Privacy policy

 

Understand how we collect, use, disclose, transfer, and store your information

 

Effective Date November 11, 2018

 

At Superpedestrian, we take your privacy seriously.

 

This Privacy Policy describes information that Superpedestrian, Inc. (“Superpedestrian”, “we”, “our”) collects, uses, shares and stores, including Personal Information (i.e., information that personally identifies you, such as your name, email address, physical address, phone number, or other data that can be reasonably used to infer your identity).

 

This document focuses on information from individuals (“you” or “your”) who visit Superpedestrian web site at superpedestrian.com and superpedestrian.com sub-domains (each, a “Site”), including our online store, who purchase and use Superpedestrian products and services (collectively, “Products”), including the Copenhagen Wheel (“Copenhagen Wheel” or “Wheel”) and any related mobile application (“App”).

 

This Privacy Policy may change from time to time, so please check back periodically to check the most recent modification date to ensure that you are aware of any changes in our processing of your Personal Information. Your continued use of the Site or Products after any changes signifies your express, explicit, voluntary and unambiguous consent to any such changes.   If you do not agree to such changes, your choice is not to use our Site or Products.

 

Your Consent

By using the Site, and/or purchasing or using our Products, you agree to allow us to collect and process your Personal Information, including international transfer, in accordance with the terms of this Privacy Policy.  You also consent to receiving direct marketing emails from Superpedestrian and understand that you may opt out by clicking “unsubscribe” on the emails you receive from us.  We also will send you “push” notifications in the App regarding your use of the Products.  If we send direct marketing messages in these “push” notifications, we will provide a mechanism to opt out of receiving such marketing messages via the App.  You agree that your consent is voluntary, explicit and unambiguous and is free and informed.

 

 

EU-US and Swiss-US Privacy Shield Frameworks

This Privacy Policy and Superpedestrian comply with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework, and associated Privacy Shield Principles (the “Principles”), as set forth by the U.S. Department of Commerce regarding the collection, use, disclosure, onward transfer and retention of Personal Information from the European Union and Switzerland, respectively. Superpedestrian has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn from about the Privacy Shield Program, and to view our certification, please visits https://www.privacyshield.gov.  

 

By adhering to the Privacy Shield Principles, Superpedestrian agrees to be subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

 

As a Privacy Shield Organization, Superpedestrian is responsible for the processing of Personal Information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.  Superpedestrian shall remain liable under the Principles if its agent processes such Personal Information in a manner inconsistent with the Privacy Shield Principles, unless Superpedestrian proves that it is not responsible for the event giving rise to the damage.

 

 

Information collected when visiting the Site

We collect information about you through our Site in several ways. This information is used to provide you and other customers with Superpedestrian Products, to allow us to understand how visitors navigate our Site, and to provide information and advertising that is relevant to your interests. The Site collects:

  • Purchase and Account Information

  • Mailing List Information

  • Application Information

  • Cookies and Tracking

  • Third Party Sites

  • Social Media Information

 

Purchase and Account Information

When pre-ordering or purchasing a Superpedestrian Product we record the necessary information to complete the purchase and delivery of the Product to you. This includes name, email address, billing and shipping addresses, phone number and payment information. We use third-party payment processing partners to collect, process and maintain payment information and information about your purchase, including any relevant credit card information.  When you place an order, you are immediately directed to our third-party payment processor, which collects your Personal Information and billing information in order to process your transaction. Our third-party payment processor and other third-party sites have separate and independent privacy policies.

 

We store your email address and name as you use this information to sign into your account. We also use this to send you important security information and product related updates. Your name is also associated with your profile and is visible when you submit comments or any other materials on our app or website.

 

Mailing List Information

When you contact us by email, sign up for our marketing communication, purchase a product, register for an account, or contact us through our support site, we collect your name, country and email address in order to respond to you. If you participate in an optional survey, we will collect the information requested by the survey in order to process survey results.  You can opt out of these emails by clicking “unsubscribe” on the emails you receive from us or by going to your Account Settings on our Site.

 

If you provide your opt-in consent to receiving marketing information from Superpedestrian, Superpedestrian will also process your email address for the purpose of sending you marketing information about Superpedestrian’s products and apps. The marketing emails you receive from Superpedestrian would be based on preferences you provide on your Superpedestrian account, these include opt ins to our newsletter, blog updates and product related promotions.

 

Application Information

 

Registering to Try the Wheel:

 

We offer trials/demonstrations of the Copenhagen Wheel and other Products in certain locations or at certain events. On the Site, there may be opportunities to sign up to try the Wheel or register for an event. For certain trials/demonstrations/marketing events we may use a third-party service to handle the reservations. In this case, when you sign up to try the Wheel or other Products, you may  be directed to the website of the third-party service, such as EventBrite, which will collect information to enable you to make a reservation, including certain Personal Information. Third party providers are contractually obligated to protect your Personal Information which is ensured by Superpedestrian, however this privacy policy only covers the data Superpedestrian stores through these third party avenues and not the collection. This is covered by their own Privacy Policies.

 

Applying to work with us:

 

When you apply for a job through the Site, we collect your first and last name, email address, postal address, resume, cover letter and the information you provide on your resume, cover letter, or in the job application.  We use this information to assess your qualifications for open positions and to contact you if we wish to discuss an opportunity with you. We retain your information even after the position has been filled.

 

Applying to be a Preferred Service Provider:

 

If you submit an application to become a Preferred Service Provider, we collect your first and last name, email address, phone number, title, company information, company address and other information related to reviewing your company and processing the application.

 

We use this information to determine whether to pursue a business relationship with you and to contact you for further information. If your application is accepted, we add your information to our partner database and may expose some of this information publicly on our website for our customers to find you.

 

Cookies and Tracking:

 

As with many websites, we and our third-party partners data collected through cookies, web beacons, and other tracking technology, to compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences and tools in the future. Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) and that enables the websites or service provider systems to recognize your browser and capture and remember certain information. We use this information to recognize you when you return to the Site to provide a better experience, to avoid having you enter information more than once, to better understand how you use our Site and Products, to diagnose and fix technology problems, and to otherwise enhance the Site and Products. Examples of information collected, include browser type, device type, IP address, domains, page views, referring/exit pages, information about how you interact with our Site’s pages and with third-party links, traffic and usage trends on the service, etc.

 

Most browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. Note that depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device. Please note that cookies are essential for our Site to function as per any e-commerce service, so disabling them may turn off some functionality of our Site.

 

If you reside in the EU or other jurisdiction that requires us to obtain your consent to use cookies on our Site, we will provide an opportunity to manage your cookie preferences on our Site. You can also manage your preferences by going to your Account Settings.

 

In some email messages, we use a “click-through URL” linked to content on our Site. We track this click-through data to help us measure the effectiveness of our customer communications. We also use third-party tools or services, such as Google Analytics, to assist us with analyzing and improving our Site. These service providers may also employ cookies but are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

 

Third Party Sites:

 

Our Site may contain links to other websites that are independent, are not owned or operated by us, are not covered by this Privacy Policy and which may incorporate third party information.  If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We therefore have no responsibility or liability for the content and activities of other websites to which you provide Personal Information, even if they are linked to our Site.

 

Social Media Information:

 

Our Site includes features from third-party social media websites such as Facebook, Twitter, YouTube, Google+ and LinkedIn that run on our Site.  Please note that our Site is not sponsored or endorsed by any of these social media sites, which are trademarked and owned by third parties and not by us.  These features may collect your information, including certain Personal Information, IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third-party or hosted directly on our Site. This Privacy Policy applies to the data we store on our own databases from these services and not on these social media servers.  Your interactions with these features, including their collection of your Personal Information, would be governed by the privacy policy and other policies of the companies providing them.

 

We also give our users the ability to create an account with us using Facebook and Google. If you choose to do this, the first time you do so you will be asked whether you agree that the Social Media provider may provide certain Personal Information to Superpedestrian, such as your name, email address with your social media account. This information is made available to Superpedestrian by the social media provider due to the way their sign-on configuration functions. However, the only Personal Information Superpedestrian retains and processes is your name and email address. If you do not want your Personal Information to be shared with Superpedestrian through the Social Media provider, you can use your email ID and name to create an account directly with Superpedestrian as described below.

 

 

Information collected by the Copenhagen Wheel and App

The Copenhagen Wheel and App collect:

  • Setup and Account Information

  • Ride Information

  • Wheel Diagnostic Information

  • Bug Reporting and Feedback 

  • Additional Information

 

Setup Information

When you sign up for a Superpedestrian account on the Site or within the App, we collect your email address and password in order to set up and manage your account and communicate with you by email. We require that you have a Superpedestrian account to use our Products. When adding a Superpedestrian Product to your account, you will be asked to validate your email address, physical address, name and phone number so that we may contact you in the event of a safety issue or recall. Other information, such as bicycle model, preferred service location, etc. may be requested as well to customize your experience with the Product.

 

Ride information

The App is required to use the Copenhagen Wheel. When using the two together we collect information from a variety of sensors both inside the Wheel, inside the phone, and potentially other connected sensors. Information collected includes, but is not limited to, phone model, operating system, user torque, motor torque, geolocation, speed, elevation, slope, temperatures, and accelerations. Please note that you can change your phone’s location preferences which would allow or prevent us from gathering any location based data on you. This information is transmitted over cellular or other wireless networks and is backed up on our cloud based servers to give you details regarding your trips.

 

By recording this information, the Wheel can respond to your actions and provide a unique riding experience. Additionally, the App can display information relevant to you and your behaviors. After your ride, the App can also display a summary of your experience to you.

 

Wheel Diagnostic Information

When riding, Superpedestrian also records non-identifiable diagnostic information about the Wheel and the Wheel’s sensors. This information includes, but is not limited to, defined faults and hazards, temperatures, battery voltages, and sensor data. This information is also transmitted from the Wheel to the App and then to our cloud-hosted servers. We use this information to diagnose issues, verify warranty claims, and aggregate service information.

 

Bug Reporting and Feedback

If you’re a Product/App owner and choose to send us an error report with details regarding a fault that you experienced or bug that you encountered in the App, that bug report in itself sends us your email and location along with other diagnostic information regarding the App and our firmware. You will be provided an opt-in to participate in this process  and Superpedestrian only receives information already registered with your account.

 

Superpedestrian also has a beta-test program that includes some current Product users. This program is an application-based process. We collect certain Personal information from participants, such as your name, email, location, phone and bike information along with demographic information, e.g. age and gender, to understand our product usage and user behavior better so that we can develop new products and improve our existing products. Participation in the beta program is voluntary.

 

Additional Information 

We use third-party services within the App that collect certain information. For instance, the mapping services we use may collect anonymous location telemetry. This Privacy Policy does not cover third party services used within the App, but we will make best efforts to notify you of additional information that may be collected by a third party when using the App.

 

 

Children’s Privacy

Our Site is geared towards users who are at least the age of majority in their jurisdiction of residence. We do not knowingly collect Personal Information from children under the age of 13 in the United States or under the age of 16 in the EU.  If your child provided Personal Information to the Site, please contact us using the information provided below.

 

 

Aggregated Data

In an ongoing effort to better understand and serve current and prospective customers, we often conduct research on our customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents, and business partners. This aggregate information does not identify you personally. We may also disclose aggregated use statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

 

 

Security

When you place an order, your information is transmitted via Secure Socket Layer (SSL) technology and encrypted into our payment provider’s database only to be accessible by those authorized with special access rights to such systems, and are subject to strict requirements to keep the information confidential. After a transaction, your payment card information will not be stored on our servers.

 

We will take reasonable and appropriate precautions to protect all Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have a security related concern, please contact privacy@superpedestrian.com

 

 

Choice and Consent

It is always your choice whether or not to provide us with Personal Information and other information that we collect.  If you do provide Personal Information to the Site, you are giving your express and unambiguous consent to the collection and processing of your Personal Information as described in this Privacy Policy.  If you choose not to provide the requested information you may not be able to access certain features on our Site, or App, place orders, or request information. You may access, change, modify or delete your information as described below.

 

We do not disclose your Personal Information to third parties for direct marketing purposes.  Superpedestrian will use Personal Information only in ways that are consistent with the purposes for which it was collected or subsequently authorized by you and we will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete and current.   You may also opt out in the event we use your Personal Information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.

 

You may revoke your consent, and/or object to or block processing of your Personal Information by emailing a request to us at privacy@superpedestrian.com.  We will respond to your request in accordance with the law that applies to you. Your Personal Information which we processed prior to your request may not be deleted from our Site or App system records but will be blocked from further processing without your permission.

 

 

Onward Transfer/Disclosure of Data

We do not disclose your Personal Information to any third party for any commercial or marketing purpose unrelated to the operation of our website, conducting our business, or servicing you. If we transfer Personal Information onward to third-parties who are acting as our agent or service provider, they are contractually obligated to maintain the confidentiality of your Personal Information consistent with the terms of this Privacy Policy and provide at least the same level of protection as required by the Privacy Shield Principles, as well as comply with applicable data protection laws.

 

We will notify you by email, in accordance with local laws, as well as any choices you may have regarding your Personal Information, if the following occurs:

  • Valid legal requests: We will disclose your information in response to valid legal process, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements.  We also may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. Superpedestrian is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  • Acquisition or merger: In addition, we may transfer your information to an entity or individual that acquires, buys, or merges with Superpedestrian, or our other business units.

 

 

International or Cross-Border Transfer of Your Personal Information and Your Express Agreement

Given that the Internet operates in a global environment and that transfer of your data is necessary to provide you with requested services, process orders, provide updates, and respond to your inquiries, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international, or cross-border, basis.  By providing Personal Information and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information in this way.  The Personal Information of users who are located outside the U.S. may be transferred outside of each eligible country to the U.S., where our servers are located and where it will be processed and stored on servers in the U.S.   We also store information in the cloud, as described in this Privacy Policy.   Although the Privacy Shield Principles have been recognized as adequate, the U.S. and other locations where information may be stored in the cloud, have not been recognized as providing an adequate level of protection according to EU and Swiss data protection requirements, but we will take all steps reasonably necessary to ensure that users’ Personal Information is treated securely in respect of such transfer and as described in this Privacy Policy and in accordance with the Principles.  By accessing the Site and/or App, providing Personal Information or sending us email, you expressly and unambiguously agree to such transfer, processing, storage and disclosure in the U.S.

 

 

Your California Privacy Rights; California Do Not Track Disclosures

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to privacy@superpedestrian.com. Please note that we do not disclose Personal Information to third parties for direct marketing purposes. In addition, we currently do not honor Do Not Track signals.

 

 

Accessing Your Information

 

For Non-EU and Non-Swiss Users

You may at any time review or change your Personal Information by contacting us in writing at: privacy@superpedestrian.com. If requested, your Personal Information will be corrected, deactivated or deleted as soon as practicable and in accordance with applicable law.

 

For EU-Users and Swiss-Users

Users and Swiss Users may access their Personal Information that we hold in order to correct, amend or delete information that is inaccurate or has been processed in violation of the Privacy Shield Principles. We may charge a fee to provide this information. A user may submit an access request in writing to: privacy@superpedestrian.com.

 

Your Rights 

 

Review and editing your information 

A user may submit an inquiry requesting access to his/her Personal Information in writing to: privacy@superpedestrian.com. Any change or update request will be handled by Superpedestrian manually.

 

Retention and Deletion of your information 

Superpedestrian retains your information while your account remains active or, until you ask us to delete your information or your account. Unless we are otherwise required to by any applicable law, Superpedestrian deletes or anonymizes all user Personal Information upon the user’s request.

 

Please note that deleting your Personal information will result in our product being rendered useless. As described above, we use your Personal Information to authenticate your access to the App and operational information without which your Product will not function.

 

If you still wish for us to delete all your Personal Information kindly email us privacy@superpedestrian.com and communicate the same.

 

 

Dispute Resolution for Complaints

In compliance with the Privacy Shield Principles, Superpedestrian commits to resolving complaints about your privacy and our collection, use or onward transfer of your Personal Information. Users with a complaint about our Privacy Policy should first contact Superpedestrian at privacy@superpedestrian.com for resolution.

 

Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Superpedestrian, Inc.’s internal processes, Superpedestrian, Inc. has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here:  https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

 

 

Contact Us

If there are any questions or complaints regarding this Privacy Policy, or if you wish to access your Personal Information, you may contact us using the information below:

Superpedestrian, Inc.

84 Hamilton St.

Cambridge, Massachusetts 02139 USA

privacy@superpedestrian.com

 

 

Terms of Service

Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website at superpedestrian.com/legal/website-terms-of-use