BACKGROUND:

 

We at Hunt Bike Wheels understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all those we do business with or who contact us at our website, [www.huntbikewheels.com] (“Our Site”). We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

We are ITS Cycling EU GmbH trading as  Hunt Bike Wheels, a Company registered in Germany under  HRB Number 45041.

Our email address is: privacy@huntbikewheels.com

Our postal address/registered office is: Am Lagerplatz 2, 01099 Dresden



2. What does this Privacy Policy cover?

This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data irrespective of whether you are in the UK or in the EEA.


3. What do we mean by Personal Data and other terms used in this Notice?

Personal data is defined by the EU GDPR as “any information relating to an identified or identifiable natural person”. We refer to this legislation as “the Data Protection Legislation” in this Policy.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below. For a definition of the other terms that we use in this Notice, please see the Glossary in Part 14, below.


4. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any personal data which is ‘special category’, ‘sensitive’, relates to children or to criminal convictions and/or offences.

Data Collected

How We Collect the Data

 

Contact Data

Directly from you when you do business with us as a customer or supplier 

or contact us with a view to doing business or from public records or third 

party data bases.

 

Business Data

Directly from you when you do business with us as a customer or supplier 

or contact us with a view to doing business or from public records or third

 party data bases.

 

Financial Data

Directly from you or from public records or third party data bases.

 

Identity Data

Directly from you when you do business with us as a customer or supplier

 or contact us with a view to doing business or from public records or third 

party data bases.

 

Marketing and Communications Data

Directly from you when you do business with us as a customer or supplier 

or contact us with a view to doing business or from public records or third 

party data bases or business data providers.

 

 

Technical Data

Directly from you when you use our website(s).






 

5. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do

What Data We Use

Our Lawful Basis

Collecting your contact details from Our Site

Contact Data.

Performance of a contract.

Consent – if this is required.

 

 

Administering our business.

Business Data & Financial Data.

Performance of a contract.

 

Legitimate interests to develop our business.

 

Supplying or buying products and services.

Contact Data & Identity Data.

Performance of a contract.

Managing payments for our products and services.

Financial Data.

Performance of a contract.

 

Personalising/tailoring and improving our products and services for you.

Business Data, Financial Data & Identity Data.

Legitimate interests to develop our business.

Communicating with you when doing business.

Contact Data, Identity Data, Business Data & Financial Data.

Performance of a contract.

Providing you with information about our products and services by telephone, email or post.

Marketing and Communications Data.

Consent – if this is required.

 

Legitimate interests to develop our business.

Protecting the security of our business assets and the well-being of our employees, customers, suppliers and visitors.

 

 

 

Technical Data.

Legitimate interests to safeguard our business and third parties.

 

Vital interests.

 

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.


If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
 In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights. 

 

6. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data

How Long We Keep It

Contact Data

5 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

 

 

Business Data

5 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

Financial Data

 2 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

Identity Data

3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

Marketing and Communications Data

3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

Technical Data

3 years in relation to any prospective business communications or enquiries, then as long as we are doing business with you and for a period of 6 years after.

 

 7. How and Where Do You Store or Transfer My Personal Data?

We will only usually store your personal data in the EEA or the UK. This means that it will be fully protected under the Data Protection Legislation.

Transfers of personal data to the UK from the EEA are permitted without additional safeguards under Data Protection Legislation. If we store some or all of your personal data in countries outside of the EEA or the UK, known as “third countries”, we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the r EEA and under the Data Protection Legislation as follows:

We will either:

  • store your data in the EEA or the UK; or
  • store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the  European Commission – Adequacy decisions

 The additional steps we take when storing or transferring personal data to “third countries” are  specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Federal Commission for Data Protection and Freedom of Information (BfDI)

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.


8. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

We may share your personal data with other companies in our group for business administration purposes. This includes subsidiaries and any holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply products and/or services, such as IT or telecommunication services.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 7.

If any personal data is transferred outside of the EEA or the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation, as explained above in Part 7.


9. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
  2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the  Federal Commission for Data Protection and Freedom of Information (BfDI) .

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the  Federal Commission for Data Protection and Freedom of Information (BfDI). We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.


10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.


11. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site or to collect analytical information (without collecting personal data). We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Details of the  Cookies which may be placed on your computer or device are set out in more detail in our Cookie Policy which can be accessed on this link.

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.


12. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: privacy@huntbikewheels.com

Postal address:Am Lagerplatz 2, 01099 Dresden


13. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website This Privacy Policy was last updated in March 2024.


14. Glossary
 

Accident Data means information relating to your health and medical treatments.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Contact Data means any information needs to contact you such as an email address(es), telephone number(s), correspondence or billing address(es).

Business Data means information about you or your business which we need or collect in the course of dealing with you or any third party (such as any regulatory authority) which may include the nature of your business, your business or personal requirements, types and location of operations, volumes of waste or materials used and produced. This may also include information from correspondence or communications between us.

Data Protection Laws means the EU GDPR, the ePrivacy Directive and such other applicable privacy related legislation which may supplement, amend or replace them.

EEA means the European Economic Area. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein.

ePrivacy Directive means EU Directive on Privacy and Electronic Communications (EU) Directive 2002/58/EC (as amended).

EU GDPR means Regulation (EU) 2016/679 as applies to EU/EEA member states and applies to ”activities of an establishment of a controller or a processor in the Union, regardless of whether the processing takes place in the Union or not” (Art 3).

Financial Data means any information relating to payments (including payment card details and/or any credit limits or payment terms), invoices, taxes or duties or banking or invoicing information which relates to you or your business.

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Marketing and Communications Data means your preferences in receiving marketing from us and our third parties and your communication preferences.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.      

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.

Vital Interests means processing your personal data where it is necessary to preserve or protect your life or well-being (such as in the case of a medical emergency).