LEGAL
DOCUMENTS.

GRUPETTO

DISCLAIMER.

All rides posted, organized, scheduled, or communicated through the Grupetto mobile application (“Grupetto App”) are informal, voluntary, and local group rides organized by independent participants. Grupetto LLC, including its owners, administrators, employees, affiliates, representatives, and any individuals identified as ride leaders, does not supervise, control, or guarantee the safety of any ride and expressly disclaims any and all liability arising from participation in such activities. By participating in any ride promoted or shared through the Grupetto App, each participant acknowledges and agrees that cycling is an inherently dangerous activity involving risks that may result in serious injury, death, property damage, or other losses. Such risks include, but are not limited to, collisions with vehicles, pedestrians, or other cyclists; hazardous road conditions; mechanical failures; weather conditions; and negligent acts or omissions of other participants. Participation in any ride is entirely voluntary and undertaken at the participant’s own risk. To the fullest extent permitted by applicable law, Grupetto LLC, its owners, administrators, employees, affiliates, representatives, and ride leaders shall not be liable for any direct, indirect, incidental, consequential, special, or punitive damages, injuries, losses, or claims arising out of or related to participation in any ride or use of the Grupetto App. Each participant is solely responsible for their own safety, conduct, and decisions while participating in any ride, including compliance with all applicable traffic laws, regulations, and safety practices. Participants are also solely responsible for ensuring that their bicycle and all related equipment are properly maintained, in safe working condition, and suitable for participation in group rides, in order to promote the safety of all riders. By participating in any ride posted or communicated through the Grupetto App, each participant acknowledges that they have read, understood, and voluntarily accepted this disclaimer and assumption of risk.

GRUPETTO

TERMS OF USE.

Grupetto App (“App”), operated by Grupetto LLC (“Grupetto,” “we,” “our,” or “us”). By accessing, downloading, registering for, or using the Grupetto App, you agree to comply with and be bound by these Terms of Use (“Terms”). If you do not agree to these Terms, you may not use the App.

1. Purpose of the App: The Grupetto App is a platform designed to allow users to create, share, discover, and participate in local cycling group rides and related cycling activities. Grupetto LLC acts solely as a technology platform provider and does not organize, supervise, manage, or control rides or rider conduct.

2. Eligibility: You must be at least 18 years old, or the legal age of majority in your jurisdiction, to use the App without parental or legal guardian consent. By using the App, you represent and warrant that you meet these eligibility requirements.

3. Assumption of Risk: Cycling and participation in group rides involve inherent risks, including but not limited to accidents, collisions, property damage, serious bodily injury, or death. By using the App and participating in rides, you voluntarily assume all risks associated with such activities. Participation in any ride listed or communicated through the App is entirely voluntary and undertaken at your own risk.

4. No Liability: To the fullest extent permitted by applicable law, Grupetto LLC, its owners, officers, employees, affiliates, administrators, contractors, sponsors, and representatives shall not be liable for any injury, death, loss, claim, damage, or any direct, indirect, incidental, consequential, or punitive damages arising from: - Participation in any ride or cycling activity; - Actions or omissions of ride leaders or other participants; - Road, traffic, weather, or environmental conditions; - Mechanical failures or equipment malfunctions; - Use or inability to use the App; or - User-generated content, communications, or interactions between users.

5. User Responsibilities: Users agree to: - Comply with all applicable traffic laws and regulations; - Ride responsibly and within their personal skill level and physical ability; - Wear appropriate safety equipment, including a helmet; - Maintain their bicycle and related equipment in safe working condition; - Respect other riders, pedestrians, motorists, and property; - Provide accurate account information; and - Use the App only for lawful purposes. Users are solely responsible for their own conduct and decisions while using the App or participating in rides or events.

6. Ride Leaders and User-Generated Content: Users who create or lead rides do so independently and are not employees, agents, or representatives of Grupetto LLC. Grupetto LLC does not verify the qualifications, experience, safety practices, or accuracy of ride information posted by users. Users are solely responsible for any content, ride descriptions, messages, photographs, or other materials they post through the App. Grupetto LLC reserves the right, but not the obligation, to remove any content or suspend accounts that violate these Terms or are deemed inappropriate, unsafe, unlawful, or harmful.

7. Account Security: Users are responsible for maintaining the confidentiality of their account credentials and for all activities conducted under their account. Grupetto LLC shall not be responsible for unauthorized access resulting from a user’s failure to safeguard account information.

8. Prohibited Conduct: Users may not: - Use the App for unlawful, harmful, or fraudulent purposes; - Harass, threaten, or endanger other users; - Post false, misleading, or defamatory content; - Impersonate another person or entity; - Interfere with the operation or security of the App; or - Attempt to gain unauthorized access to systems or accounts.

9. Intellectual Property: All trademarks, logos, branding, software, designs, text, graphics, and other content associated with the App are the property of Grupetto LLC or its licensors and are protected by applicable intellectual property laws. Users may not reproduce, distribute, modify, or commercially exploit any part of the App without prior written consent from Grupetto LLC.

10. Termination: Grupetto LLC reserves the right to suspend or terminate access to the App, at its sole discretion and without prior notice, for conduct that violates these Terms or is otherwise deemed harmful to the App, users, or third parties.

11. Privacy: Use of the App is also governed by the Grupetto Privacy Policy and any additional policies published by Grupetto LLC.

12. Disclaimer of Warranties: The App is provided on an “AS IS” and “AS AVAILABLE” basis without warranties of any kind, whether express or implied. Grupetto LLC does not guarantee uninterrupted access, accuracy, reliability, or safety of the App or any rides listed through it.

13. Indemnification: Users agree to defend, indemnify, and hold harmless Grupetto LLC and its owners, officers, employees, affiliates, and representatives from and against any claims, liabilities, damages, losses, costs, or expenses arising from: - Use of the App; - Participation in rides; - Violation of these Terms; or - Violation of any law or rights of a third party.

14. Governing Law: These Terms shall be governed and interpreted in accordance with the laws of the State of Maryland, without regard to conflict of law principles.

15. Modifications to Terms: Grupetto LLC reserves the right to modify or update these Terms at any time. Continued use of the App following any modifications constitutes acceptance of the updated Terms.

GRUPETTO

PRIVACY POLICY.

Grupetto LLC (“Grupetto,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you provide through the Grupetto mobile application and related services (collectively, the “App”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the App. By accessing or using the App, you consent to the practices described in this Privacy Policy.

1. Information We Collect: We may collect the following categories of information:

a. Personal Information Information you voluntarily provide, including: - Full name - Email address - Phone number - Profile photo - Username - Emergency contact information

b. Ride and Location Information When using ride-related features, we may collect: - Ride routes and ride history - GPS and location data - Check-in or meetup locations - Activity and performance data

c. Device and Usage Information We may automatically collect: - IP address - Device type and operating system - Browser type - App version - Usage activity and interactions within the App - Crash reports and diagnostic data

2. How We Use Information: We may use collected information to: - Provide and operate the App; - Create and manage user accounts; - Facilitate ride organization and participation; - Improve functionality, security, and user experience; - Communicate updates, notices, or support information; - Monitor usage and prevent fraudulent or harmful activity; and - Comply with legal obligations.

3. Location Services: Certain features of the App may require access to your device’s location services. You may disable location permissions at any time through your device settings; however, some App features may not function properly without location access. By enabling location services, you consent to the collection and use of your location data in connection with App functionality.

4. Sharing of Information: Grupetto LLC does not sell personal information to third parties. We may share information in the following circumstances: - With other users as part of ride participation features; - With service providers who assist in operating the App; - When required by law, subpoena, or legal process; - To protect the rights, safety, or property of Grupetto LLC, users, or the public; or - In connection with a merger, acquisition, or business transfer.

5. User Content: Any content you voluntarily post within the App, including ride details, comments, photos, or profile information, may be visible to other users. You are solely responsible for the information you choose to share.

6. Data Retention: We retain personal information only for as long as reasonably necessary to provide services, comply with legal obligations, resolve disputes, enforce agreements, or maintain operational records. We reserve the right to delete inactive accounts or associated data at our discretion.

7. Security: We implement commercially reasonable administrative, technical, and organizational safeguards designed to protect personal information. However, no method of electronic storage or transmission is completely secure, and Grupetto LLC cannot guarantee absolute security.

8. Third-Party Services: The App may contain links to or integrations with third-party services, including mapping, payment, analytics, or social media platforms. Grupetto LLC is not responsible for the privacy practices or content of third-party services. Users are encouraged to review the privacy policies of any third-party services they access through the App.

9. Children’s Privacy: The App is not intended for children under the age of 13. Grupetto LLC does not knowingly collect personal information from children under 13. If we become aware that such information has been collected, we may delete it promptly.

10. Your Rights and Choices: Depending on your jurisdiction, you may have rights regarding your personal information, including the right to: - Access your personal information; - Correct inaccurate information; - Request deletion of your data; - Withdraw consent where applicable; or - Request information about how your data is used. Requests may be submitted using the contact information below.

11. International Users: If you access the App from outside the United States, you understand and agree that your information may be transferred to and processed in the United States or other jurisdictions where data protection laws may differ from those in your country.

12. Changes to This Privacy Policy: Grupetto LLC reserves the right to modify or update this Privacy Policy at any time. Updated versions will be posted within the App or on the official website, with the revised effective date. Continued use of the App after changes become effective constitutes acceptance of the updated Privacy Policy.

GRUPETTO

DATA RETENTION.

Grupetto LLC (“Grupetto,” “we,” “our,” or “us”) is committed to maintaining and protecting user information responsibly and securely. This Data Retention Policy explains how long information collected through the Grupetto mobile application and related services (the “App”) is retained and how such information may be deleted or anonymized. By using the App, you acknowledge and agree to the practices described in this Policy.

1. Purpose of Data Retention: Grupetto LLC retains personal and operational data only for as long as reasonably necessary to: - Provide and maintain App functionality; - Facilitate ride organization and user interactions; - Improve platform performance and security; - Comply with legal, regulatory, tax, accounting, or reporting obligations; - Resolve disputes and enforce agreements; and - Protect the safety, rights, and integrity of users and the platform.

2. Categories of Data Retained: The following categories of information may be retained:

a. Account Information Including: - Name - Email address - Username - Profile information - Account preferences - Login and authentication records

b. Ride and Activity Data Including: - Ride participation history - Routes and ride details - Group memberships - Ride communications and interactions

c. Device and Technical Data Including: - IP addresses - Device identifiers - Browser and operating system information - Application usage logs - Diagnostic and crash data

d. Support and Administrative Records Including: - Customer support communications - Reports of misconduct or safety incidents - Administrative actions and enforcement records

3. Retention Periods. Grupetto LLC may retain data for the following general periods: - Active Accounts: Information is retained while an account remains active. - Inactive Accounts: Grupetto LLC reserves the right to deactivate or delete inactive accounts and associated information after a prolonged period of inactivity. - Ride and Activity Records: Certain ride history and activity records may be retained for operational, safety, analytics, or legal purposes. - Legal and Security Records: Information related to disputes, violations, investigations, or legal obligations may be retained for longer periods as required by law or legitimate business interests. Specific retention periods may vary depending on the nature of the information and applicable legal requirements.

4. Account Deletion Requests. Users may request deletion of their account and associated personal information by contacting Grupetto LLC through the designated support channels. Upon receiving a verified deletion request, Grupetto LLC will take reasonable steps to delete or anonymize applicable personal information within a commercially reasonable timeframe, subject to: - Legal retention obligations; - Fraud prevention and security purposes; - Dispute resolution; - Enforcement of agreements; and - Legitimate business and operational needs. Certain residual copies of information may remain in backups, archives, or system logs for a limited period.

5. Data Anonymization: Grupetto LLC may anonymize or aggregate certain data so that it can no longer reasonably identify individual users. Anonymized or aggregated information may be retained indefinitely for analytics, research, operational improvement, and business purposes.

6. Security of Retained Data: Grupetto LLC implements commercially reasonable administrative, technical, and organizational safeguards designed to protect retained data against unauthorized access, disclosure, alteration, or destruction. However, no security system is completely secure, and Grupetto LLC cannot guarantee absolute security.

7. Third-Party Service Providers: Certain information may be stored or processed by third-party service providers engaged by Grupetto LLC for hosting, analytics, communications, payment processing, or infrastructure services. Such providers may retain information in accordance with their own legal and operational requirements.

8. Changes to This Policy: Grupetto LLC reserves the right to modify or update this Data Retention Policy at any time. Updated versions will be published within the App or on the official website with the revised effective date. Continued use of the App after updates become effective constitutes acceptance of the revised Policy.