Datenschutzerklärung

Privacy Notice for EEA and UK

Effective Date: May 17, 2023

Date Last Updated: May 17, 2023

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 (“Website”), use our mobile application (“App”), and/or our connected ebikes (“connected ebikes”) (collectively, “Users”).

Before submitting any Personal Data to our website, App, or using a connected ebike, Users should carefully review this Notice. By checking the box provided in our App or on our Website, 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 within the EEA and UK. Users located in the U.S. should review our U.S. Privacy Notice above.


Contents

  1. About Serial 1 2
  2. Personal Data We Collect 2
  3. Personal Data We Automatically Receive 4
  4. Other Ways We Collect Personal Data 5
  5. Legal Bases and Purposes for Using Personal Data 5
  6. How We Share Personal Data 9
  7. International Transfers of Personal Data 10
  8. Cookie Policy 10
  9. Information Regarding Persons Under 18 11
  10. Retention of Personal Data 11
  11. Privacy Rights 11
  12. External Links 13
  13. Updates to This Privacy Notice 13
  14. Contact Us 13

  • 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 websites that collect data about visitors to our sites, and purchasers of our connected ebikes and accessories. Our connected ebikes allow Users to 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 Users to locate their connected ebike and enable or disable various theft notification features.


  • 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. 


  • Visitors to our Website
    •


    We collect the following Personal Data from Users when they register for an account on our Website. The Personal Data that Website Users 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 Users may provide to us related to their account. 
    • Preferences. Information about the types of services used, a User’s communications preferences, and other preferences a User may select in their account.


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


    • Message Contents. This may include Personal Data depending on what the User communicates to us.
    • Survey Responses. Responses to surveys we may post on our Website from time to time.



  • 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.
    • Connected ebike Device ID. If a User does not connect their connected ebike to the App, or enables Privacy Mode, we (or our vendors) collect only the device ID from the connected ebike to allow us to push firmware updates as needed.



  • 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 you use a third-party service to create an account (e.g., Google or Apple) we will receive your email address (unless you choose to obfuscate your email with Apple’s sign-on functionality)from them to help create your account. If a 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 a 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. Information about a User’s metrics and App settings preferences.
    • Geolocation for Navigation. When a User rides a connected ebike with the User’s phone location features enabled in the App in order to navigate, we collect geolocation data via GPS on the User’s phone and via Bluetooth from the GMS in the smart device embedded in the connected ebike. We also collect information about the time rode, distance traveled, speed, level of motor assistance, and battery life.
    • Connected Ebike Performance Information. We record information about a User’s connected ebike and ride, such as the device ID, ride information (average speed, direction, duration, route, telemetry, battery performance and health, pedal data, elevation, timestamp), and firmware version.
    • Pinpoint Mode. When Users elect to use Pinpoint features, we collect connected ebike location, lock status, connection status and motor assist status (activated or deactivated). 
    • 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 will collect 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, location, and telemetry will periodically be sent to our device vendor to enable periodic firmware updates. Our device vendor immediately deletes this data following the update.


    Note that enabling Privacy Mode will negatively impact the use of the App, including Virtual Garage, navigation, ride history and Pinpoint Mode.


  • 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 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, we 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. After an initial firmware update, the connected ebike will automatically switch to Privacy Mode and not collect any information or Personal Data until or unless a User downloads the App and registers the connected ebike to the User’s account on the App.



  • Personal Data Automatically Collected about Riders of our Connected ebikes (“Riders”) – Smart Device in Privacy Mode (no App Installed)
    •



    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. Until the connected ebike is registered by installing the App, the 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; this information will be immediately deleted upon completion of the update. 


  • 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, 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 a User rides a connected ebike with the User’s phone location features enabled in order to navigate, we collect geolocation data via GPS on the User’s phone and via Bluetooth from the GMS in the smart device embedded in the connected ebike. We also collect information about the time rode, distance traveled, speed, level of motor assistance, and battery life.


    1. Personal Data Automatically Collected about Visitors to our Website (“Visitors”)



    • Device Identifiers. We may automatically collect information from Website Visitors, such as IP address, unique device identifier, 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 Website Visitors 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 our Cookie Policy, we may use analytics providers and technologies, including cookies and similar tools, to collect this information.
    • We also collect cookie information from Users who visit our Website, in accordance with our Cookie Policy, available here.



  • 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



  • Legal Bases and Purposes for Using Personal Data


    • We use Personal Data collected via the Website, 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 ), (3) necessity for performance of a contract or taking requested pre-contractual steps (for example, processing personal information to provide services under warranty), or (4) on necessity for compliance with an EEA or UK legal obligation.


  • Purposes for Processing Personal Data from the Website
    •

    We use Personal Data collected via the Website to:


    1. Create and Manage User Accounts. We use Personal Data submitted by Users to create user accounts on our Website, to communicate with Users about their accounts, for technical support, and if a User contacts us with a question or concern. We rely on performance of a contract as the legal basis for this processing.
      • Operate our Business and Provide our Services. We use Personal Data to enable the services we provide through our Website to run our day-to-day operations. We rely on our legitimate interests in promoting our services in order to grow our business 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 Users via the App to create user accounts, to communicate with Users about their accounts, for technical support, and if a 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. When Users connect the App to a connected ebike, the connected ebike sends Personal Data to the App which sends the data to us. We use Personal Data to enable the App’s ride tracking functionality. This Personal Data includes information related to 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.
    • Geolocation for Navigation. We use Personal Data to allow Users to navigate using the App. When a User rides a connected ebike with the User’s phone location features enabled in the App, we collect geolocation data via GPS on the User’s phone and via Bluetooth from the GMS in the smart device embedded in the connected ebike. We also collect information about the time rode, distance traveled, speed, level of motor assistance, and battery life, as well as other ebike performance metrics. 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 Users elect to use Pinpoint features, we collect the User’s mobile device location, connected ebike location, 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. This Personal Data 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 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 Users, including riding style and habits. We use 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.
    • Evaluate and Improve our Products and Services. We use information we collect from the smart device in the connected ebike (including the devices’ unique identifiers, which are considered the 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 product accessories, features, and 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 from the smart device in the connected ebike (including the devices’ unique identifiers, which are considered Personal Data) to create inferences about Users, including riding style and habits. We use these inferences to improve the function of the smart device 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. 
    • Push Firmware Updates. We use 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 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 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. The device ID is immediately deleted once the firmware update is complete. 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 Website, 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. 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 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 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.


  • How We Share Personal Data

    •


    We disclose and/or share Personal Data collected via the Website, App, and connected ebike with our affiliates, business partners, and vendors as necessary under the following circumstances:


  • Personal Data from the Website
    •

    We disclose Personal Data collected from our Website with:


    • Vendors and Agents. We provide access to or share Personal Data with vendors who perform services to support our Website, 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 Users use our Services, and in particular the Services provided through our mobile application, Users are electing 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 manufacturer, Comodule, and except where immediately deleted, transmitted to us. 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.



  • 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 device provider, which is subject to approved standard contractual clauses. If a new EU-US data transfer agreement receives approval, we may certify our compliance with such a transfer mechanism.


  • Cookie Policy

    •


    Our Website 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.


  • 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. 


  • 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 Website (e.g., for as long as a User maintains an account with us);
    • Whether there is a legal obligation to which we are subject (e.g., 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 our legal position (e.g., if we are involved in litigation to which the Personal Data is relevant).

  • 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 Rights

    To 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.

  • External Links


    • Our Website 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.

  • 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.

  • Contact Us

    •

    Questions about our Notice should be emailed to us at support@serial1.com. Users can also write to us at 


    Serial 1 Cycle Company, LLC

    3451 North Triumph Blvd.

    Suite 100

    Lehi, UT 84043

    United States