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BROMPTON ELECTRIC APP PRIVACY POLICY

Brompton Bicycle Limited (‘Brompton’, ‘we’, ‘our’ and ‘us’), a company registered in England and Wales under company number 1261512 with registered address at Unit 1, Ockham Drive, Greenford, London, UB6 0FD  , is committed to respecting your privacy rights and recognises the importance of protecting your personal information.

This Privacy Policy describes how we collect, use, disclose, store and protect your information when you visit the Brompton website at www.brompton.com (the ‘Website’), you use the ‘My Brompton’ mobile application (the ‘App’), you participate in one of our promotions and/or attend one of our events, or you otherwise engage with our services as described on the Website.

This Privacy Policy was last updated on 19 August 2020.  We may update this Privacy Policy from time to time, the up-to-date version will always be available on the Website but we will also tell you about any important changes. 

Your Information

We collect and use the following information about you:

i. Information you provide to us when you visit the Website or use the App

Before you are able to buy any products through the Website, we will ask you to register and create an account on the Website (a ‘Brompton Account’).  This is to enable us to process your purchases and communicate with you.  To create a Brompton Account, we will ask you to provide your full name, email address and password.
You will also need to provide us with your payment information, billing, and delivery address in order for us to process your payment and deliver your products to you.
If relevant in the circumstances, we will also collect and use the following information that you provide us  :
through direct interactions, by corresponding with us by post, phone, email or other communication that you send to Brompton, for example, if you make an enquiry about the Website or the App, our products, services or the status of your order;

your email address, if you subscribe to receive marketing communications from us (for example, the newsletter), and any other contact data;

information about any orders you place through the Website and other transaction data;

information about any products that you have registered through the Website  or the App; and

information you submit via any surveys or review that we invite you to participate in and any other preference data.

ii. Information you provide to us  when you participate in one of our promotions and/or attend one of our events

In order to register for or attend one of our events or participate in one of our promotions, we may ask you to provide your full name, your home address, your email address and your age (to determine whether you are eligible to attend or participate). We may also collect special category personal  about you if you inform us of any event access or dietary requirements (for example if you need special assistance at one of our events).

We may also process any information you have provided in connection with the event or promotion, including feedback, reviews, answers to promotion questions, photos, videos or other user generated content. 

Please note that if you provide us with information relating to another person, you must inform them of our identity, the purposes for which their information will be used and obtain their consent to sharing their information with us.

iii. Information we collect automatically (including by cookies)

When you visit the Website or the App, even if just browsing, we will automatically collect certain information from your device.  This may include your computer’s IP address (which is automatically assigned to your computer by your internet service provider), operating system, log in times, browser type and unique device ID, broad geographic location (e.g country or city-level location) and other technical information including details about the websites you visited before and after visiting the Website[or the App ], search queries that landed you on the Website, search queries you conducted on the Website[ or the App] and pages and advertisement you viewed and links you clicked on while using the Website[or the App].

Collecting this information enables us to better understand the visitors who come to our Website or App, where they come from, and what content on our Website or App is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevant of our Website or App to our visitors.
Some of this information may be collected using cookies and similar tracking technology.  For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.

We also collect data indirectly through your use of the Website or App, for example, usage data about the distance you have cycled and your location data or IP address when you request to find our nearest store. 

If you engage with one of our promotions or events via social media, for example if you enter one of our promotions through a social media channel, or register for, like, or comment on one of our events through social media, we will collect your social media handle or ID to enable us to contact you via the applicable social media channel about the promotion or event.

We may record and/or photograph our events for repurposing in digital e.g. on the Website, through our social media channels or in print form.  We will let you know in advance if we intend to take photographs or record an event. 

iv. Information we collect from third parties

From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclosure your personal information to u.

For example, you may choose to connect to our services via a social media account or you may choose to register for an event of participate in a promotion via a social media account.  Exactly what information we receive from your social media provider will depend on your social media privacy settings, but will typically include your basic public profile information and email address.

We may collect information about you from third party providers of postcode demographic information that we will associate with your Brompton Account.  In conjunction with the other personal information we collect about you, this helps us to service you with digital marketing and e-mail communications that we believe are better tailored to your interests. We will only send you marketing communications where we have a lawful basis to do so.

Use of Information

The purposes for which we use your personal information are:

In connection with your use of the Website and the App:

to create and administer your Brompton Account;

to fulfil your requests for products [and services], including processing orders you have placed, delivering your goods and arranging test rides;

to manage and respond to your enquiries, complaints or other correspondence with us;

to solicit and manage your review of our products/services;

to send you service-related communications (e.g. relating to products purchased or registered through the Website or your Brompton Account);

to send you marketing communications where we have a lawful basis  to do so;

to provide you with personalised content and advertising about our products, services and offers through email communications through our Website, our App and third party websites and mobile applications;

to protect the Website, the App and your Brompton Account, against malicious or fraudulent activity by any person;

to store details relating to the use of your product; inform you when it may be due to be serviced; and store the service history;

to recommend our nearest store based on your location;

to store mode preferences relating to use of your product; and 

to carry out analysis and market research into our Website and App usage, products and services to help improve both.

In connection with your participation in one of our promotions and/or your attendance at one of our events:

to manage our events and coordinate your attendance at our events;

to facilitate your participation in our promotions;

to manage and respond to your enquiries, complaints or other correspondence with us;

to solicit and manage your review of our products and/or services;

to send you service-related communications (e.g. about our event(s));

to send you marketing communications where we have a lawful basis to do so;

to carry out analysis and market research into our events, products and services to help improve them;

for marketing and/or advertising purposes; and

for any other uses or purposes made known to you at the time of collection.

Who we share your Information with

We may share your information with the following categories of recipients:

to Brompton group companies or our third party service providers and third party partners who provide data processing services to us for any of the purposes explained above (for example, to host our Website and App or manage our events), or who otherwise process personal information for purposes that are described in this Privacy Policy or who were otherwise notified to you when we collect your personal information.  Our service providers are all located in Europe and the United States and fall within the following categories:

customer support service providers;

product support service providers;

marketing service providers;

advertising partners;

website hosting and maintenance service providers;

product review service providers;

payment service providers and acquirers ;

event management service providers.

to any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, to protect, exercise or defend our rights or the rights of any third party, or otherwise to protect the vial interests of any person;

to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy; and

to any other person with your consent to disclose.

Legal basis for processing your Information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only: (i) where we need the personal information to perform a contract with you (i.e. to fulfil your purchase of products or your entry to an event that you have registered for); (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so (e.g. where we process special category personal data relating to your dietary or access requirements).  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we need to process your personal information to comply with a legal requirement we will make this clear at the relevant time and advise you whether the provision or your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our services (including the Website, the App and our events)  and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing and advertising, or for the purposes of detecting or preventing illegal activities.  We may have other legitimate interests and if appropriate will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact” heading below.

Security

We want you to feel confident about using the Website and the App and we are committed to protecting the information that we collect. We have appropriate technical and organisational measures in place to protect the information you provide to us against unauthorised or unlawful use and against accidental loss, damage or destruction. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality. 

Your Rights


You have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the "Contact” heading below.

In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact” heading below.

You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contact” heading below.

Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority, in the UK this is Information Commissioner’s Office (www.ico.org.uk). 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

International Transfers

From time to time, we, our group companies, service providers and/or third party partners may need to transfer your information internationally in order to service this Website or in connection with any other purpose explained in this Privacy Policy. This may include transfers of your personal information to territories outside of the European Economic Area (or EEA). These countries may have data protection laws that are different to the laws of your country and in some cases may not be as protective.

Specifically, our Website servers are located United Kingdom, our third party service providers and partners operate across Europe and the United States and our group companies operate around the world including in [Asia, Australia] and the United States. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy as provided for by the standard contractual clauses that have been adopted by the European Commission.

Retention


We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example to comply with applicable legal, tax or accounting requirements and/or as necessary to defend ourselves against any claims).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Other Websites


The Website may contain links to other websites which are outside our control and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.

Contact

If you have any questions about this Privacy Policy, about the ways in which we process your information or would like to exercise one of your rights you can contact us at: support@brompton.co.uk.

Alternatively you can contact the Data Protection Officer.

For the purposes of European data protection law, Brompton Bicycle Limited is the data controller of visitors' personal information collected as described throughout this Privacy Policy.