Privacy Policy

Updated: 26th June 2023

1 Introduction

1.1 Important information and who we are

Welcome to Buzz Bikes Limited’s Privacy and Data Protection Policy (“Privacy Policy”).

At Buzz Bikes Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”).

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

Customers
Visitors to our website

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Who is your data controller

Buzz Bikes Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should be sent to us on email at hello@buzzbike.cc

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data Breach;

2 Legal basis for data collection

2.1 Types of Data / Privacy Policy Scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth. We may also require photographic identification and a proof of address.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone number
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
Transactional Data: This is information of details and records of all payments you have made for our services or products.
Location Data: This is data relating to the location of our Bicycles and E-bicyles.

We also collect, use and share Aggregated Data such as number of leavers to calculate churn. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3 How we use your personal data

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed below.

Examples provided below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

You visit our public website

Type of data: Technical, Usage

Legal Justification: Legitimate Interest

We need to understand where you are logging in from so we know whether you can use our services. We also collect browser date to help diagnose service provision issues and analyse how customers use our services
To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy

When a customer signs up to use our services

Type of data: Contact Data, Billing Data, Identity Data

Legal Justification: Consent, Contractual Obligations, Legitimate Interest

You consent to provide us with your profile data when you create an account
We need to know your contact data so we can enter into a contract with you to use our services
We also need to determine that someone signing up for services is who they say they are. This is a contractual obligation and helps to prevent fraud.
We need to process this data so that we know who and where to charge for the service you have purchased from us. We will retain the name that is stated on the credit/debit card you enter into our Stripe API but all other card details are stored by them and not retained by us.

When a customer pays to use our services

Type of data: Financial, Transaction, Profile

Legal Justification: Consent, Contractual obligation, Legitimate interest

You consent to provide us with your profile data when you create an account. We will retain the name that is stated on the credit/debit card you enter into our Stripe API but all other card details are stored by them and not retained by us.
We need to retain your Transactional Data so that we can comply with our legal obligation to send you a record of your subscription payment
We retain your transaction records to ensure you have met your contractual obligation to pay to use our services.

Providing customer support to you

Type of data: Identity, Transaction, Profile, Usage

Legal Justification: Consent, Contractual obligation, Legitimate interest

We may need your telephone number or other contact details to provide customer support and other services as defined in our contract with you (e.g. on demand maintenance)
We will retain records of the transactions you have made with us and what you have used on the Platform so when you come to us with an issue we can quickly identify what your issue relates to and provide you with the most efficient support

When a customer uses our mobile app

Type of data: Usage Data, Location Data

Legal Justification: Legitimate Interest

Collection of GPS data is required to provide you with your riding stats and usage data.
Where access to this data must be explicitly granted by the user then Buzzbike will integrate with whatever permission management tools are available on the underlying platform, as well as any platform-specific policies

When a customer opts- in to marketing communications

Type of data: Marketing and Communications Data

Legal Justification: Explicit Consent

We need to process this data to give you information about our services. You can opt out of these communications at any time

When you use our live chat support

Type of data: Contact Data

Legal Justification: Consent

We ask you for your email so we can easily get back in touch with you and connect the conversation history to an individual or to your account if you are a registered rider

When a Bicycle or E-bicycle is stolen or there has been a break of our Terms of Use

Type of data: Location data

Legal Justification: Contractual obligation, Legitimate interest

Should you bike get stolen we may use the bike’s GPS to try and locate the bike and recover it. Equally, if your account falls significantly in arrears such that you breach our terms of use and you are unresponsive, we may use the bike’s GPS to try and locate and recover the bike.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4 Your rights and how you are protected by us

4.1 What Control Do I Have Over Buzz Bikes Limited’s Use Of My Personal Data?

If you are no longer using our Services, you may request to have your account delete your account at any time – this will remove your account page from our systems and our related software.

We do not guarantee the ability to delete all stored data. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

You can access information associated with your account by logging into your account you created with us.

4.2 How Does Buzz Bikes Limited Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including We implement certain security measures to ensure the security of your Personal Data on our systems, including adopting a secure protocol and encrypting our databases. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Buzz Bikes Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by You can opt out of receiving marketing communications by clicking "Unsubscribe" at the bottom of any marketing communications you receive from us.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

5 Your data and third parties

5.1 Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).

We may share your personal data to enforce our Terms of Use. For example, we may share your data with a 3rd Party Debt Collection agency to collect overdue subscription payments in such cases where you have become non- responsive to our attempts to contact you. We also work with our payment provider Stripe to check your details against Identification and address documents you provide.

We may share Personal Data with interested parties in the event that Buzz Bikes Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Buzz Bikes Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

We currently share personal data with the following parties:

- Legal Recoveries & Collections Ltd for debt collection purposes - see Legal Recoveries & Collections Ltd’s Privacy Policy here. We also use Direct Collection Bailiffs Ltd - their Privacy Policy can be found here

- Rakuten advertising for marketing purposes, uses third-party cookies

- Experian - for credit checking and fraud purposes - see Experian’s Privacy policy here

5.2 Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

6 How long will we retain your data for?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7 Age limit for our users

You must not use Buzz Bikes Limited unless you are aged 18 or older. If you are under 18 and you access Buzz Bikes Limited by lying about your age, you must immediately stop using Buzz Bikes Limited.

This website is not intended for children and we do not knowingly collect data relating to children.

8 International transfer of data

Our business operations are supported by a variety of cloud-based servers and other infrastructure which are provided by third party services. We transfer personal data to these services for the purpose of providing our services to you and the performance of our Terms of Use. Some of these services store and process your personal data in the United States of America and elsewhere in the world, including countries that have differing data protection laws. We have certified that all service providers we transfer data to internationally are certified under the EU-US Privacy Shield framework, are hosting data in a country recognised by the European Commission as having adequate levels of data protection, or have agreed to contractual clauses with us that adequately safeguard your personal data.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9 Notification of changes and acceptance of policy

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 26 June 2023. By using Buzz Bikes Limited, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Buzz Bikes Limited will constitute your express acceptance of any modifications to this Privacy Policy.

10 Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.)

Our staff are not authorised to contract on behalf of Buzz Bikes Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Buzz Bikes Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Buzz Bikes Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Buzz Bikes Limited legal department.

11 Terms of use

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of Buzz Bikes Limited.