We respect your privacy and private information, and we’ll only ever use your personal data to give you a better riding experience. Here we’ll explain exactly what data we use, how we use it, and how we protect your data to keep you safe. We encourage you to read this Privacy Policy to understand what we do with the personal data we collect from you and how we keep you safe. This Privacy Policy applies to the use of SUWAY website, App and products (collectively, the “Services”), effective from March 14, 2022. From time to time, you may be able to follow a link to the websites or services of other companies or individuals from our website or our App. These companies or individuals may collect your personal data in accordance with their own privacy policies. Urtopia’s Privacy Policy does not extend to these external websites, services and third parties.
1 PRIVACY POLICY SUWAY and its affiliates
1.1 We are SUWAY. We respect your privacy and private life, but sometimes we need your Personal Data. In this privacy policy, we explain which data we use and how we save, protect and process these data. This privacy policy applies to the use of:
1.1.1 our website https://www.suwaybike.com (the "Website"),
1.1.2 the services that we offer (the "Services"), for example, the selling of bikes, Peace of Mind Maintenance and Peace of Mind Theft.
1.1.3 our app (the "App"),
1.1.4 Website, Services and App together are referred to as our “Platform”.
1.2 We comply with the General Data Protection Regulation (the "Relevant Legislation"), This policy is effective from May 20, 2023.
2.1 If you are younger than sixteen years old, you cannot use our Website, Services and App without the permission of your parents or legal guardian.
3 Personal Data
3.1 To offer our Website, Services and App we process Personal Data and Non Personal Data. "Personal Data" means any information relating to an identified or identifiable natural person as defined in the Relevant Legislation. “Non- Personal Data” is information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity.
4 Lawful basis
4.1 We can collect and process your data at various moments, for example when you visit our Website, create an account via our Website for example for making a purchase, use our Services, install and use our App or Rides feature, or when you contact us.The lawful basis for our processing can be:
4.1.1 the necessity to carry out the agreement between you and us,
4.1.2 compliance with legal obligations,
4.1.3 your consent,
4.1.4 our legitimate interests or the legitimate interests of a third party,
4.1.5 a legal requirement to share Personal Data.
5 What data do we collect and process and how do we use your data?
5.1 When you use our Platform, we need the following contact data. We need these data for your interactions with SUWAY viadigital/electronic tools such as e-mail or telephone; for example to process your order efficiently and correctly, to connect you to your bike, for pre and post sale services, for the use of your account, to improve our services, for marketing purposes, and for any other business/commercial purposes:cessing can be:
5.1.1 Your name
5.1.2 Your address
5.1.3 Your residence
5.1.4 Your phone number
5.1.5 Your e-mail address
5.1.6 Your IP-address
5.1.7 Your payment details
5.1.8 Your shipping address
5.1.9 Your username and password
5.1.10 Your reference number
5.2 For some orders (for example, for our B2B partners) we also need:
5.2.1 Company name
5.2.2 Date of birth
5.2.3 IBAN number
5.3 We may also collect and process the following Non-Personal Data if you use our Platform:
5.3.1 The type of your browser
5.3.2 The operating system that you use
5.3.3 The internet service provider
5.3.4 Website behaviour
5.4 We may also collect and process the following Non-Personal Data if you use our App. We use these data to provide support and improve our services:
5.4.1 Operating system & version
5.4.2 Type of Device
5.4.3 App version
5.4.4 Firmware version
5.4.5 Bike settings, e.g. Speed Limit, Total distance, Battery Level.
5.5 After your explicit consent, you allow the App to collect and process Non-personal Bike event data from your bicycle, e.g. Distance, Speed, Battery level, Boost Behaviour, when you are using our Rides feature. We use these data to execute the feature, provide support, improve our services and products and for marketing purposes. The App does not share the Bike event data with third parties.
5.6 After your explicit consent, you allow the App to access Bluetooth and GPS data (each also called location data). The App allows you to use Bluetooth data locally on your telephone. The App does not share the location data with third parties. SUWAY does not collect the location data on its servers, nor uses or shares it.
5.7 After your explicit consent, you allow the App or the Bike, or both, to use location data for explicitly specified features. The App does not share the location data with third parties. SUWAY collects the location data on its servers and uses it for the execution of thefeature.
6 Market research
6.1 We may ask you to participate in market research. In that case, we shall use your data for that market research. We use that statistical data pseudonymised for SUWAY We do not sell, trade or share your answers with others or make them publicly available. In addition, your answers are not connected to your e-mail address.
7 Newsletter
7.1 SUWAY offers newsletters. That way, you are fully informed of (discount)offers and other news. We use a double opt-in system to be sure of your permission. This means that you verify your permission for any new confirmation. We ask you for this verification via an e-mail that we send to the address you have given us. Every time we send you a newsletter you have the possibility to unsubscribe from the newsletter.
8 Security
8.1 We observe reasonable procedures to prevent unauthorised access to, and the misuse of, Personal Data.
8.2 We use appropriate business systems and procedures to protect and safeguard the Personal Data you give us. We also use security procedures and technical and physical restrictions for accessing and using the Personal Data on our servers. Only authorized personnel are permitted to access Personal Data in the course of their work.
9 How long do we store your Personal Data?
9.1 We will not retain your Personal Data longer than is legally allowed, and only as long as is necessary to enable you to use our Platform, including maintaining the online user account if created), to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All Personal Data we retain will be subject to this Privacy Policy.
10 With whom do we share your Personal Data?
10.1 Processors and other business partnersWe may share your Personal Data with Processors, within the meaning of the Relevant Legislation. We may also share Personal Data with third parties who are not processors, as per contractual obligation, for example, other Controllers who provide services connected to the use of our Platform. With these parties, we make clear agreements about the use and protection of Personal Data. We may share your Personal Data for example with IT service providers, marketing analytics, advertising platforms, payment platforms, cloud based data warehousing, lease companies and consumer review platforms. They will, for example, store and visualize data, process transactions, and perform marketing activities.
11 Transfer
11 .1 The Personal Data that we collect from you is stored within the European Economic Area (“EEA”), but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your Personal Data will be carried out in compliance with applicable laws.
12 Links
12.1 You may find advertising or other content on our Website that link to other websites. We do not control the content on these websites and are not responsible for the content or the privacy protection of these websites. We advise you to read the privacy policies of those websites.
13 Cookies
13.1 SUWAY uses client-side browser storage like cookies. Cookies are text files that your device or browser stores when you visit our website. SUWAY can also use techniques similar to cookies, such as tracking pixels, flash cookies, Java scripts, tags and web beacons. We classify all these techniques under the term Cookies.Cookies are used to send data from a server to your device or browser for the purpose of being stored. On a subsequent visit, this data is sent back to the server. This way the server can recognize your device or browser.
14 Update to this notice
14.1 We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Platform or through other means, such as e-mail. We encourage users to periodically review this notice for the latest information on our privacy practices.
14.2 After such notice, the use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.