Understand how we collect, use, disclose, transfer, and store your information
Effective Date May 25, 2018
At Superpedestrian, we take your privacy seriously.
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”).
EU-US and Swiss-US Privacy Shield Frameworks
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
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.
Registering to Try the Wheel:
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.
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:
Social Media Information:
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
Wheel Diagnostic Information
Bug Reporting and Feedback
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.
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.
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.
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.
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 firstname.lastname@example.org
Choice and Consent
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 email@example.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 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
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 firstname.lastname@example.org. 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: email@example.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: firstname.lastname@example.org.
Review and editing your information
A user may submit an inquiry requesting access to his/her Personal Information in writing to: email@example.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 firstname.lastname@example.org and communicate the same.
Dispute Resolution for Complaints
Superpedestrian has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent recourse mechanism. If EU Users or Swiss Users do not receive a response to a complaint within 45 days, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
When these other dispute resolution mechanisms are exhausted, EU Users and Swiss Users may seek redress from the Privacy Shield Panel, a binding arbitration mechanism, available under EU-US and Swiss-US Privacy Shield Frameworks (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint).
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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