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TERMS OF USE OF APPLICATION – PERSONAL DATA PROTECTION POLICY

TERMS OF USE

The present Terms of Use (hereinafter referred to as "Terms of Use"), including the Personal Data Protection Policy (hereinafter referred to as “PDPP”), govern the use of the mobile application under the trademark “NOOS” (hereinafter referred to as the “Application”). The company under the name "PETROS PETROPOULOS S.A. COMMERCIAL AND INDUSTRIAL COMPANY", with registered office in Athens, 94 Iera Odos, TIN 094043269, and number 000285301000 of the General Commercial Register (hereinafter the "Company"), is the owner and holds all rights to the Application, which concerns the provision of services (hereinafter “Services”) related to the use of the smart electric two-wheeler vehicle named “NOOS”, which is manufactured by the Company.

General: These Terms of Use govern the use of the Application and Services. The person who wishes to use the Application and/or the Services (hereinafter the "User") accepts the Terms of Use by Creating an Account (see below, article 2.). The Company reserves the right to modify the Terms of Use at any time. In that case, the User will be informed of the updated Terms of Use via email sent to the email address provided during the Creating an Account (see below, article 2.). The current Terms of Use will also be available within the Application on the User's device.

Creating an Account: To activate and use the Application, a User account is required (hereinafter the “User Account”). Activation or creation of User Account is done through the Application. The following details are required for creation of the User Account: email address, password, full name, display name, address, mobile phone number, and alternative phone number – if any.

If the User is a NOOS vehicle owner, these details (except the password) are submitted to the Company during vehicle acquisition and entered into the Application by the Company. The Company provides to the User a temporary password for the first login, which the User must change afterward. In order to activate the User Account, an e-mail with a link is sent to the e-mail address of the User. This type of account is marked in the Application as “Owner.”

In the event of vehicle ownership transfer, the new owner must contact the Company by sending an e-mail to or by calling the telephone number +30 2103499580. The new owner must follow the Company’s instructions and provide the above-mentioned details and the vehicle’s registration in their name in order to create a User Account marked as “owner”.

Non-owners can also create a User Account by manually entering in the Application and providing the above-mentioned details. For the creation of the User Account an e-mail with a link will be sent to the e-mail address of the User.

User Login: Users must log in to the Application to use it. The Application stores login credentials, so re-entry is not required. The User must keep the login credentials (e-mail and password) confidential and not disclose them to anyone. The User is solely responsible for their account’s security and confidentiality. If unauthorized use or device loss is suspected, the Company must be notified immediately by the User either by calling the telephone number +30 2103499580 either by sending an e-mail to . The User must follow the relevant instructions of the Company.

Account Deletion: The User may request deletion of their User Account by contacting the Company through email at or telephone at +30 2103499580 and by following the Company’s instructions.

User Obligations: Users must provide truthful information during “Creating an Account”. The User must use the Application legally, according to the Greek legislation and regulations and to the Company’s instructions and in good faith.

Intellectual Property Rights: The Application and its content such as texts, graphics, information, data, blueprints, illustrations, products’ names and descriptions, services, interface, presentation and structure of the content, software, Company’s name, its trademarks and distinguishing features are the Company’s intellectual property (except for third-party rights) and are protected by relevant laws. Any copy, reproduction, analog/digital recording, distribution, redistribution, transfer, modification, resale, or derivative work of the Application or of its content or related to the Application or its content is prohibited.

PERSONAL DATA PROTECTION POLICY (PDPP)

The Company implements appropriate technical and organizational measures to protect personal data (hereinafter “PD”), in compliance with the GDPR (EU 2016/679) and relevant Greek legislation. Data is collected, stored, and processed by the Company for service provision (for example the experience of using the NOOS vehicle or the Application), legal compliance, technical support, and improvement purposes regarding the vehicle “NOOS”, the Application and/or the Services. During the activating the Application the User will state if he/she accepts the PDPP. The PDPP will be always available to the User through the Application.

User Data: The data collected during “Creating an Account” as described in article 2 of the Terms of Use is stored in a cloud (Firebase - Cloud Firestore). The said cloud is managed exclusively by the Company and its use is governed by the relevant terms of use and policies (, ). Data processing through the Firebase platform may involve transfer to countries outside the EEA. The Company ensures that appropriate safeguards are provided (Articles 44-49 GDPR), including standard contractual clauses of the European Commission. In case the User wishes to use the Application to activate the vehicle “Noos” the following Vehicle-related data will be used and stored in the cloud VIN (Vehicle Identification Number), bt_mac (Bluetooth MAC address) and bt_ token. The Company shall bear no liability whatsoever regarding the cause, the manner, the legality or illegality, or, more generally, any matter related to or arising from the granting of use of 'NOOS' by the owner to any third party.

Location Data: Certain Services (such as vehicle activation via the Application using Bluetooth technology) require that location services be enabled on the User’s mobile device. The Application itself does not store any location data from the mobile device on which it is installed. The “NOOS” vehicle is equipped with an integrated GPS system and internet connectivity. Irrespective of whether the Application is in use, the vehicle’s current geographic coordinates [lat (Latitude Coordinate – Location) and lon (Longitude Coordinate – Location)] are transmitted and stored in the cloud for the purpose of enabling the owner to locate the vehicle (for example, for anti-theft protection). Specifically, if the User is the owner of a “NOOS” vehicle, they may, through the Application, retrieve from the cloud the vehicle’s most recent geographic location. The above-mentioned data is not utilized by the Company for the purposes of monitoring or recording your personal activity. Users of the Application who are not owners of a “NOOS” vehicle should be aware that, in accordance with the foregoing, the User-owner who has granted them use of a “NOOS” vehicle may access the geographic location of the vehicle via the Application.

Stored Vehicle Data and other Data: For every NOOS vehicle the following data are collected and stored: VIN (Vehicle Identification Number), bt_mac (BlueTooth MAC Address), bt_token, vehicle’s color, forward KWH, kilometers, kwh, lat (Latitude Coordinate – Location), lon (Longitude Coordinate – Location), mean_speed, model, owner_id, production_date, reverse KWH, type, vehicle velocity, ambient temperature, accelerations in X, Y, Z, motor temperature, motor voltage, motor current, temperature of motor controller, battery id, battery’s state of health, cycles of battery, battery’s state of charge and maximum temperature.

Data Retention Period: All PD of the User (article 8) and location data (article 9) is retained at least for as long as the User maintains an account or uses the Application and/or the Services and for as long as is required for the Company to respond to and fulfill the aforementioned purposes (Article 7). By way of exception, the Company shall continue to process PD even after the aforementioned period, insofar as such information is necessary for compliance with its statutory obligations or required for the establishment, exercise, or defense of legal claims. With respect to data processing for statistical purposes or for reasons related to the further development, evolution, or improvement of the 'NOOS' vehicle and/or the Application, the Company shall ensure the deletion of the User’s personal data and shall maintain anonymized records of the technical data collected, without such data being linked to the use of a specific 'NOOS' vehicle.

Disclosure of Personal Data: The recipient of PD is the Company. The Company may share PD with its internal teams (customer service, scientific/technical team, legal team etc). The Company may disclose the PD to its personnel and third parties, such as affiliates, business partners, companies with which the Company may potentially form a joint venture, merge, or to which it may be sold, as well as the successors to its business.

Third-Party Data Processors: The Company may use third-party processors who act on its behalf under strict compliance with GDPR and internal policies. Processors shall process PD in accordance with the instructions they receive from the Company and shall fully comply with the PDPP, the principles of the General Data Protection Regulation (EU 2016/679), and the applicable legislation. All aforementioned recipients shall agree to and be bound by the obligation to use the PD in accordance with these terms and solely for the purposes specified herein. Unless explicitly required by law, the Company shall not otherwise disclose, sell, or share any information provided by a User without that User’s prior notice and consent. Furthermore, the Company reserves the right to disclose the PD provided by each User to third parties, other than those previously mentioned, strictly under the following circumstances: (a) in order to comply with legal obligations, court orders, or requirements of regulatory authorities; (b) when acting under urgent circumstances to protect the personal safety of its Users or the general public.

Confidentiality and Security: The Company is committed to protect PD and, more generally, all data provided by the User. To this end, it has implemented the necessary technical security measures and organizational procedures for their processing. The data is protected by security systems equipped with robust mechanisms to prevent unauthorized access. The PD collected is stored in the cloud storage system referenced above, which is governed by the provisions set forth in Article 8, and is controlled through access credentials. The Company employs specialized technologies and procedures and adopts strict physical, electronic, and administrative security measures to enhance the protection of such information against loss or misuse and to safeguard it from unauthorized access, disclosure, alteration, or destruction.

User Rights: According to the relevant legislation for data protectiin you have the following rights:

Access right: You have the right to be informed about the processing of your PD by the Company, the right to access such data and the information related to its processing, as well as the right to obtain a copy thereof. The Company reserves the right to refuse the fulfillment of this right in accordance with the provisions of national legislation.

Rectification right: You have the right to request the rectification or supplementation of your PD, which is incorrect or incomplete.

Erasure right: You have the right to request the erasure of your PD. The Company shall fulfill this right in the following cases:

if the Data is no longer necessary for the purposes for which it was collected;

if you exercise your right to object (see below under vi);

if the Data was processed in violation of applicable legal provisions;

if the Data must be erased to comply with a legal obligation. The Company reserves the right to refuse the fulfillment of this right if the processing of the PD is necessary for compliance with a legal obligation, for the performance of a task carried out in the public interest, for statistical purposes, or for the establishment, exercise, or defense of its legal claims.

Right to Restriction of Processing

You have the right to request your PD to be marked in order to restrict its processing. This right may be exercised in the following circumstances:

when you contest the accuracy of the PD, for the period necessary for the Company to verify its accuracy;

when the processing is unlawful under applicable legal provisions and you request the restriction of use of the PD instead of its erasure;

when you have exercised your right to object (see below under vi), pending verification of whether the Company’s legitimate grounds for processing override your interests, rights, and freedoms.

Portability right:

You have the right to receive your PD in a structured, commonly used, and machine- readable format, as well as the right to request that such data be transmitted either to you or to another party who will process the data.

Right to Object

You have the right to object to:

the processing of your PD carried out for the purposes of the Company’s or third parties’ legitimate interests. The Company reserves the right not to fulfill this right if there are compelling and legitimate grounds for the processing that override your interests, rights, and freedoms, or if such processing is necessary for the establishment, exercise, or defense of its legal claims;

the processing of your PD for direct marketing purposes;

the processing of your PD for statistical purposes.

The Company reserves the right not to fulfill this right if the processing is necessary for the performance of a task carried out for reasons of public interest.

Right Not to Be Subject to Automated Individual Decision-Making, Including Profiling

You have the right to object to a decision concerning you that is based solely on automated processing, including profiling, where such decision produces legal effects or significantly affects you.

All the above rights may be exercised free of charge. For any information regarding the PDPP, as well as to exercise the aforementioned rights, you may contact the Company’s Data Protection Officer, Apostolos Vlachos, by email at or by phone at +30 211 11 33583.

In the event that you exercise any of the above rights, the Company will promptly take all reasonable steps to satisfy your request within a reasonable timeframe, and in any case, no later than one (1) month from the verification of your submitted request. You will be informed in writing as to whether your request has been fully or partially granted, or of the reasons preventing the exercise of the relevant right.

Users may also contact the Hellenic Data Protection Authority (

16. The Company reserves the right to modify this PDPP at any time. In that case, the User will be informed of the updated policy via email sent to the email address provided during the Creating an Account.

LIMITATION OF LIABILITY

The Company does not guarantee the correctness, completeness, integrity, timeliness, technical adequacy, accuracy, clarity, suitability, validity, or uninterrupted transmission of the information and content of the Application, or its use or accessibility. The Company shall not be held liable for any damage that may be caused to Users or third parties due to the use of, or inability to use, the Application, nor for satisfying or remedying any related claims. Furthermore, the Company shall not be held liable for any damage caused to Users or third parties arising from the copying or tampering of the Application or its contents by unauthorized third parties, nor for satisfying or remedying any such claims.

PARTIAL INVALIDITY AND REPLACEMENT OF VALID PROVISIONS

The potential invalidity of one or more provisions of the Terms of Use and the Personal Data Protection Policy (PDPP) shall not render the entirety of these documents invalid. The remaining provisions shall remain in full force and effect and shall continue to produce their full legal consequences.

APPLICABLE LAW – JURISDICTION

These terms are governed by Greek law. Any dispute shall be subject to the jurisdiction of the courts of Athens.