Privacy Policy

A. What Personal Information Do We Collect?

In broad terms, applicable Canadian privacy legislation defines “Personal Information” as information about an identifiable individual. This Privacy Policy applies solely to Personal Information and does not apply to public information of a general nature that is not also Personal Information.

We collect Personal Information from You when you voluntarily provide it through our Platform or by using our products and services. For instance, we may collect Personal Information when you create an Account, when you communicate with us by phone, email or functionality provided through our Platform, when you access our platform from a browser or mobile device, or when you install one of our devices on your e-bike or operate your e-bike with our device attached. We may also collect Personal Information about you from other sources such as third-party service providers or publicly available sources.

The types of Personal Information that we may collect about you include:

• Your legal name as well as contact information such as your email address, physical address and phone number;
• Your Account username, password, demographic information such as your age, birth date and gender, profile picture, location/region and other information you may provide to us on creating an Account;
• Data regarding your usage patterns relating to our website or mobile app;
• Information about your e-bike, including brand, model, wheel size, and various settings on your e-bike such as your dashboard settings and various visual information about your dashboard visual layout; and
• Real-time data about your activities on your e-bike, including GPS location data, battery status and other electrical systems data, data regarding error codes, data about specific rides such as distance and duration, and data from motion and environmental sensors. This data may be obtained from both your e-bike controller and from sensors incorporated in our devices.

B. How do we use your Personal Information

The Personal Information we collect from you may be used by us for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to You and to which You consent. Without limiting the generality of the foregoing, we may use the Personal Information we collect from you for the following purposes:

• To facilitate Account registration;
• To monitor the usage of our Platform as well as detect, prevent and address technical and security issues with the Platform, including to verify your identity and protect against error and fraud;
• To respond to inquiries and provide customer support;
• To gather analysis or valuable information so that we can improve our Platform, including the operation of our devices;
• To facilitate delivery of our products and services and the operations of our Platform in the ordinary course of business. Please be aware that certain Personal Information, such as your user name, profile picture, ride distance and achievements may be accessible to other users of our Platform through the social functionality provided by our Platform. You can control the information that may be viewed by other users of the Platform through your Account settings;
• To verify compliance with our Terms of Service and for dispute resolution purposes;
• For any other purposes that are disclosed to you and to which you consent; and
• For any purposes required or authorized by law.

We will retain your Personal Information for the period reasonably necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations. Different pieces of Personal Information may be retained for different time periods in light of the requirements above.

Some or all the information we collect may be stored or processed in jurisdictions outside of Canada. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

C. Sharing Information With Third Parties

Under certain circumstances, for the purposes set out above, we may disclose your Personal Information to third parties, including as follows:

• To our third-party service providers for the purposes of providing our services to you;
• if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency);
• based on our good faith belief that such action is necessary to protect and defend our rights or property, to protect the personal safety of our customers or the public or to protect against legal liability; or
• to a third party in the event that we merge with or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition;

Please be aware that any Personal Information disclosed to any third parties as set out above may be subject to the privacy policies and terms of service of such third parties. We have no control over the privacy policies or privacy practices of such third parties.

D. Cookies and Usage Data

In addition to any information that you choose to submit to us, we may use a variety of technologies that store or access information already stored on your personal computer, laptop, tablet or mobile phone (each a device) whenever you visit or interact with our website. We use Cookies to collect information about you and your use of our Platform. Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies may also be used, such as beacons, tags, and scripts, to collect and track information and to improve functionality and performance of our website, including tailoring our website to increase the relevancy of content displayed to you.

When you visit our Platform, we may use any of the above technologies to collect information such as the type of Internet browser and operating system you use, the domain name of our website from which you came, your preferences, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. We use cookies to improve and customize your browsing experience and to analyze and measure information about visitors’ on our website and on other platforms, and for the other purposes identified above. We may also monitor traffic patterns, usage, and related information to optimize your visit to our Platform. This data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, and the location from which you are accessing our Services.

We obtain your consent to our information collection technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make your choice whether to use our website. You have the right to object to the use of information collection technologies. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please be aware that if you disable or remove these technologies some parts of our Platform may not function effectively. When you revisit our website your ability to limit cookies is subject to your browser settings and limitations.

E. Withdrawal of Consent

You may withdraw your consent to our collection, use, and disclosure of your Personal Information at any time, subject to legal and/or contractual restrictions and reasonable notice. Your withdrawal of consent to our collection, use and disclosure of your Personal Information may impact your ability to use our Platform. To withdraw consent, please contact our Privacy Officer by using the contact information provided below in our Contact Information section.

F. Safeguards and Risks

We maintain appropriate safeguards to ensure that your Personal Information is protected against loss, theft, misuse, unauthorized access, disclosure, or alteration in accordance with industry-standard security measures. These include security of our physical premises, and various security safeguard software and firewalls to prevent unauthorized access to Your personal information.

While we endeavour to keep your Personal Information safe, our collection, use, and disclosure of your Personal Information is not without risks. For example, our security safeguards may be compromised by viruses, hacking attempts, or physical break-ins. Consequently, we cannot guarantee the security of your Personal Information.

G. Access and Rectification

You have a right to challenge the accuracy and completeness of your Personal Information and to have it amended or deleted, as appropriate. You also have a right to request access to your Personal Information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal Personal Information about another individual, your request for access may be limited or denied.

To request access or to amend your Personal Information, please write to our Privacy Officer at info@cykel.io or at the address provided in our Contact Information section below.

H. Age Restriction

We do not knowingly collect or maintain Personal Information from people under 19 years old. If we learn that Personal Information of people under 19 years old has been collected by us, we will take appropriate steps to delete this information unless we are legally required to keep it. By using our Platform you confirm that you are at least 19 years old.

In the event that you are over the age of 19 but under the age of majority in your jurisdiction, you must obtain the consent of your parents or legal guardian before using our website or engaging with our Platform. By using our Platform you and your parents or legal guardian confirm that you consent to the collection, use, and disclosure of your Personal Information as set out in this Privacy Policy.

I. Privacy Officer Contact Information

If you have any questions or concerns about this Privacy Policy or the handling of your Personal Information, if you wish to withdraw your consent to our use or disclosure of your Personal Information, or to request access to or update any of your Personal Information we have on file, please contact our Privacy Officer at: info@cykel.io.

J. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Any changes will be posted on our website. The “effective date” notice at the top of our Privacy Policy lets you know when this Privacy Policy was last updated. Please check from time to time to ensure you are aware of our current policy. Any changes to our Privacy Policy are effective as of the “effective date”.