent on those pages, and other diagnostic data.

6. INFORMATION FROM THIRD-PARTY TOOLS

Our store is hosted by Shopify Inc., which provides the e-commerce platform for our product sales. When you visit or make a purchase, your personal information is collected and processed by Shopify. Please review Shopify's Privacy Policy at https://www.shopify.com/legal/privacy.

By using the Service, you consent to data sharing with the following providers and to their onward transfer to partners as needed to deliver the Service:

7. DATA LINKED TO YOU vs. DATA NOT LINKED TO YOU

In accordance with Apple App Store privacy label requirements, we distinguish between data linked to your identity and data that is not.

Data Linked to You

The following data is collected and linked to your identity (e.g., your account, device, or profile):

• Contact Information – name, email address, phone number, and mailing address
• Financial Information – payment card data and billing details
• Purchase History – records of products purchased or considered
• Account Credentials – username and authentication information
• Device Identifiers – advertising identifiers (IDFA/GAID) when associated with your account
• Location Data – precise or approximate location, when enabled
• eBike Diagnostic Data – device diagnostics, firmware data, and crash logs associated with your registered eBike and account
• Customer Support Data – communications and correspondence with our support team
• Push Notification Tokens – when tied to your account for personalized communications

Data Not Linked to You

The following data is collected for analytics, performance, or operational purposes and is not associated with your identity:

• Crash Logs – anonymized App crash and error reports used solely for debugging
• Performance Data – aggregated App usage metrics such as load times and screen views
• Advertising Data – aggregated, anonymized data used for measuring advertising effectiveness
• Browsing/Interaction Data – anonymized in-app navigation patterns used to improve App design

Note for Apple App Store Connect: This categorization is intended to support your App Privacy Details submission and should be declared individually in App Store Connect. This section does not replace that submission.

8. HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Data for the following purposes:

• To provide, operate, maintain, and improve the Service;
• To notify you about changes to the Service, products, or offers;
• To allow participation in interactive features of the Service;
• To provide customer and technical support;
• To process and fulfill purchases, including payments, delivery, and related communications;
• To send push notifications and other communications (where you have opted in);
• To personalize your experience with tailored content, products, and offers;
• To develop and test new features and diagnose technical issues;
• To send promotional communications, news, and special offers (where you have opted in);
• To contact you by email, telephone, SMS, or in-app push notification for informational or operational communications;
• For analytics, auditing, and measurement of marketing effectiveness;
• To comply with legal obligations and enforce our agreements;
• To evaluate mergers, acquisitions, or asset transfers, in which your information may be among the assets transferred.

9. SHARING AND DISCLOSURE OF YOUR PERSONAL INFORMATION

We may share your Personal Information in the following circumstances:

• Service Providers – to support Service operations, analytics, advertising, and customer communications, under contractual safeguards;
• Business Transfers – in connection with a merger, acquisition, financing, or sale of Retrospec assets;
• Affiliates – with our parent company, subsidiaries, and joint venture partners, who are required to honor this Policy;
• Business Partners – to offer products, services, or promotions;
• Marketing Partners – for commercial and advertising purposes;
• Other Users – when you share information in public areas of the Service, it may be visible to other users;
• Law Enforcement – when required by law or in response to valid legal process;
• Other Legal Requirements – to protect rights, prevent fraud, ensure safety, or comply with legal obligations;
• With Your Consent – for any other purpose with your explicit consent.

10. RETENTION OF YOUR PERSONAL INFORMATION

We retain Personal Information only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. De-identified or aggregated data may be retained indefinitely at our discretion.

11. TRANSFER OF YOUR PERSONAL INFORMATION

Your information may be transferred to and processed on computers located outside your state, province, or country, where data protection laws may differ. By using the Service and submitting information, you consent to such transfer and processing in the United States.

12. APP STORE PLATFORM TERMS

Apple App Store

If you download the App from the Apple App Store:

• This Privacy Policy is between you and Retrospec only, not Apple, Inc. ("Apple"). Apple is not responsible for the App or its content.
• Apple has no obligation to provide maintenance or support for the App.
• Apple is not responsible for product liability claims, warranty failures, or third-party intellectual property claims related to the App.
• Apple and its subsidiaries are third-party beneficiaries of this Privacy Policy and may enforce it against you.
• Your use of the App is also subject to Apple's App Store Terms of Service.

We comply with Apple's App Store Review Guidelines, including App Tracking Transparency (ATT) requirements. Where required, we request your permission before tracking you across third-party apps and websites.

Google Play Store

If you download the App from the Google Play Store:

• This Privacy Policy is between you and Retrospec only, not Google LLC ("Google"). Google is not responsible for the App or its content.
• Your use of the App is subject to the Google Play Terms of Service.

We comply with Google Play's Developer Program Policies, including requirements related to Data Safety disclosures, user data handling, and prominent disclosure for sensitive permissions. Our Data Safety form in the Play Console reflects the information contained in this Privacy Policy.

13. CONSENT

How do you get my consent? When you provide Personal Data to complete a transaction, place an order, or create an account, we imply your consent for that specific purpose. For secondary uses such as marketing, we will request your explicit consent.

How do I withdraw my consent? You may withdraw your consent at any time by contacting us via the form at https://retrospec.com/pages/do-not-sell-my-personal-information, or by adjusting your device permissions and notification settings.

14. LINKS TO OTHER WEBSITES AND APPS

Our Service may contain links to third-party websites or apps. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies before providing any personal information.

15. SECURITY OF YOUR PERSONAL INFORMATION

We implement commercially reasonable measures — including encryption and administrative safeguards — to protect your Personal Information. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. Any transmission of information is at your own risk.

16. YOUR PRIVACY RIGHTS AND CHOICES

Right to Opt Out of the Sale or Sharing of Personal Information

We do not sell your Personal Information for monetary consideration. However, under the California Privacy Rights Act (CPRA), certain disclosures of data to advertising and marketing partners — such as sharing for cross-context behavioral advertising — may qualify as a "sale" or "sharing" under California law, even where no money is exchanged.

"Sale" means the disclosure of Personal Information to a third party for monetary or other valuable consideration.

"Sharing" means the disclosure of Personal Information to a third party for cross-context behavioral advertising, regardless of whether money is exchanged.

We may engage in "sharing" as defined above when we disclose data such as online identifiers, browsing behavior, and advertising identifiers to marketing partners for targeted advertising purposes.

You have the right to opt out of both the sale and sharing of your Personal Information. To exercise this right, visit our homepage and click "Do Not Sell or Share My Personal Information," or click here. If you opt out, we may be unable to offer certain personalized features of the Service that depend on this sharing.

Right to Request Deletion

You have the right to request deletion of your personal information from our records, subject to legal exceptions. To submit a request, use the form at https://form.jotform.com/220116730097045.

17. STATE-SPECIFIC PRIVACY RIGHTS

Nevada Privacy

Nevada residents may opt out of the sale of covered personal information by emailing team@retrospec.com. You may also review and request changes to your personal information at that address. Material changes to this Policy will be posted on the Service.

California Privacy Notice (CCPA/CPRA)

California residents have the following rights upon submission of a verifiable request:

• Right to Know – the categories and specific pieces of personal information collected, the sources, business purposes, and third parties with whom we share it.
• Right to Correction – the right to request correction of inaccurate personal information we hold about you.
• Right to Deletion – the right to request deletion of your personal information, subject to legal exceptions.
• Right to Opt-Out of Sale – opt out at https://retrospec.com/pages/do-not-sell-my-personal-information. Some categories of personal information (including online behavioral data, IP addresses, interest data, and unique IDs) may be shared with Oracle America, Inc. for value.
• Right to Non-Discrimination – we will not deny services, charge different prices, or provide a different level of service based on your exercise of these rights.
• Notice of Financial Incentive – any financial incentive offered in exchange for personal information is based on a reasonable estimate of its value, consistent with CCPA/CPRA requirements.

California residents under 18 who are registered users may request removal of publicly posted content by emailing team@retrospec.com.

To exercise any California rights, submit a request at https://form.jotform.com/220116730097045. We will confirm receipt within 10 business days and respond within 45 calendar days.

18. "DO NOT TRACK" POLICY

Our Service does not respond to Do Not Track ("DNT") signals. To learn more, visit http://www.allaboutdnt.com.

19. AGE OF CONSENT AND CHILDREN'S PRIVACY

The Service is intended for users 18 years of age and older. By using the Service, you represent and warrant that you are at least 18 years old. Users under 18 are not permitted to use the Service. We do not knowingly collect Personal Data from individuals under 18, and we do not knowingly sell the Personal Data of minors under 16 without affirmative authorization.

The Service is not directed to children under 13, and we comply with the U.S. Children's Online Privacy Protection Act (COPPA). If you believe a child under 13 has provided us with personal information, please contact us at https://retrospec.com/pages/contact-us. Parents are encouraged to use parental control tools to monitor and limit their children's online activities.

20. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy at any time. Changes take effect immediately upon posting. Where required by law or app store guidelines, we will provide notice of material changes through the Service or by other means. We encourage you to review this Policy periodically.

21. QUESTIONS AND CONTACT INFORMATION

If you have questions about this Privacy Policy or our data practices, please contact us:

Retrospec Website: https://retrospec.com/pages/contact-us Email: team@retrospec.com