1. Scope and Overview

This Privacy Policy describes how Trailblaze Motors Inc. ("Trailblaze Motors," "TBM," "we," "us," or "our") collects, uses, retains, protects, and discloses personal information when you visit trailblazemotors.com, use a Trailblaze Motors mobile application or connected-product feature, create an account, purchase or service a product, participate in a test ride or event, communicate with us, or otherwise interact with our products and services (collectively, the "Services").

This Policy applies to customers, prospective customers, website visitors, app users, riders, event participants, dealers, service contacts, and other individuals who interact with the Services. It does not apply to information processed solely in an employment or independent-contractor context, which may be covered by a separate notice, or to third-party websites and services that operate under their own privacy policies.

Please read this Policy carefully. Our processing of personal information is based on the context of your interaction with us and may be necessary to provide requested products or services, comply with law, protect safety and security, pursue legitimate business purposes, or carry out activities with your consent where consent is required.

2. Our No-Sale and No-Sharing Commitment

Trailblaze Motors does not sell personal information for money or other valuable consideration. We do not rent customer lists. We also do not "share" personal information, as that term is defined under the California Consumer Privacy Act, for cross-context behavioral advertising, and we do not disclose personal information for targeted advertising based on a person’s activity across unaffiliated websites or services.

We may disclose personal information to service providers, contractors, dealers, professional advisers, and other recipients for the limited operational purposes described in this Policy. Those limited disclosures are not sales or cross-context behavioral-advertising sharing when handled under applicable legal exceptions and appropriate restrictions. Service providers may use personal information only to perform authorized services for us or as otherwise permitted by law.

If our practices materially change, we will update this Policy and provide any notice, consent mechanism, or opt-out right required by applicable law before beginning the new practice.

3. Personal Information We Collect

The information we collect depends on how you interact with us. We seek to collect information that is reasonably necessary and proportionate for the purposes described below.

4. Sources of Personal Information

We collect personal information from the following sources:

·         Directly from you, including through purchases, account registration, forms, applications, test rides, events, warranty or service requests, surveys, and communications.

·         Automatically from your browser, device, app, motorcycle, battery, controller, or other connected component when you use a feature that generates usage or diagnostic data.

·         From service providers and contractors acting on our behalf, such as Shopify, payment processors, financing providers, shipping carriers, hosting providers, analytics providers, customer-support systems, and fraud-prevention providers.

·         From authorized dealers, distributors, service centers, event partners, referral partners, or other parties involved in a transaction or service you requested.

·         From publicly available sources, government records, and information you make available through public websites or social-media platforms.

5. How We Use Personal Information

We use personal information only for purposes reasonably related to providing and improving our products and Services, including to:

·         Process payments, deposits, purchases, shipping, delivery, returns, exchanges, registrations, financing referrals, and other requested transactions.

·         Create and maintain accounts; authenticate users; remember settings; and provide requested website, app, and connected-product functionality.

·         Provide customer support, diagnostics, maintenance, warranty service, recall administration, safety communications, and technical assistance.

·         Analyze product operation, reliability, battery behavior, performance, fault patterns, durability, and customer feedback to enhance the user experience and improve existing and future products.

·         Develop, test, maintain, troubleshoot, secure, and improve our websites, applications, firmware, systems, products, and customer-service processes.

·         Send transactional and service messages and, where permitted, marketing communications about Trailblaze Motors products, events, offers, or news. You may opt out of promotional email or text messages using the instructions in the message.

·         Prevent fraud, abuse, theft, unauthorized access, safety incidents, and other illegal or harmful activity; enforce agreements; and protect our customers, personnel, property, products, and legal rights.

·         Comply with laws, court orders, subpoenas, tax and accounting requirements, regulatory obligations, product-safety duties, recalls, warranty requirements, and lawful government requests.

·         Create aggregated or deidentified information that does not reasonably identify an individual, and use that information for research, analytics, reporting, product development, and other lawful business purposes.

6. Cookies, Analytics, and Similar Technologies

We use cookies, pixels, local storage, software development kits, and similar technologies as needed to operate the Services, remember preferences, maintain sessions, secure accounts, prevent fraud, measure website and app performance, understand how our Services are used, and improve user experience and products.

Our analytics providers are used to perform services on our behalf and are expected to process information only for authorized purposes. Trailblaze Motors does not permit third parties to use information collected through the Services to build profiles about users across unrelated businesses or to deliver cross-context behavioral advertising or targeted advertising.

You can manage many cookies through your browser or device settings. Blocking essential cookies may prevent parts of the Services from functioning. Where applicable law requires consent before nonessential technologies are activated, we will request that consent through an appropriate control. A browser "Do Not Track" signal is different from a legally recognized opt-out preference signal. Because we do not sell or share personal information for cross-context behavioral advertising, we do not use such signals as permission to engage in those practices.

7. When We Disclose Personal Information

We may disclose personal information only as reasonably necessary for the purposes described in this Policy, including to:

·         Service providers and contractors that support hosting, e-commerce, payment processing, financing, communications, analytics, cybersecurity, fraud prevention, customer service, cloud storage, fulfillment, shipping, product diagnostics, warranty administration, and professional services.

·         Authorized dealers, distributors, repair facilities, logistics providers, event operators, and other transaction participants when disclosure is necessary to deliver, register, inspect, service, repair, transport, recall, or support a product or activity you requested.

·         Professional advisers, insurers, auditors, accountants, and attorneys when reasonably necessary to obtain advice, manage risk, establish or defend legal claims, or comply with professional obligations.

·         Government agencies, regulators, courts, law enforcement, or other parties when we reasonably believe disclosure is required or permitted by law, necessary to protect safety or rights, or appropriate to investigate fraud, security incidents, illegal activity, or violations of our agreements.

·         A successor, buyer, investor, lender, or adviser in connection with a proposed or completed merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to appropriate confidentiality and legal protections where required.

·         Other recipients at your direction or with your consent, such as when you ask us to send information to a dealer, service provider, financing provider, insurer, registration agency, or shipping recipient.

We do not authorize service providers or contractors to sell personal information or use it for their own cross-context behavioral advertising. Where appropriate, our contracts restrict recipients to specified purposes and require reasonable privacy and security protections.

8. Marketing Communications and Mobile Messaging

We may use contact information you provide to send Trailblaze Motors marketing communications where permitted by law. You can unsubscribe from promotional email using the link in the message. You can opt out of promotional text messages by replying STOP or using any other method stated in the message. Opting out of marketing does not prevent us from sending nonpromotional communications about orders, accounts, warranties, safety, recalls, service, or other transactions.

Mobile opt-in information and consent records are not sold or shared with third parties for their own marketing or promotional purposes. We may disclose them to messaging and telecommunications service providers solely to deliver and administer our messaging program, prevent fraud, and comply with law.

9. Product Improvement, Research, and Deidentified Data

A central purpose of our data use is to improve the rider and customer experience and develop safer, more reliable, and higher-performing products. We may analyze support history, warranty information, surveys, app usage, diagnostic logs, charging patterns, fault codes, and connected-product telemetry to identify issues, evaluate design changes, improve firmware or components, and guide future development.

Whenever reasonably practicable, we use aggregated or deidentified information for product research and analytics. We maintain deidentified information in deidentified form and do not attempt to reidentify it except as permitted by law to test whether our deidentification processes are effective.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide products and Services, maintain accounts and transaction records, administer warranties and recalls, support vehicle ownership and safety obligations, resolve disputes, enforce agreements, comply with tax, accounting, regulatory, and legal requirements, prevent fraud, and maintain appropriate business records.

Retention periods vary by category and context. We consider the duration of the customer relationship, product and warranty life cycles, legal limitation periods, regulatory or recall obligations, the sensitivity and volume of the information, security needs, and whether the purpose can be achieved using aggregated or deidentified information. When information is no longer reasonably required, we delete, anonymize, or securely dispose of it in accordance with our processes, subject to lawful exceptions and backup-cycle limitations.

11. Data Security

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, or disclosure. Safeguards may include access controls, authentication, encryption where appropriate, vendor management, employee training, monitoring, backups, and incident-response procedures.

No security measure, transmission method, website, application, connected vehicle, or storage system can be guaranteed to be completely secure. You are responsible for maintaining the confidentiality of your account credentials, using secure networks and devices, installing available updates, and notifying us promptly if you suspect unauthorized account or product access.

12. Your Privacy Rights and Choices

Depending on where you live and subject to applicable exceptions, you may have the right to:

·         Request confirmation of whether we process your personal information and access the categories or specific pieces of information we maintain.

·         Request correction of inaccurate personal information.

·         Request deletion of personal information, subject to legal and operational exceptions.

·         Request a portable copy of certain personal information.

·         Withdraw consent where processing is based on consent, without affecting processing that occurred before withdrawal.

·         Opt out of promotional communications.

·         Appeal a decision we make regarding a privacy request where applicable.

·         Exercise privacy rights without unlawful discrimination or retaliation.

To submit a request, email team@trailblazemotors.com with the subject line "Privacy Request" or write to us at the address in Section 19. Describe your request and identify the state or country where you reside. We may request information reasonably necessary to verify your identity and authority. We will use verification information only for that purpose and will respond within the time required by applicable law.

An authorized agent may submit a request on your behalf where permitted by law. We may require proof of the agent’s authority and may ask you to verify your identity or confirm the request directly. We may deny or limit a request when an exception applies, when we cannot reasonably verify the request, or when fulfilling it would adversely affect another person’s rights, security, or legally protected information. We will explain the basis for a denial when required.

13. California Privacy Notice

This section supplements the rest of this Policy for California residents. The categories of personal information we may collect are described in Section 3. The categories of sources are described in Section 4; our business and commercial purposes are described in Sections 5 and 9; and the categories of recipients to whom information may be disclosed for business purposes are described in Section 7.

During the preceding 12 months, depending on individual interactions, we may have collected and disclosed for business purposes identifiers; California customer-record information; commercial information; internet or electronic-network activity; approximate geolocation information; audio, electronic, visual, or similar information; professional information provided in a business interaction; sensitive personal information used for permitted purposes; and inferences created solely to improve our Services and products.

Trailblaze Motors has not sold personal information and has not shared personal information for cross-context behavioral advertising during the preceding 12 months. We do not have actual knowledge that we sell or share personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes that require a right to limit under California law, such as inferring characteristics about a consumer.

California residents may have rights to know, access, delete, correct, and obtain information about disclosure practices, as well as the right to non-discrimination. Instructions for submitting and verifying a request appear in Section 12. We will not discriminate against you for exercising an applicable privacy right.

14. Children’s Privacy

The online Services are not directed to children under 13, and we do not knowingly collect personal information online from children under 13 without legally valid authorization. Test rides, races, events, or other activities involving minors may require information and consent from a parent or legal guardian for safety, eligibility, waiver, insurance, or legal purposes. If you believe a child has provided personal information to us without appropriate authorization, contact us so we can review and take appropriate action.

15. Third-Party Websites, Platforms, and Services

The Services may contain links to or integrations with third-party websites, social-media platforms, financing providers, map services, app stores, dealers, or other services that we do not control. This Policy does not govern those third parties. Their collection and use of personal information are governed by their own policies and settings. We are not responsible for the privacy, security, availability, accuracy, or practices of third-party services merely because we provide a link or enable an interaction with them.

16. International Users and Data Transfers

Trailblaze Motors is based in the United States. If you access the Services from another country, your information may be transferred to, stored in, and processed in the United States and other countries where we or our service providers operate. Those countries may have privacy laws that differ from the laws where you live. Where required, we use recognized transfer mechanisms or other lawful safeguards and provide rights required by applicable law.

17. Legal Bases for Processing Where Required

Where applicable law requires a legal basis, we process personal information as necessary to perform a contract or take steps at your request; comply with legal obligations; protect vital interests and safety; pursue legitimate interests that are not overridden by your rights, such as operating, securing, supporting, and improving our products and Services; or based on consent. You may withdraw consent where applicable, but withdrawal does not affect prior lawful processing and may limit features that depend on the information.

18. Changes to This Privacy Policy

We may update this Policy to reflect changes in our products, Services, technology, data practices, or legal obligations. We will post the revised Policy, update the effective date, and provide additional notice or obtain consent when required by law. Unless otherwise stated, the revised Policy applies when posted. Material changes will not retroactively authorize us to sell or share personal information collected under this no-sale/no-sharing commitment without providing any notice and choice required by applicable law.

19. Contact Us

For privacy questions, concerns, complaints, or requests, contact: