Privacy Policy 2023

December 31, 2022

Effective Date: January 1, 2023

I. Notice

This Privacy Policy describes how your personal information is collected, used, and disclosed by Lordstown EV Company (“LEVC,” “us,” “we,” or “our”). This Privacy Policy applies to our websites (www.lordstownmotors.com) (the “Site”) and to information we collect offline (together, our “Service”).

Please read this Privacy Policy and our Telematics Terms and Conditions carefully before using our Service. We want you to be fully aware and confident of how your information is collected and used because we appreciate the trust you have placed in us. By using the Service or otherwise providing personal information to us, you agree to the LEVC’s Telematics Terms and Conditions (if applicable), and consent to LEVC’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.

II. What Information We May Collect

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, pseudonymized, or aggregated.

We may collect personal information related to you (such as your name, email, phone number, addresses and payment information) and your devices (such as information about your web browser, device, operating system, IP address, some cookies installed on your device, how long you have stayed on the Site, dates and times of activity on the Site, geolocation data, the individual web pages or products that you view, what websites or search terms referred you to the Site and information about how you interact with the Site).

We may collect personal information from or about you or your devices in a variety of ways, including:

We may collect personal information from or about you through our Site, including when you request information or place an order with us.

We may collect personal information about your web browser, IP address, time zone and some of the cookies that are installed on your device. Additionally, as you browse the Site, we may collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site and information about how you interact with the Site. Additionally, when you visit our Site, we may use cookies, analytics tools and other similar external-party technologies to help provide and improve our Site.

“Cookies” allow us to collect information such as browser type, time spent on the Site, pages visited and other web traffic data. We, and our service providers, may use the information to facilitate online navigation, to display information more effectively, to personalize your experience while using the Site and to otherwise analyze user activity. We can recognize your computer to assist your use of the Site. We also gather statistical information about the usage of the Site in order to improve its design and functionality of the Site. If you do not want information collected through the use of cookies when using our Site, most browsers (e.g., Safari, Chrome, Firefox) allow you to automatically decline cookies or gives you the choice of declining or accepting the transfer to your computer of a particular cookie(s). Please note that if you do not accept these cookies from our Site, you may experience some inconvenience in your use of the Site and some features may not function.

“Log files” track actions occurring on the Site and collect data including your IP address, browser type, internet service provider, referring/exit pages and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

We also use website and application analytics services provided by external parties (such as Google Analytics) that use cookies and other similar technologies to collect information about website or application use and to report trends, without identifying individual visitors. You can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptou

We may receive personal information about you from our vendors, affiliates, and business partners.

We may collect or receive publicly available information about you, e.g., information you post on social media sites.

We may collect personal information, including geolocation, if you operate one of our vehicles. Please see our Telematics Terms and Conditions for more information.

III. How We May Use Your Information

We may use personal information we collect from you in a variety of ways, including to:

Communicate with you.
Fulfill orders.
Improve and enhance development of our Site and products.
Present products and offers to you.
Respond to your inquiries.
Fulfill your requests for product information and alerts.
Process payments.
Provide you with related customer service.
For our other business purposes, such as data analysis, audits, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

IV. How We May Disclose Your Information

In addition to the purposes for collection, use, and disclosure of personal information described above, we may collect, use, and disclose personal information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a threatened or pending case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose personal information to other parties in connection with the sale, assignment, merger, or reorganization.

V. Additional Information

If you no longer want to receive promotional-related emails or messages from us, you may opt out of receiving them by following the opt-out instructions below or in communications received from us.

To opt-out, or if you have questions, concerns, or complaints about this Policy or our privacy practices, please contact us as provided in the Contact Us section, below.

VI. Updates to This Privacy Policy

We may occasionally update this Privacy Policy. The Effective Date at the top of this page indicates when the Privacy Policy was last revised. Any changes to the Privacy Policy will become effective when we post the revised Privacy Policy. By using our Site, or otherwise providing information to us following these changes, you accept the revised Privacy Policy.

VII. Notice for California Consumers

This Notice for California Consumers (“Notice”) is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”), and describes how LEVC collects, uses, and discloses personal information of California consumers. This Notice supplements our other privacy policies and notices,. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California consumers.

This Notice does not apply to California job applicants or current and former California employees. If you are an employee or current or former employee/contractor, a separate privacy notice will be provided to you in the course of your employment. If you are applicant, please review our California applicant privacy notice. If you believe you interacted with us in a different capacity, or if have any questions, please contact us as provided below.

Unless otherwise noted, the disclosures in this Notice cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.

A. How and Why we Collect, Use, and Disclose Personal Information

We may collect, use, and disclose personal information for business purposes consistent with applicable laws as identified below. Where we disclose applicable personal information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us. We may also collect other categories of personal information from you even though we do not regularly request such information. For example, if you voluntarily provide us with a personal email address in the context of a business-to-business relationship.

B. Disclosing Your Personal Information

We may disclose each of the categories of personal information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the personal information was collected including, but not limited to:

Auditing related to ads;

Helping to ensure security and integrity;

Debugging, repairing, and improving functionality;

Short-term, transient use;

Performing services on our behalf;

Providing advertising and marketing services, as applicable;

Internal research for technological development; and

Verifying quality and/or safety.

In addition to the other purposes for collection, use, and disclosure of personal information described in this Notice, we may collect, use, and disclose personal information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a threatened or pending case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose personal information to other parties in connection with the sale, assignment, merger, or reorganization.

C. Sources of Personal Information

We may collect personal information from the following sources:

Directly from you. For example, when you voluntarily provide us with information during your interactions with us, when you place an order, or when you communicate with us.
Automatically when you use our website or drive one of our vehicles. For example, we may collect your usage history when you use our websites, systems, and applications, and we may collect geolocation about your vehicle.
Other parties. For example, we may receive personal information from service providers who provide us with IT services, data analytics, advertising services, help facilitate our sales, or help us operate our business.

See Section II above for more information about what information we may collect and the context of that collection.

D. How Long We Keep Your Personal Information

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected;
The personal information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
We are otherwise required or permitted to keep your personal information by applicable laws or regulations.

Where personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

E. Sales and Sharing of Personal Information

We do not sell personal information or share it for cross-context behavioral advertising.

F. Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your personal information as described below. To exercise any of these rights, please submit a request by emailing us at privacy@lordstownmotors.com or calling us toll-free at 855-RIDE-LMC. Please note that if you submit a request to know, request to delete, or request to correct, you will be asked to provide two-to-three (2-3) pieces of personal information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.

1. Right to Know. You have the right to know what personal information we have collected about you, which includes:

a, The categories of personal information we have collected about you, including:

i. The categories of sources from which the personal information was collected;

ii. Our business purposes for collecting or disclosing personal information;

iii, The categories of recipients to which we disclose personal information;

iv. The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information.

b. The specific pieces of personal information we have collected about you.

2. Right to Delete Your Personal Information. You have the right to request that we delete personal information we collected from you, subject to certain exceptions.

3. Right to Correct Inaccurate Information. If you believe that personal information we maintain about you is inaccurate, you have the right to request that we correct that information.

4. Right to Opt Out of Sales and Sharing of Personal Information. We do not sell your personal information or share it for cross-context behavioral advertising.

5. Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

6. Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

G. California “Shine the Light”

Separate from your CCPA rights, you may obtain a list of the recipients to which we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for those recipient’s own direct marketing purposes, if applicable. To submit a request, please email us at privacy@lordstownmotors.com or send a letter to us at Lordstown Motors Corp., Attn: Legal/Privacy, 2300 Hallock-Young Road, S.W., Lordstown, Ohio 44481. Requests must include “California Shine the Light Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mail address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

VIII. How to Contact Us

If you have any questions, please contact us as provided below:

Email: privacy@lordstownmotors.com

Toll-free phone: 833-762-4734

Mail: Lordstown Motors Corp., Attn: Legal/Privacy, 2300 Hallock-Young Road, S.W., Lordstown, Ohio 44481.

Privacy Policy 2023

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