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Website Privacy Policy

Last updated: 2024-08-15

1. Introduction

1.1 This Privacy Policy explains howElectric Bicycle Innovation B.V. (hereinafter referred to as “we”, “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 following data that we collect about you:

    A. Data we receive through our website at https://www.ebibike.com/;
    B. Data we receive when you inquire about the products or services offered by us.

    1.3 If this Privacy Policy does not cover certain scenarios where we use your personal data, we will explain these to you separately.

    1.4 This Privacy Policy describes:
      • What types of personal data do we process about you?
      • Cookies and similar technologies
      • For what purposes do we process your personal data?
      • Disclosure of personal data to third parties
      • What about links to other websites and social media?
      • 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
      1.5 This Privacy Policy may be modified, e.g., as a result of new functionalities of the websitethat require the processing of personal data. We therefore advise you to check this Privacy Policy regularly. Any material changes will be notified via the website.

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

      2.1 Information that you provide to us directly through thewebsite. This includes:
        1) Browsethe Website. When you visit our website and browse the information, such as such as the introduction of our company and E-Bike product, the story of our brand, the instruction manual, etc., we will collect: [IP address, device type, operation behaviour record];
        2) Create an When you want to use our services and products via the website, you need to create an account. We will collect: your first name, last name, your company name, email address to help you create an account;
        3) Purchase our products. When you place an order via our website to purchase our products, we may ask you to provide: your first name, last name, your company name, email address, telephone number and shipping address;
        4) Business Partner. When you want to become our business partner or want to know more about our services and products or cooperation matters, we may ask you to provide: your first name, last name, your company name, email address, telephone number, and the information contained in the message you sent to us;
        5) Job Application. When you apply for a job through the Recruiting Page of our website, we will collect: your first name, last name, primary email, experience level, area of interest, communities of interest, primary country/region, all the information on the resume you provided to us, including but not limited to your education background, employment history, compensation information, transcripts, country of residence, citizenship, visa and immigration status, reference information, and any other information (including sensitive personal data) you provide to us;
        6) Contact Us.Any information that you choose to share when you contact us which may be considered personal data.

          The types and the nature of the products or services you are using or requesting will determine the types of personal data we might ask.  

          2.2 Information that we collect or generate about you.This includes:
          • Information on your interaction with ouronline customer service, including your device and user identifier, information on your operating system, sites and services accessed during your visit, the date and time of each visitor request.
          2.3 Information obtained from third parties. This includes:
            • Our website is build on Shopify, so we may obtain personal data about you from Shopify. For information about how Shopify processes your personal data, please refer to Shopify's own privacy policy at https://www.shopify.com/legal/privacy.
            • 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. Cookies and similar technologies

            Cookies are used to collect technical information about the services that you use, and how you use them. Since our website is build on Shopify, we do not use cookies on the website ourselves, but Shopify will use cookies.  For information about how Shpify uses cookies on the website,  please see Shopify's cookie policy at: https://www.shopify.com/legal/cookies/. 

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

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

            • To provide services and functions via our website which includes creating and administering your account, updating, securing, and troubleshooting, providing support, as well as improving and developing our onlineservices;
            • 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 contact you with information and offers concerning our products and services, to send you further marketing information or to contact you in the context of customer satisfaction surveys;
            • To create a personal profile containing business-related information on interactions between you and us with the aim of being able to offer you and the company you work for relevant information and suitable offers for our services and products and to improve our personal communication with you;
            • To plan, perform and manage the (contractual) relationship with customers and business partners, e.g., by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;
            • To consider your job application (including, in some cases, verifying your qualifications, education and references with those third parties you name) and handle the recruitment process;
            • As reasonably necessary to enforce the onlineservice’s terms, to establish, exercise or defend legal claims, enforce our contractual agreements and to solve disputes;
            • To maintain and protect the security of our products, services and websites, 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.

              4.2 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 ourservices;
                • we need to do so in order to perform our contractual obligations with our other customers and third-party providers.

                4.3 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@ebike.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.

                5. Disclosure of personal data to third parties

                5.1 We may disclose your personal data within our group. We only share necessary personal data subject to the purposes stated in this Privacy Policy.
                5.2 We may also share your personal data to third parties for the following purposes:
                  • with our business partners in connection with your use of the Online Offerings or our business relationship with you, such as sales partners or suppliers. Personal data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
                  • with third party agents and contractors for the purposes of providing services to us (for example, our accountants, service provider for payment services, professional advisors and IT and communications providers). 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;
                  • to the extent required by law, 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;
                  • 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
                  • 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.

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

                    The website may contain references (e.g., via hyperlinks) to other websites or apps, which are offered by third parties. 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 our own website, and your use of third-party websites and apps is at your own risk.
                    In addition, our website is build on Shopify, if you use Shopify's own services such as Shop or Shop Pay, Shopify may process your personal data itself and we are not responsible for its processing activities.  For more informaiotn about Shopify's processing about your personal data, please see Shopify's own privacy policy at: https://www.shopify.com/legal/privacy.

                    7. How are your personal data protected?

                    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.

                    8. Protection of minors’ personal data

                    8.1 Ourwebsite is designed for adults. We will not knowingly collect any personal data about children.

                      9. Retention of your personal data

                      9.1 For how long wewill hold your personal data will vary and will be determined by the following criteria:
                        • The purpose for which weare using 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.

                          10. International data transfer

                          10.1 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. 
                          10.2 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.

                            11. 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.
                            11.1 You can exercise your rights by contacting us using the details set out under the “Contact Us” section below.

                              12. Changes and notifications

                              12.1 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 website or 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.
                              12.2 You should review this Privacy Policy periodically. By continuing to use our website, 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 products or services via the website.

                                13. Contact Us

                                If you have any further questions about the processing of your personal data, about the online services and products via our website or about this Privacy Policy, you can always contact us:
                                by telephone: +31 (0)62 912 8352
                                by mailing to: Bicycle Hub, Copernicusstraat 10, 6604 CR Wijchen, The Netherlands

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