US Privacy Policy

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U.S. Privacy Policy Effective Date: April 22, 2022

Date Last Updated: April 22, 2022

This Privacy Policy (“Policy”) describes how Serial 1 Cycle Company, LLC and our brands, affiliates, and subsidiaries (“Serial 1,” “we,” “us,” and “our”) collect, use, and disclose your Personal Information when you visit our websites, download our mobile applications, activate our ebikes, and use any of our products, tools, and any other services that reference this Policy (collectively, the “Services”). We also collect and use Personal Information when you purchase ebikes or accessories from us or our retailers (“Products”). Before you use our ebikes or submit any information through or in connection with the Services, please carefully review this Policy. By clicking checking the box, by signing up for an account or, where permitted, using any part of the Services, regardless of how you access the Services, you acknowledge you have read this Policy and consent to the collection, use, and disclosure of your information as further outlined in this Policy and our Terms of Service. This Policy covers our data practices within the U.S. If you are located in a European Economic Area country, please review our E.U. Privacy Notice below.

Table of Contents

  1. About Serial 1
  2. Personal Information We Collect
  3. How We Use Personal Information
  4. How We May Disclose Personal Information
  5. Our Cookie Policy
  6. Do Not Track
  7. Information Regarding Children
  8. California Privacy Rights
  9. Legal Disclaimers
  10. External Links
  11. Updates to This Privacy Policy
  12. Contact Us

1. About Serial 1

Serial 1 manufactures and provides ebikes and related services and applications including mobile applications that permit the collection of data about the ebike and its use.


2. Personal Information We Collect

We collect information that identifies, describes, or is reasonably capable of being associated with you ("Personal Information”). Personal Information does not include publicly available information from government records, deidentified information, or aggregated information. We collect and use certain types of Personal Information for various reasons depending on how you interact with us or your ebike. The following describes the types of Personal Information we collect.

Personal Information We Collect Directly From You

We may collect Personal Information directly from you when you activate and use your ebike or use our Services, including if you register for an account, fill out a survey, or otherwise communicate with us. The Personal Information you provide directly to us may include:

  • Contact Information. If you provide contact information when you register your account, use our Services, or purchase our Products, we may collect your name, telephone number, email address, address, and zip code.
  • Account Details. If you register for an account with us, including via our mobile application, we collect your username and password, as well as other information you provide to us related to your account.
  • Message Contents. If you contact our customer service team, we may collect your messages or emails.
  • Audio, Visual, or Similar Information. If you speak with our customer service team by phone, we may collect a recording for quality assurance and training purposes.
  • Preferences. We may collect information about the types of Services you use, your communications preferences, and other preferences you may select in your account or when using the mobile application.
Personal Information that is Passively or Automatically Collected

We may automatically collect the following Personal Information from or about you (or from or about others if you allow them to use your ebike):

  • eBike Information. When you power on and use your ebike we collect various device and usage information, including device ID, GPS latitude and longitude information, firmware version, and other information about the ebike’s operation and performance. Note: you have the option to disable this data collection via our mobile application but doing so may negatively impact your use of our Services, including features available via our mobile application such as ebike tracking and theft notification features.
  • Device Identifiers. When you visit our site or use our mobile application we may automatically collect information such as IP address, unique device identifier, IMEI and TCP/IP address, operating system, mobile device carrier information, and other information about your computer or device. We may also collect information about your browser type and browser language.
  • Network and Network Activity Information. We may collect information related to how you interact with the Services and advertisements, such as referring and exit web pages and URLs, browsing history, and other similar information. As described below in Section 5 on Cookies, we may use analytics providers and technologies, including cookies and similar tools, to collect this information.
  • Geolocation. When you use your ebike with location features enabled we collect geolocation data via GPS devices on the ebike. Additionally, depending on your device settings, if you visit our website or use our mobile application, we may collect geolocation information from your IP address which links to the region you live in.

Please Note: as specified in our Terms of Service, if you allow others to use your ebike it is your responsibility to inform them of the information collected, including that you may be able to view information about their location and ride status via the mobile application.

Other Ways We Collect Personal Information

We may collect Personal Information about you through our affiliates, business partners, retailers, and vendors who provide services or sell products on our behalf. For example, we may receive your Personal Information from our retailers for warranty purposes. These parties may have their own privacy policies for handling your information. You should review their terms and conditions and privacy policies for more information.

Advertising Information. We use Rakuten Advertising for our digital marketing solutions. When you interact with our website or mobile application, Rakuten may receive your personal information including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about Rakuten's use and sale of your personal data and your rights, please visit Rakuten's Privacy Policy and learn more about Your Rights.


3. How We Use Personal Information

We may use the Personal Information we collect for the following purposes:

  • Operate our Business and Provide You Services. We use Personal Information to allow you to use our Services, maintain your account, and otherwise run our day-to-day operations. As noted above, some of our Services involve the use of the ebike’s geolocation and other vehicle information, including ride tracking and recording features, range and battery estimation, and theft notification features.
  • To Communicate With You. We may use Personal Information to communicate with you about our Services, your account, technical support, and if you contact us with a question or concern. With your consent, we may also use Personal Information to send SMS messages regarding our Services.
  • Evaluate and Improve our Products and Services. We may use the Personal Information we collect for product and Service improvement, quality assurance, training, and to measure, improve, and understand the effectiveness of Services and its features. We also use this information to develop new Service offerings.
  • To Create Inferences. We may use Personal Information we collect to create inferences about you, including your riding style and habits. We use these inferences to customize our Services and provide you with a better experience.
  • Marketing and Advertising. We use Personal Information to contact you with surveys and information regarding our products and Services and those of our business partners that we believe may be of interest to you. This may include commercial emails sent on behalf of ourselves, our affiliates, and our advertisers.
  • Security Purposes. We may use Personal Information to mitigate fraud and protect Serial 1 and others. For example, if you submit a privacy rights request to us we may use Personal Information to verify your identity.
  • Legal Requirements. We may use Personal Information to comply with lawful court orders, law enforcement requests, or other legal requirements.
  • Other Operational and Business Purposes. We may use Personal Information for purposes not provided for in this Policy, but if we do, we will notify you (and, if necessary, obtain your consent) before using your Personal Information in this way.

4. How We May Disclose Personal Information

We may disclose and/or share Personal Information with our affiliates, business partners, and vendors under the following circumstances:

  • At Your Request. We may disclose your information to others when it is necessary to provide the Services you requested.
  • Vendors and Agents. We may provide access to or share your Personal Information with vendors who perform services on our behalf, including research and development, marketing, market research, customer support, data storage, analysis and processing, and legal services.
  • Our Business Partners. When Serial 1 partners with other businesses to offer products and services, we may share your Personal Information with those business partners. For example, we may share your Personal Information with retailers or component manufacturers for sale and warranty purposes.
  • To enable Google Maps Features. When you use our Services, and in particular the Services provided through our mobile application, you are electing to use services provided by Google Maps. Your use of these Services may result in our sharing of certain Personal Information, including geolocation data, with Google. Google and its affiliated companies may use and retain this data to provide and improve Google products and services. The use of any Google Maps supported features within our Services is not subject to this Policy, and is instead subject to the then-current versions of the: (1) Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html; and (2) Google Privacy Policy at https://www.google.com/policies/privacy/.
  • Protection of Serial 1 and Others. We may disclose Personal Information if required to do so by law, or if we believe in good faith that such disclosure is reasonably necessary to comply with legal obligations. We may also disclose Personal Information to protect our rights and the rights of others. This may include exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
  • Corporate Transactions. As we continue to develop our business, we may buy, merge, or partner with other companies. We may disclose Personal Information as part of those transactions (including in contemplation of such transactions, e.g., due diligence). Where possible we will do so under appropriate confidentiality agreements.
  • With Your Permission. We may disclose Personal Information in ways not described above. If we do so, we will notify you and, if necessary, obtain your consent.


6. Do Not Track

Some web browsers and mobile operating systems offer a “Do Not Track” setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. At this time our websites and Services do not recognize “Do Not Track” signals.


7. Information Regarding Children

Our website, products, and Services are not intended for minors. We do no intentionally collect Personal Information online from children under 13 years of age without parental consent. If we become aware that we have collected information from a child under 13 years old online without parental consent, we will delete such information from our records. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please contact us at the email, address, or phone number provided below under Contact Us.


8. California Privacy Rights

This section provides additional information for California residents pursuant to the California Consumer Privacy Act (“CCPA”). If you are a California resident, you may have additional rights under the CCPA, as explained in this section.

This section does not address or apply to our handling of personal information that is exempt under the CCPA. To the extent Serial 1 collected your Personal Information while you were acting in your capacity as an owner, director, officer, employee, or contractor of a business (“ B2B Contacts”), then these California Specific Rights do not yet apply to you. B2B Contacts include our retailers’ employees.

Categories of Personal Information Collected and Disclosed

The table below describes the categories of Personal Information (as further described in the “Information We Collect” section above) that we have collected and disclosed for a business purpose in the prior 12 months.

For more information about these categories, and the business and commercial purposes for which we may collect or disclose such information, please review Sections 2 – 4 above.

 

Categories of Personal Information Collected Description Categories of Recipients
Identifiers Includes direct identifiers, such as name, username, email address, phone number, device ID, and other similar identifiers.
  • Service providers and vendors, including our hosting and analytics providers, and supply chain and logistics providers.
  • Business partners.
Account Details Includes information such as username (your email or phone number) and password collected when you register for an account to use the Services.
  • Service providers and vendors, including our e-commerce provider.
Geolocation Includes an ebike’s precise location information.
    • Service providers and vendors, including our hosting and analytics providers.
  • Public entities or law enforcement if you request we share this information when a theft has occurred.
Audio, Visual, or Similar Information Includes phone call recordings, if you contact our customer service.
  • Service providers and vendors.
  • Advisors and agents.
Internet and Network Activity Information Includes browsing history, Cookie data, and other usage data and information regarding an individual’s interaction with our Services, marketing emails, and online ads.
  • Service providers and vendors, including ad companies and analytics providers.

The Right to Request More Information

You may have the right to request more information about how we have treated your Personal Information in the past 12 months, including:

  • The categories of Personal Information we collected about you;
  • The categories of sources from which we collected that information;
  • Our business or commercial purpose for collecting or selling that information;
  • The categories of third parties with whom we shared that information; and
  • The specific pieces of Personal Information we collected about you.

The Right to Request Access

You may also have the right to receive a copy of the Personal Information we collected about you in the past 12 months, but no more than twice in a 12-month period. The Right to Request Deletion Under certain conditions, and subject to exceptions, you have the right to request that we delete your Personal Information.

How to Exercise Rights to Request More Information, Access, and Deletion

To submit a request to exercise these rights you may use one of the following methods:

  • Phone: (844) 737-4251 (toll free)
  • Email: support@serial1.com

For all requests, please clearly state that the request is related to “Your California Privacy Rights,” indicate which type of request you are making, and provide your name and email address or phone number where you may be contacted. We may not be able to respond to requests that are not properly communicated, or that do not include complete information.

Verification

Before responding to your request, we must first verify your identity using the Personal Information you recently provided to us. You must provide the email you used to register your account with us and the serial number of your ebike for us to verify your identity. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request.If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Designating an Authorized Agent

You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf. We may also ask you directly to verify you have authorized your Authorized Agent to act on your behalf.

Right to Opt-Out

 

California residents have the right to opt out of “sales” of their Personal Information under the CCPA. The CCPA broadly defines both “Personal Information” and “sale.” We do not receive monetary compensation from third parties when we share Personal Information.

We may share the following categories of Personal Information with advertising companies, marketing companies, social media platforms, and analytics partners for target advertising, marketing, and campaign management purposes: identifiers, internet, and network activity information, and other information about how you interact with our website or mobile application.

Some of this data sharing may be considered a “sale” as broadly defined by the CCPA. You can request to opt-out of future “sales” of your Personal Information by using our Cookie preferences tool. Please note that submitting an opt-out request will only opt you out of disclosures that are considered “sales” under CCPA, but it will not opt-out of the other disclosures, such as to our service providers.

Our websites and mobile applications are not intended for use by individuals under the age of 18. We do not have actual knowledge that we “sell” information from individuals under 16 years old.

Your Privacy Rights Under the California Shine the Light

California residents who provide us certain Personal Information are entitled to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. You can submit a “Shine the Light” request by using the contact information below under Contact Us. Please include in your request a current California address and your attestation that you are a California resident.


9. Legal Disclaimers

Restrictions Nothing in this Privacy Policy restricts Serial 1’s ability to:

  • Comply with federal, state, or local laws;
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
  • Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law;
  • Exercise or defend legal claims;

Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or

Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of our business.



11. Updates to This Privacy Policy

This Privacy Policy is reviewed and updated regularly. If we change this Policy, we will post the updated Privacy Policy here, and those changes will go into effect on the “last updated” date shown above. We will take your continued use of our Site and Services to mean you accept the terms of the updated Policy. We will not retroactively use or share your Personal Information for materially different purposes without first taking reasonable steps to provide you notice.


12. Contact Us

If you have any questions about our Policy, you can contact us by emailing us at support@serial1.comYou can also write to us at -Serial 1 Cycle Company, LLC3451 North Triumph Blvd.Suite 100Lehi, UT 84043 United States



Privacy Notice for EEA and UK

May 17, 2022

Date Last Updated:May 17, 2022

This Privacy Notice (“Notice”) describes how Serial 1 Cycle Company, LLC with offices at 3451 North Triumph Blvd., Suite 100, Lehi, UT 84043, United States (“Serial 1 ,” “we,” “us,” and “our ”) collect, use, and disclose the Personal Data of users located in the European Economic Area (“EEA”), and the United Kingdom (“UK ”). This Notice applies to people who visit our website (“Site”) at [URL ], use our mobile application (“App”), and/or our connected ebikes (“connected ebikes”) (collectively, “ Users”). Before submitting any Personal Data to our Site, App, or using a connected ebike, Users should carefully review this Notice. By checking the box provided in our App or on our Site, Users acknowledge they have read this Notice and agree to our Terms of Service. Serial 1 Cycle Company, LLC is the controller of our Users’ Personal Data. This Notice covers our data practices for Users in the EEA and UK. Users located in the U.S. should review our U.S. Privacy Notice above.


Contents

  1. About Serial 1

  2. Personal Data We Collect

  3. Personal Data We Automatically Receive

  4. Other Ways We Collect Personal Data

  5. Legal Bases and Purposes for Using Personal Data

  6. How We Share Personal Data

  7. International Transfers of Personal Data

  8. Cookie Policy

  9. Information Regarding Persons Under 18

  10. Retention of Personal Data

  11. Privacy Rights

  12. External Links

  13. Updates to This Privacy Notice

  14. Contact Us


1. About Serial 1

Serial 1 manufactures and provides connected ebikes and related services and applications including mobile applications that permit the collection of data (including Personal Data) about Serial 1 connected ebikes and their use. We also operate the Site, which collects data about visitors to our Site, and purchasers of our connected ebikes and accessories (currently, on our Site we do not sell ebikes and accessories to be delivered to the EEA or UK). Our connected ebikes track ride metrics and location via a connected device within the connected ebike. Our App allows riders to create a user account, add their connected ebike to a virtual garage, and track and visualize metrics about their rides and connected ebike. Our App also allows riders to locate their connected ebike and enable or disable various features, described below and in our Terms of Service [https://serial1.com/pages/terms-conditions]


2. Personal Data We Collect
We collect information that identifies, describes, or relates to individuals (“Personal Data ”). We collect and use certain types of Personal Data for various reasons depending on how a User interacts with us or a Serial 1 connected ebike. The following describes the types of Personal Data we collect depending on a User’s interaction.
  1. Personal Data Collected from Visitors to our Site (“Visitors”)

We collect the following Personal Data from Visitors when they register for an account on our Site. The Personal Data that Visitors may provide to us is:
  • Contact Information. Name, telephone number, email address, address, and zip code.

  • Account Details. Username and password, as well as other information Visitors may provide to us related to their account.

  • Preferences.Information about the types of services used, a Visitor’s communications preferences, and other preferences a Visitor may select in their account.

We collect the following information from Users if they communicate with us via our Site:

  • Message Contents. This may include Personal Data depending on what the Visitor communicates to us.

  • Survey Responses. Responses to surveys we may post on our Site from time to time.

  • Personal Data Collected from Connected Ebike Users
When Users purchase a connected ebike we may receive the following Personal Data:

 

  • Warranty Information . Name, address, and connected ebike serial number. We receive this information from the retailer to track warranty time periods and enable Users to have their connected ebike repaired under warranty.

  • Personal Data Collected from App Users
We collect Personal Data from Users when they install our App, create an account on the App, and use our App in conjunction with a connected ebike. The Personal Data that App Users may provide to us directly, or may request we collect, is:
  • Account Details. In order to install and use the App, we collect App Users’ email address, username, password, connected ebike serial number, and the connected ebike’s device ID. If an App User uses a third-party service to create an account (e.g., Google or Apple) we will collect the App User’s email address from them to help create the account, unless the App User chooses to obfuscate the email address with Apple’s sign-on functionality. If an App User does not provide all this information, the App cannot be correctly installed and will not function as intended.

  • Virtual Garage. To activate the Virtual Garage feature, we collect the connected ebike’s precise location. If an App User does not provide this location, the Virtual Garage feature cannot function. We also collect the name and photo of each connected ebike registered in that garage, and the remaining distance that can be traveled with the motor assist.

  • Preferences. App Users may provide information about their metrics and App settings preferences.

  • Geolocation for Navigation. When an App User rides a connected ebike and the App User’s phone location features are enabled in the App in order to navigate, we collect geolocation data via GPS on the App User’s phone.

  • Geolocation for Pinpoint Mode and Where’s My Bike . We collect the connected ebike’s geolocation information from the GMS in the smart device embedded in the connected ebike. We collect this information to enable the App’s Pinpoint Mode and the Where’s My Bike feature.

  • Pinpoint Mode. In addition to the connected ebike’s location, when App Users elect to use Pinpoint features, we collect the connected ebike’s lock status, connection status and motor assist status (activated or deactivated).

  • Connected Ebike Performance Information and Ride History . We record information about an App User’s connected ebike and ride, such as the device ID, ride information (average speed, direction, duration, distance traveled, route, telemetry, battery performance and health, motor assistance, pedal data, elevation, timestamp), and firmware version.

  • Support Center. App Users can contact our support center by phone or email. We may collect a recording of App User calls for quality assurance and training purposes, and we will collect App User emails.

Privacy Mode: The App includes a Privacy Mode feature that allows Users to prevent the storage of any connected ebike data generated by the App, and prevent transmission of any connected ebike data from the ebike to the App. While Privacy Mode is enabled, however, the connected ebike’s device ID, GPS latitude and longitude information, firmware version, and other information about the connected ebike’s operation and performance will still periodically be sent to our smart device vendor to enable periodic firmware updates. Note that enabling Privacy Mode will negatively impact the use of the App, including Virtual Garage, navigation, ride history and Pinpoint Mode.

  • Personal Data Collected from Other Connected Ebike Users
  • Support Center.Users can contact our support center by phone or email. We may collect a recording of User calls for quality assurance and training purposes, and we will collect User emails.


3. Personal Data We Automatically Receive
  • Powering on the Connected ebike for the First Time
  • Each Serial 1 connected ebike has an embedded smart device that enables key ebike functions: lights, measurement of vehicle range, speed, battery health, pedal power, and usage metrics. The first time the connected ebike is powered on, our smart device vendor will collect various device and usage information, including device ID, GPS latitude and longitude information, firmware version, and other information about the connected ebike’s operation and performance. We do not obtain that information. After the initial firmware update, the connected ebike will automatically switch to Privacy Mode and not collect any further information or Personal Data: (1) until or unless a User downloads the App and registers the connected ebike to the User’s account on the App, (2) except for during automatic updates of the firmware running the device. During these automatic updates, the smart device vendor will automatically collect the device ID, GPS latitude and longitude information, firmware version, and other information about the connected ebike’s operation and performance.
  • Personal Data Automatically Collected about Riders of our Connected ebikes (“Riders”) – Smart Device in Privacy Mode (no App Installed)
  • As long as a connected ebike is not registered by installing the App, the ebike’s smart device will stay in Privacy Mode and not collect any information or Personal Data, except for automatic updates of the firmware running the device. During these automatic updates, the device manufacturer will automatically collect the device ID, GPS latitude and longitude information, firmware version, and other information about the connected ebike’s operation and performance.
  • Personal Data Automatically Collected about Riders of our Connected ebikes (“Riders”) – With App Installed
  • Each Serial 1 connected ebike has an embedded smart device that enables key ebike functions: lights, connected ebike geolocation, measurement of vehicle range, speed, battery health, pedal power, and usage metrics. Once the connected ebike is registered by installing the App, the device will automatically collect the following Personal Data:
    • Geolocation for Navigation. When the Rider’s phone location features are enabled in order to navigate, we collect geolocation data via GPS on the App User’sphone.

     

  • Personal Data Collected from Other Connected Ebike Users
  • If you borrow a connected ebike, the owner of the connected ebike will be able to view all information collected via the App (described above), including information about the location of the connected ebike, ride history, and ride status via the App.
  • Personal Data Automatically Collected about Visitors to our Site (“Visitors”)
  •  

    • Device Identifiers. We may automatically collect information from Site Visitors, such as IP address, unique device identif ier, IMEI and TCP/IP address, operating system, mobile device carrier information, and other information about their computer or device. We may also collect information about their browser type and browser language.

    • Network and Network Activity Information. We may collect information related to how Site Visitors interact with our Site and advertisements, such as referring and exit web pages and URLs, browsing history, and other similar information.

    • We also collect cookie information from Users who visit our Site, in accordance with our Cookie Policy, available here.


    4. Other Ways We Collect Personal Data
    We may collect Personal Data about purchasers and Users through our affiliates, business partners, retailers, and vendors who sell Serial 1 products. For example, we will receive a User’s Personal Data from our retailers (including the purchaser’s name, email address, connected ebike serial number, and any other information necessary) for the Serial 1 warranty. These parties may have their own privacy policies for handling Personal Data. Users should review their terms and conditions and privacy policies for more information

    5. Legal Bases and Purposes for Using Personal Data

    We use Personal Data collected via the Site, App, and connected ebike when we have a legal justification (“legal basis”) for doing so, and for the purposes described below.

     

  • Legal Bases
  • We process Personal Data based on one of the following legal bases: (1) our legitimate interests or those of a third party, provided these interests are not overridden by a User’s fundamental rights and freedoms (for example, to analyze the movement of visitors to our Site), (2) consent (for example, to send marketing emails ), or (3) necessity for performance of a contract or taking requested pre-contractual steps (for example, processing personal information to provide services under warranty).

     

     

  • Purposes for Processing Personal Data from the Site
  • We use Personal Data collected via the Site to:

     

    • Create and Manage User Accounts . We use Personal Data submitted by Visitors to create user accounts on our Site, to communicate with Visitors about their accounts, for technical support, and if a Visitor contacts us with a question or concern. We rely on performance of a contract as the legal basis for this processing.

     

  • Conduct Marketing and Advertising. We use Personal Data to send information regarding our products and services that we believe may be of interest to Users. This may include commercial emails sent on behalf of ourselves, our affiliates, and our advertisers. We rely on consent as the legal basis for this processing.
  •  

     

  • Purposes for Processing Personal Data from the App
  • We use Personal Data collected via the App to:

     

    • Create and Manage User Accounts . We use Personal Data submitted by App Users via the App to create user accounts, to communicate with App Users about their accounts, to provide technical support, and if an App User contacts us with a question or concern. We rely on performance of a contract as the legal basis for this processing.

    • Enable Ride Tracking Functionality . We use Personal Data to enable the App’s ride tracking functionality. This Personal Data includes information related to the time rode, distance traveled, level of motor assistance, the connected ebike’s telemetry, elevation change, geolocation, range, speed, battery, and pedal torque. We rely on performance of a contract as the legal basis for this processing. Using the App, App Users can elect not to save ride history.

    • Geolocation for Navigation. We use Personal Data to allow App Users to navigate using the App. The App’s navigation features are supported by Google Maps. When an App User rides a connected ebike and elects to activate turn-by-turn navigation with the App User’s phone location features enabled in the App, we collect geolocation data via GPS on the App User’s phone. We rely on performance of a contract as the legal basis for this processing.

    • Enable Pinpoint Mode. We use Personal Data to enable the App’s Pinpoint Mode functionality. When App Users elect to use Pinpoint features, we collect the App User’s mobile device location, connected ebike location (from the smart device embedded in the connected ebike), lock status, connection status, motor assist status (activated or deactivated), and whether the connected ebike was moved while powered off. We rely on performance of a contract as the legal basis for this processing.

    • Enable Virtual Garage. We use Personal Data to enable the App’s Virtual Garage feature. When App Users elect to activate the Virtual Garage, the Personal Data collected includes the connected ebike’s precise location. If a User does not provide this location, the Virtual Garage feature cannot function fully. We also collect the name and photo of each connected ebike registered in that garage, and the remaining distance that can be traveled with the motor assist . We rely on performance of a contract as the legal basis for this processing.

    • Evaluate and Improve our Products and Services. We use information we collect via the App (including App User devices’ unique identifiers, which are considered Personal Data) for product and service improvement, quality assurance, training, and to measure, improve, and understand the effectiveness of our App. We also use this information to develop new service offerings. We rely on our legitimate interests in improving our services in order to grow our revenue as the legal basis for this processing.

    • Create Inferences . We use information we collect via the App (including User devices’ unique identifiers, which are considered Personal Data) to create inferences about App Users, including riding style and habits. We use aggregated data created from these inferences to customize our App and provide a better User experience. We rely on our legitimate interests in improving our services in order to grow our revenue as the legal basis for this processing.

     

  • Purposes for Processing Personal Data from the Ebike
  • If a User chooses to link a connected ebike with the App (i.e., add a connected ebike to the App’s Virtual Garage) we use Personal Data collected from the connected ebike’s smart device to:

     

    • Enable Ride Tracking Functionality . We use Personal Data collected from the connected ebike to enable the App’s ride tracking functionality. This Personal Data includes the connected ebike’s telemetry, elevation change, geolocation, range, speed, battery status, and pedal torque. We rely on performance of a contract as the legal basis for this processing.

    • Enable Pinpoint Mode . We use Personal Data collected from the connected ebike to enable the App’s Pinpoint Mode. This Personal Data includes the connected ebike’s geolocation and whether it has been moved while the connected ebike was powered off. We rely on performance of a contract as the legal basis for this processing.

    • Where’s My Bike? We use Personal Data collected from the connected ebike to enable the “Where’s My Bike” feature in the App. This Personal Data includes the connected ebike’s geolocation. We rely on performance of a contract as the legal basis for this processing.

    • Evaluate and Improve our Products and Services. We use information we collect from the smart device in the connected ebike (including the device’s unique identifier, which is considered the Personal Data) for product and service improvement, quality assurance, training, and to measure, improve, and understand the effectiveness of our connected ebikes and our App. We also use this information to develop new product accessories, features, and service offerings. We rely on our legitimate interests in improving our products and services in order to grow our revenue as the legal basis for this processing.

    • Create Inferences . We aggregate the information we collect from the smart device in the connected ebike to create general inferences about Riders, including riding style and habits. We use these inferences to improve the function of the smart device and our connected ebike, and provide a better User experience. We rely on our legitimate interests in improving our products and services in order to grow our revenue as the legal basis for this processing.

    • Push Firmware Updates. Our smart device vendor uses Personal Data collected from the smart device in the connected ebike to confirm it has the latest firmware installed, and, if necessary, push newer firmware updates. We rely on performance of a contract as the legal basis for this processing if the Rider has linked a connected ebike with our App.

    If a User does not link a connected ebike with the App then the connected ebike will remain in Privacy Mode. We do not collect Personal Data when the connected ebike is in Privacy Mode. However, our smart device vendor collects the device ID, GPS latitude and longitude information, firmware version, and other information about the connected ebike’s operation and performance from the smart device embedded in the connected ebike to check whether the smart device has the latest firmware installed and, if not, push a firmware update to the smart device. We rely on legitimate interests in ensuring critical device safety and security updates are applied in a timely manner as the legal basis for this processing.

     

  • Other Purposes for Processing
  •  

    Additionally, we use Personal Data collected from the Site, App, and connected ebikes for the following general purposes:

     

  • Enable Security. We use Personal Data to mitigate fraud and protect Serial 1 and others. We rely on legitimate interests in conducting our business lawfully and ethically as the legal basis for this processing.
  • Comply with Legal Requirements . We use Personal Data to comply with lawful court orders, law enforcement requests, or other legal requirements, and may disclose Personal data where we believe in good faith that such disclosure is reasonably necessary to comply with legal obligations. We rely on legitimate interests in conducting our business lawfully and ethically as the legal basis for this processing.
  •  

    • Protection of Serial 1 and Others. We may use or disclose Personal Data to protect our rights and the rights of others. This may include exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes. We rely on legitimate interests in conducting our business lawfully and ethically as the legal basis for this processing.

    • Corporate Transactions. As we continue to develop our business, we may buy, merge, or partner with other companies. We may use or disclose Personal Data as part of those transactions (including in contemplation of such transactions, e.g., due diligence). Where possible we will do so under appropriate confidentiality agreements. We rely on legitimate interests in conducting our business and using our assets efficiently as the legal basis for this processing.


    6. How We Share Personal Data
    We disclose and/or share Personal Data collected via the Site, App, and connected ebike with our affiliates, business partners, and vendors as necessary under the following circumstances:
  • Personal Data from the Site
  • We disclose Personal Data collected from our Site with:
    • Vendors and Agents. We provide access to or share Personal Data with vendors who perform services to support our Site, including marketing, market research, customer support, data storage, analysis and processing, and legal services.

    • Our Business Partners. When Serial 1 partners with other businesses to offer products and services, we share Personal Data with those business partners. For example, we share Personal Data with retailers or component manufacturers for sale and warranty purposes.

     

  • Personal Data from the App
  • We disclose Personal Data collected from our App with:

     

    • Google Maps. When using our App, App Users may elect to use services provided by Google Maps. The use of these services may result in our sharing of certain Personal Data, including geolocation data, with Google. Google and its affiliated companies may use and retain this data to provide and improve Google products and services. The use of any Google Maps supported features within our services is not subject to this Notice, and is instead subject to the then-current versions of the: (1) Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html; and (2) Google Privacy Notice at https://www.google.com/policies/privacy/.

    • Vendors and Agents. We provide access to or share Personal Data with vendors who perform services to support our App, including research and development, marketing, market research, customer support, data storage, analysis and processing, and legal services.

     

  • Personal Data from the Ebike
  • Personal Data collected from the smart devices in the connected ebikes is transmitted to the smart device vendor, and transmitted to us except when the smart device is in Privacy Mode. We disclose Personal Data collected from connected ebikes with:

     

    • Vendors and Agents. We provide access to or share Personal Data with vendors who perform services to support our connected ebike functionality, including enabling connected device capabilities, firmware updates, research and development, data storage, analysis and processing, and legal services.


    7. International Transfers of Personal Data

    Serial 1 is based in the United States, and generally User Personal Data is transferred to, and stored in, the United States, which may not provide the same level of data protection as your home country. Personal Data from the smart device in the connected ebike and from App is stored in the EU, but Personal Data extracted to evaluate and improve our products and services will be transferred and stored in the US. We take steps to ensure Personal Data exported from the EEA or UK receives the same level of protection as it enjoys under the laws of the originating country. Transfers of Personal Data may be either (1) directly from a User to Serial 1 and thus necessary to perform the Terms or provide connected ebike functionality, or (2) from our smart device vendor located in the EU, which is subject to approved standard contractual clauses.


    8. Cookie Policy
    Our Site uses cookies, tags, and similar tracking technologies (“Cookies”) to provide, customize, evaluate, and improve our services. A Cookie is a small piece of text that is placed on a User’s website browser when they visit a website. These include our own first-party Cookies as well as third-party Cookies of our service providers and marketing partners (if any). They are used to “remember” when your computer or device accesses this Site. Cookies are stored in your browser. A cookie will help the Site, or another website, to recognize your device the next time you visit. Most cookies won’t collect information that directly identifies you as a person, and will instead collect more general information such as how visitors arrive at and use our Site. Other cookies collect personal data. Cookies may be used to create a profile of a visitor's activities on the Internet which can be used (for example) to try to predict the visitor’s purchasing and behavioral preferences. You can read our Cookie Policy here.

    9. Information Regarding Persons Under 18
    Our connected ebike is not intended for sale or use by persons under 18. We do not intentionally collect Personal Data from any person under 18 years of age.

    10. Retention of 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. We use the following criteria to determine our retention periods:

    • The length of time we have an ongoing relationship with a User and provide services via the App or Site (such as, for as long as an App User maintains an account with us);

    • Whether there is a legal obligation to which we are subject (certain laws require us to keep records of our transactions with customers for a certain period of time before we can delete them);

    • Whether retention is advisable in light of relevant statutes of limitation (the period of time during which we may raise a legal claim, or a claim can be made against us), or our legal position (for example, if we are involved in litigation to which the Personal Data is relevant).


    11. Privacy Rights

    As a resident of the EEA or UK Users have certain privacy rights regarding their Personal Data. These rights are as follows:

    1. Right of Access . Users have the right obtain from Serial 1 confirmation as to whether we are processing their Personal Data, and to be provided access to that Personal Data as well as information about how we process User Personal Data.

    2. Right of Rectification . Users have the right to request we correct inaccurate Personal Data concerning them, or complete incomplete Personal Data including by means of providing a supplementary statement.

    3. Right to Erasure . Subject to certain exceptions, such as when we need the Personal Data to exercise or defend a legal claim, Users have the right to request we delete Personal Data concerning them. Users have a right to erasure where one of the following grounds applies:

      1. the User’s Personal Data are no longer needed for the purposes for which they were collected;

      2. the User withdraws consent and Serial 1 does not have an alternative legal basis for the processing;

      3. the User objects to processing that is based on legitimate interests and there are no overriding legitimate grounds upon which we can base the processing;

      4. the User’s Personal Data have been processed unlawfully; or

      5. the User’s Personal Data must be erased for compliance with a legal obligation under EEA or Member State law.

    4. Right to Restrict Processing. Users have the right to request we restrict our processing of their Personal Data under one of the following conditions:

      1. the User contests the accuracy of their Personal Data, for a period of time that allows Serial 1 to verify accuracy;

      2. the processing of the User’s Personal Data is unlawful but the User does not want Serial 1 to erase their Personal Data;

      3. Serial 1 no longer needs the User’s Personal Data, but Serial 1 is required by the User to maintain their Personal Data for the establishment, exercise, or defense of legal claims; or

      4. The User has exercised their right to object to Serial 1’s processing, for a period of time that allows Serial 1 to verify whether it has any overriding legitimate grounds.

    5. Right to Portability . Users have the right to obtain a copy of their Personal Data in a structured, commonly used, and machine-readable format, and to have this Personal Data transmitted to another controller where technically feasible, under the following conditions:

      1. Serial 1’s processing is based on the legal bases of consent or necessity for performance of a contract; and

      2. Serial 1’s processing is carried out by automated means.

    6. Right to Object . Users have the right to object to our processing of their Personal Data on grounds relating to their particular situation, when our processing is based on legitimate interests as a legal basis. Unless we can demonstrate compelling and overriding legitimate grounds to continue to process the User’s Personal Data, we will cease our processing.

    How to Exercise Privacy RightsTo submit a request to exercise these rights Users may send a request to support@serial1.com. For all requests, Users must clearly state that the request is related to “European Privacy Rights,” indicate which type of request they are making, and provide a name and email address or phone number where they may be contacted. We may not be able to respond to requests that are not properly communicated, or that do not include complete information.

    12. External Links
    Our Site and App may contain links to other websites that we don’t own or control. We are not responsible for the content or any other aspect of these third-party sites, including their collection of Personal Data. Users should review the terms and conditions and privacy policies of third-party sites before providing Personal Data to that site.

    13. Updates to This Privacy Notice

    This Privacy Notice is reviewed and updated regularly. If we change this Notice, we will post the updated Privacy Notice here, and those changes will go into effect on the “last updated” date shown above. If we make a change to this Notice that materially impacts how we handle Personal Data we will notify you of this material change prior to making it effective.


    14. Contact Us

    Users can also write to us at
    Serial 1 Cycle Company, LLC.
    3451 North Triumph Blvd.
    Suite #100 Lehi, UT 84043
    United States