Pacific Cycle Privacy Policy
Last Updated: October 12, 2023
Scope
This Privacy Statement governs the collection, use and other forms of processing of personal data by Pacific Cycle Inc. and its affiliates under common ownership (“Pacific Cycle”) related to our services, our products and this website.
Who is responsible for processing your personal data?
Pacific Cycle Inc. (4902 Hammersley Rd, Madison, WI 53711, United States of America) is the legal entity responsible for all collection and all processing of your personal data in connection with our products, services and websites.
Pacific Cycle is part of Pon Holdings B.V. its affiliates and its subsidiaries (“Pon”). Pacific Cycle and Pon are committed to respecting and safeguarding your privacy and the security of your personal data you share with us.
Why do we process your personal data?
Personal data is information that identifies you as an individual or relates to an identifiable individual. When you choose to register your personal data, contact us, or visit our websites, we will process some personal data about you. We process these personal data for the following purposes:
communicate with you in a personal way or to inform you about Pacific Cycle products or services, consistent with your choices;
provide customer service, including service around the purchase of services and products, fulfil warranty obligations and product recalls for our own services and those of related companies, and to deal with any enquiries or complaints;
administer and fulfil your purchases of Pacific Cycle products including the financial and logistic handling;
administer your Pacific Cycle account;
administer your participation in any contests, promotions, surveys or website features;
perform market research and improve our business, services and Pacific Cycle products or to develop new business, services and products;
perform statistical analyses and reporting;
providing services on the internet;
offering a loyalty program and communicating with participants;
provide app functionality, including providing relevant commercial messages;
to communicate future promotional and marketing information including direct marketing purposes and retargeting;
to aggregate and/or anonymize personal data in order to generate other data for our use;
to comply with our legal obligations, resolve disputes, or enforce our agreements;
as otherwise stated at or about the time information is collected.
Which personal data do we process?
Which personal data we exactly process, depends on which websites, products or services you use. We process the following personal data.
Personal data you provide to us:
● This is the personal data that you enter when you use our websites, products or services. This data includes e.g. your name, address, gender, height and weight, email address, phone number, age, birth date, Pacific Cycle products you bought, the account name and password that you create, bank details for buying Pacific Cycle products etc.
How do we process your personal data?
In the table below we describe the way of processing personal data and the purposes for which we process the personal data as well as the legal basis for the processing:
| Ways of processing | Personal data processed | Purposes for processing the personal data | Legal basis |
|---|---|---|---|
| Registration for our newsletter | First name, Country, Email | The above described purposes: 1, 2, 6, 7, 8, 11, 12, 13 and 14 | Consent or legitimate interest |
| Contact form customer service | First name, Last name, Country, Email | The above described purposes: 1, 2, 6, 7, 8, 11, 12, 13 and 14 | Performance of a contract or legitimate interest |
| Pacific Cycle account creation | First name, Last name, Country, Email | The above described purposes: 1, 2, 4, 6, 7,8, 9, 11, 12, 13 and 14 | Consent, legitimate interest or performance of a contract |
| Pacific Cycle product registration | First name, Last name, Address, City, Country, Telephone number, Email | The above described purposes: 1, 2, 3, 6, 7, 8, 9, 11, 12, 13 and 14 | Performance of a contract or legitimate interest |
| Buying Pacific Cycle products on the website | First name, Last name, Address, City, Country, Telephone number, Email, Payment information | The above described purposes: 1, 2, 3, 6, 7, 8, 9, 11, 12, 13 and 14 | Performance of a contract or legitimate interest |
| Attend to product promotion, events or online forum | First name, Last name, Country, Email | The above described purposes: 1, 5, 6, 8, 11, 12, 13 and 14 | Consent or legitimate interest |
| Visit our websites (cookies) | Please refer to our Pacific Cycle Cookie Policy for further details | The above described purposes: 6, 7, 8, 11, 12, 13 and 14 | Consent or legitimate interest |
| Log on our websites via social media | We never get access to your social media account | The above described purposes: 1, 6, 7, 8, 11, 12, 13 and 14 | Consent or legitimate interest |
Our legitimate interests include: marketing, advertising, security, (crime) prevention, IT management, research and analysis of our products or services, business management, legal affairs, internal management.
You have the right to withdraw your consent which you may have given to the processing of your personal data at any time by sending your withdrawal request to dataprivacy@pacific-cycle.com.
How do we share or transfer your personal data?
You should be aware that Pacific Cycle is part of a business group within Pon and that departments (like IT, Marketing) can be located in Pon companies around the world. As a consequence your personal data may be shared within and/or transferred to other business group companies or other Pon companies around the world. You can consult the list and location of our companies here: http://www.pon.com/en/our-business/bedrijven.
Pacific Cycle may share your personal data also with third parties to perform certain processing activities. These can include providers of services such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. Pacific Cycle may also share your personal data to third parties, to permit them to send you marketing communications, consistent with your choices. Pacific Cycle requires these third parties to process and protect your personal data diligently. Pacific Cycle will not sell your personal data to third parties.
Pacific Cycle or Pon might reorganize, merge or in any other way sell or dispose (part of) a business company to another company. Where such business relates to Pacific Cycle products, such transfer of ownership may include the transfer of your personal data to the new owner and its advisors.
We will otherwise only disclose your personal data if so required or authorized by law, where necessary for preventing or combating fraud, where necessary for dispute resolution, or for any other pressing legitimate need which under the circumstances must outweigh your privacy interests, such as the security of our business and the safety of our staff.
How do we protect your personal data?
Pacific Cycle will take appropriate technical and organizational security measures against loss or unlawful processing of personal data. This may include using secure registration forms, encryption of data, and restricting access to your personal data.
Please note that some countries do not provide for an adequate level of protection for your personal data. However, you can be assured that Pacific Cycle will take appropriate safeguards for the confidentiality and protection of your data. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, standard contractual clauses adopted by the European Commission, to protect your personal data. You may obtain a copy of these measures by contacting dataprivacy@pacific-cycle.com.
How long do we retain your personal data?
We retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
● The length of time we have an ongoing relationship with you and provide our services to you (for example, for as long as you have an account with us or keep using our services);
● Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
● Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Cookies, web beacons and similar techniques
If you are using our websites, services, applications, communications (including email) and accessing or using tools, we may use cookies, web beacons and other similar technologies for storing information to provide you with a better, faster and safer browser experience.
Please refer to Pacific Cycle’s Cookie Policy for the explanation of cookies, web beacons and similar techniques, how we use these techniques and how you can control these techniques.
Children
Our services are not directed to children who are under the age of 16. We do not knowingly collect personal data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal data to us through our services, please contact us at dataprivacy@pacific-cycle.com and we will endeavour to delete that information from our databases.
Your rights
If you would like to request to review, correct, update, suppress, restrict or delete personal data, object to the processing of personal data, or if you would like to request to receive an electronic copy of your personal data for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us via dataprivacy@pacific-cycle.com or 4902 Hammersley Rd, Madison, WI 53711, United States of America (Office of the General Counsel, Attn: Privacy Compliance Counsel). We will respond to your request consistent with applicable law.
In your request, please make as clear as possible what personal data your request relates to. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event within any applicable legally required timeframes.
Contact, questions, feedback and Data Protection Officer
If you have any questions about this Privacy Statement, please contact us at dataprivacy@pacific-cycle.com.
You may also contact our Data Protection Officer (DPO) via dataprivacy@pacific-cycle.com. You have the right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.
Policy changes
We may change this Privacy Statement from time to time. Any changes will become effective when we post the revised Privacy Statement. If necessary, we will inform you when we change the Privacy Statement. This statement was last modified on date: September 28, 2023.
PRIVACY NOTICE ADDENDUM FOR CALIFORNIA RESIDENTS
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we hereby provide additional details regarding the categories of Personal Information* about California residents that we have collected or disclosed within the preceding 12 months.
*“Personal Information” as defined in Section 1798.140 of the CCPA means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
WE COLLECTED THE FOLLOWING CATEGORIES OF PERSONAL INFORMATION:
o Identifiers, such as name, contact information, online identifiers, and government-issued ID numbers;
o Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number, medical information, insurance information, education information, employment information, and government-issued ID numbers;
o Characteristics of protected classifications under California or federal law, such as gender and marital status;
o Commercial information, such as transaction information and purchase history;
o Biometric information, such as fingerprints and voiceprints;
o Internet or network activity information, such as browsing history and interactions with our website;
o Geolocation data, such as device location and IP location;
o Audio, electronic, visual, and similar information, such as call and video recordings;
o Professional or employment-related information, such as work history and prior employer; and
o Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.
As described above, we collect this Personal Information from you and from other categories of sources: publicly available databases, joint marketing partners and OEMs when they share the information with us. Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
WE DISCLOSED THE FOLLOWING PERSONAL INFORMATION TO THIRD PARTIES FOR OUR OPERATIONAL BUSINESS PURPOSES:
o Identifiers, such as name, contact information, online identifiers, and government-issued ID numbers;
o Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number, medical information, insurance information, education information, employment information, and government-issued ID numbers;
o Characteristics of protected classifications under California or federal law, such as gender and marital status;
o Commercial information, such as transaction information and purchase history;
o Biometric information, such as fingerprints and voiceprints;
o Internet or network activity information, such as browsing history and interactions with our website;
o Geolocation data, such as device location and IP location;
o Audio, electronic, visual, similar information, such as call and video recordings;
o Professional or employment-related information, such as work history and prior employer; and
o Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.
We share Personal Information with our affiliates, service providers, third-party sponsors of sweepstakes, contests, and similar promotions, and our business partners.
For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
CALIFORNIA RESIDENTS MAY REQUEST THAT WE:
Disclose the following information covering the 12 months preceding their request:
The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
The specific pieces of Personal Information we collected about you;
The business or commercial purpose for collecting Personal Information about you; and
The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us in accordance with the “Contact Us” section below. We will respond to your request consistent with applicable law.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
CONTACT US - INFORMATION FOR CALIFORNIA RESIDENTS
If You Have Any Questions, Comments or Concerns About Our Privacy Practices or This Policy, Please Contact Us Via Toll Free Number or Email.
PHONE (Toll Free): (+1) 833-482-3734
