PRIVACY POLICY

 

UNDERSTAND HOW WE COLLECT, USE, DISCLOSE, TRANSFER, AND STORE YOUR INFORMATION

 

Last updated November 28, 2017

 

At Superpedestrian, we take your privacy seriously.

 

This Privacy Policy describes information that Superpedestrian, Inc. collect, use, share and store, 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 Information
  • 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.

Mailing List Information

When you contact us by email, sign up for our mailing list, purchase a product, register for an account, or contact us through our support site, we collect your email address in order to respond to you. When submitting other information such as name or country, we will include this in our mailing list to provide you with relevant emails. 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.

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, you will be directed to the website of the third-party service, such as EventBrite, which will collect information to enable you to make a reservation.  This third-party collection of your information is covered by the third party’s privacy policy and is not covered by this Privacy Policy.

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. 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.

We use cookies, or small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites 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. 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.

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 are not permitted to use the information collected on our behalf except to help us conduct and improve our business.  To learn more about cookies, clear gifs/web beacons and related technologies, please visit allaboutcookies.org.

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 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 does not apply to these features.  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.

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.  If your child provided Personal Information to the Site, please contact us using the information provided below.

 

 

Information collected by the Copenhagen Wheel and App

The Copenhagen Wheel and App collect:

  • Setup and Account Information
  • Ride Information
  • Wheel Diagnostic Information
  • 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. 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. This information is also transmitted over cellular or other wireless networks and is backed up on our cloud-hosted servers.

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.

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.

 

 

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 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.

We will retain Personal Information we process for as long as needed to provide the Services. We will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

 

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 support@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 system records but will be blocked from further processing without your permission.  A request to revoke consent or block processing of your Personal Information may not apply to information collected by cookies or used internally to recognize you and/or facilitate your visits to the Site, or information we may keep to comply with legal requirements.

 

 

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 support@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: support@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: support@superpedestrian.com.

 

 

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 support@superpedestrian.com for resolution.

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).

 

 

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

support@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