App Privacy Policy

Last updated: 2024-08-15

1.Introduction

1.1 This Privacy Policy explains howElectric Bicycle Innovation B.V. (hereinafter "we" or "us") collects, uses, discloses, transfers, stores and protects your personal data and what corresponding rights you have in relation to the processing of personal data. Personal data refers to any data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person.

1.2 This Privacy Policy concerns the personal data we collect through our mobileapp EBI Bike and bicycle app installed on your BikePlay and/or subdomains of the online services where this Privacy Policy is linked to (each an “Online Offering”).

1.3 This Privacy Policy describes:

What types of personal data do we process about you?
For what purposes do we process your personal data?
Disclosure of personal data to third parties
How are your personal dataprotected?
Protection of minors’ personal data
Retention of your personal data
International data transfer
Your rights
Changes and notifications
Contact Us

1.4 This Privacy Policy may be modified, e.g., as a result of new functionalities of the Online Offerings that require the processing of personal data. We therefore advise you to check this Privacy Policy regularly. Any material changes will be notified via the Online Offerings.

2. What types of personal data do we process about you?

2.1 Information that you provide to us directly through Online Offerings. This includes:

1) Createan account. When you want to use our services and products via Online Offerings, you need to create an account. We will collect: your email address to help you create an account;

2) User personaldata records. When you create an account via Online Offerings, we will collect: your nickname, photo, gender, age, height, weight to form your basic user profile.

3) Geolocation data.The GPS function is the core feature of BikePlay and we will collect your geolocation information through your EBI Bike and BikePlay for the purpose of GPS navigation, locating and finding your bicycle through EBI Bike and preventing the theft of the bi You can turn off the location to stop sharing gelocation information.

4) Device in We will collect device information suchas the data related to bicyle's terminal, frame, battery and motor. Since the data is linked to the connected bicycle and may be associated with you.

5) Interconnection between EBI Bike anBikePlay. When you connect a bicycle with the EBI Bike, we may collect data which may contain personal data:

The user information you choose to enter in your mobile app EBI Bikeincluding height and weight. We will use these body data to calculate the amount of energy and carbon emissions while riding.
The photos taken through the bicycle’scamera, and you choose to transfer these photos to the mobile app EBI Bike, which may contain personal data.
The bicycle status data which will access via mobile appEBI Bike. These data may reflect your personal riding habits or histories, or may have unique identification with the bicycle, thus may be associated with you.
Thegeolocation information can be transferred between EBI Bike an BikePlay, and the device information of the bicyle will be transmitted to the mobile app EBI Bike.

6) Contact Us.Any information that you choose to share when you contact us which may be considered personal data.

2.2 Information that we collect or generate about you.This includes:

1) Cyclingrecords. When you are in a cycling state, our app will record your geographical location data and whereabouts to form a cycling record.

2) User behaviour analysis and functional optimization. When you use our app, we may collect basic information about your deviceand the user operation record for behaviour analysis and fault detection, in order to optimize the functionality of our services and products.

2.3 Information obtained from third parties. This includes:

The personal data provided to us by third-party service providers, business partners, agencies or other publicly available sources where applicable.

2.4 We understand that the conversation information you enter, the message you submit, and other information you provide to us may contain other people’s personal data. In this case, you must obtain the legal authorization of others before providing it to avoid improper disclosure of others’ personal data.

3. For what purposes do we process your personal data?

3.1 Your personal data may be stored and processed by us in the following ways and for the following purposes:

To provide the Online Offering’s services and functions which includes creating and administering your account, calculatingyour personal energy consumption during riding, recording your personal riding history;
To improve and develop the Online Offering’s services and functions which includes updating, securing, troubleshooting and providing support;
To communicate with you about our products, services and projects, e.g., by responding to inquiries or requests or providing you with information about purchased products;
To maintain and protect the security of our Online Offerings, preventing and detecting security threats, fraud or other criminal or malicious activities;
To ensure compliance with legal obligations (such as record keeping obligations), export control and customs, customer compliance screening obligations, business compliance screening obligations, (to prevent white-collar or money laundering crimes), and our policies or industry standards;
To administrate and perform market analysis, sweepstakes, contests, or other customer activities or events;
For the administration and maintenance of databases storing personal data.

3.2 When we use your personal data, we make sure that the usage complies with applicable law, and the law allows us to use your personal data in these ways because of one or more of the following apply:

we have obtained your consent;(Article 6 (1) (a) General Data Protection Regulation).
the use of your personal data is necessary for the performance of the contractbetween you and us; (Article 6 (1) (b) General Data Protection Regulation)
we havelegal and regulatory obligations that we have to discharge; (Article 6 (1) (c) General Data Protection Regulation)
the use of your personal data is necessary for the protection of the vital interests of you or other natural person;(Article 6 (1) (d) General Data Protection Regulation)
the use of your personal data is necessary for the performance of a task carried out in the public interest; (Article 6 (1) (e) General Data Protection Regulation)
the use of your personal data as described is necessary for our legitimate business interests(Article 6 (1) (f) General Data Protection Regulation), including:

allowing us to effectively and efficiently manage and administer the operation of our business;
maintaining compliance with internal policies and procedures;
monitoring the use of our copyrighted materials;
direct marketing;
managing our relationship with you;
enabling quick and easy access to information on our services;
we need to do so in order to perform our contractual obligations with our other customers and third-party providers.

3.3 Marketing

Where and as permitted under applicable law, we may process your personal data for direct marketing purposes (e.g., trade show invitations, newsletters with further information and offers concerning our products and services) and to carry out customer satisfactions surveys, in each case also by e-mail.

You may object to the processing of your personal data for these purposes at any time by writing to service@ebibike.com or by using the opt-out mechanism provided in the respective communication you received.

If you decide to leave us, we may contact you to allow us to market our products and services to you after you have left for up to one year, unless you opt out.

4. Disclosure of personal data to third parties

4.1 We may disclose your personal data within our Group. We only share necessary personal data subject to the purposes stated in this Privacy Policy.

4.2 In our Online Offerings, we provide you with various features from external providers in order to offer you a user-friendly and intuitive navigation with regard to theuse of our services as well as other additional functions. In this context, your personal data will only be transferred to our business partners if this is necessary for the provision of the functionalities selected by you. You can revoke your consent for functionalities at any time directly in the Online Offerings. Please also note the privacy policy of the respective service providers. These external providers include:

1) Mapbox: We use the map service provider, Mapbox Inc, (740 15th St NW, 5th Floor Washington, D.C. 20005, USA) to offer you the navigation and route calculation functions. Further information about Mapbox’s services can be found at: https://www.mapbox.com/. Mapbox’s privacy policy can be found at: https://www.mapbox.com/legal/privacy.

2) Wheatherapi: We use the weather service provider, WeatherAPI.com, (Unit No. 001,IFZA Dubai - Building A1, Dubai Silicon Oasis, Dubai) to offer you the weather forecast functions. Further information about WeatherAPI’s services can be found at: https://www.weatherapi.com/. WeatherAPI’s privacy policy can be found at: https://www.weatherapi.com/privacy.aspx.

3) Google: We use various services from Google Inc. (1600 Amphitheatre Parkway,Mountain View, CA 94043, USA), to provide you with additional services and functions and develop our mobile or bicycle apps.

We use Google Text-to-Speech AI to convert the text data into voice in the context of voice broadcast service of navigation function. Further information about Google Text-to-Speech AI’s services can be found at: https://cloud.google.com/text-to-speech?hl=en. Google’s privacy policy can be found at: https://policies.google.com/privacy.
We use Google Firebase to conduct front-end code deployment and management, bug tracking in both mobile and bicycle apps. Further information about Google Firebase’s services can be found at: https://firebase.google.com/. Google’s privacy policy can be found at: https://policies.google.com/privacy.
We use Google Analytics to analyse the user operation data and device data via our mobile or bicycle apps. Further information about Google Analyitics’ services can be found at: https://analytics.google.com/. Google’s privacy policy can be found at: https://policies.google.com/privacy.

4.3 We also use external service providers of IT systemsand marketing services, call centres and programming to provide you with our services; These third parties will be subject to appropriate data protection obligations, and they will only use your personal data as described in this Privacy Policy;

4.4 In addition, your data may be transferred to public authorities if we are obliged to do so by law or byan enforceable official or court order. For example, if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;

4.5 If we sell our business or assets, in which case we may need to disclose your personal data to the prospective buyer for due diligence purposes; and

4.6 If we are acquired by a third party, in which case the personal data held by us about you will be disclosed to the third-party buyer.

5. What about links to other websites and social media?

The Online Offering may contain references (e.g., via hyperlinks) to other websites or apps, which are offered by third parties. You can also choose to share information to other social media platform including Facebook, Instagram and X. We are not responsible for the processing of your personal data via these websites or apps. We advise you to check the privacy policies, the terms and conditions of these websites and apps before downloading the apps or using their service. This Privacy Policy applies only to the Online Offering, and your use of third-party websites and apps is at your own risk.

6. How are your personal data protected?

6.1 Weuse Amazon Web Services to store the data collected and generated via Online Offerings. The cloud server is located in Frankfurt, Germany.

6.2 We strive to protect your personal data by means of technical and organizational measures that are in line with the industry standards, such as firewalls and secure servers so that access to your personal data is limited to authorised employees.

7. Protection of minors’ personal data

7.1 The Online Offeringis designed for adults. We will not knowingly collect any personal data about children.

8. Retention of your personal data

8.1 For how longwe will hold your personal data will vary and will be determined by the following criteria:

The purpose for which we areusing it: We are required to retain the personal data for as long as is necessary to satisfy or meet the purpose for which it was obtained or any other legal purpose.
Legal Obligations: Laws or regulations may set a minimum period for which wemust retain your personal data.

9. International data transfer

9.1 The recipients of your personal data may be located outside of the country in which you reside. That means that we may transfer your personal data to locations outside of your country, including countries outside European Economic Area (“EEA”). Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers to countries not considered adequate by the European Commission, we have put in place adequate measures, such as ensuring that the recipients arebound by EU Standard Contractual Clauses, to protect your personal data.

9.2 You can obtain more details of the protection given to your personal data when it is transferred outside your country by contacting us using the details set out under the “Contact Us” section below.

10. Your rights

In all the above cases in which we collect, use or store your personal data, you may have the following rights:

the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal data to comply with a legal obligation;
in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to us;
the right to request that we rectify your personal data if it is inaccurate or incomplete;
the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it;
the right to object to, or request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
the right not to be subject to a decision based solely on automated processing; and

the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

10.1 You can exercise your rights by contacting us using the details set out under the “Contact Us” section below.

11. Changes and notifications

11.1 We may update this Privacy Policy from time to time. If there is any material change to this Privacy Policy, we will notify you either by posting a notice on our Online Offeringor by sending you an email notice or by other means permitted under applicable law. You will be able to see our current Privacy Policy along with its most recent revision date. The revised Privacy Policy will take effect from the date of publication.

11.2 You should review this Privacy Policy periodically. By continuing to use our relevant products or services, you will be deemed to have accepted to the changes or updates to this Privacy Policy. If you do not agree to such changes or updates, you should not use our Online Offerings, products or services.

12. Contact Us

If you have any further questions about the processing of your personal data, about the Online Offering or about this Privacy Policy, you can always contact us:

by e-mail: service@ebibike.com

by telephone:+31 (0)62 912 8352

by mailing to: Bicycle Hub, Copernicusstraat 10, 6604 CR Wijchen, The Netherlands