Data Protection Policy
This policy applies to the personal data that we process about you as a natural person. This policy does not apply if we process anonymous or business data.
Who processes your personal data?
We are COWBOY SA, with our registered office at rue de la Régence 67, 1000 Bruxelles, Belgium, company number 0669.908.031, VAT-number: BE0669.908.031, e-mail firstname.lastname@example.org.
We are the ‘controller’ for the processing of your personal data.
What do we expect from you?
We expect that you only communicate personal data about yourself to us. If you also communicate personal data about other people to us, then you must ensure that you are entitled to do so.
We also expect that the personal data that you communicate to us is correct and that, if specific data changes, you promptly inform us of this change.
Why do we process your personal data?
The purposes for which we process your personal data depend on how you enter in contact with us.
You surf on our website
You contact us (e.g. by filling in a form on our website, by sending us an e-mail)
We process your personal data in order to answer and manage your request (e.g. request for information, subscription to our newsletter, complaint). This processing is based on your consent.
You purchase Cowboy products/services and you download the Cowboy app
We process your personal data for the purpose of client management, based upon the performance of the contract with you regarding the provision of the smart bike.
This includes the processing of your name/e-mail/bike reference/private key in order to activate your personal Cowboy account and to start/stop the bike; the processing of the localization of your bike in order to allow you to track and record the duration/distance/speed of the rides with your bike; the processing of the information (including photos) you may send us in the context of our bike maintenance and reparation service; the processing of the localization of your bike in the context of the bike retrieval functionality.
Aforementioned functionalities are essential characteristics inherent to our smart bikes, which are necessary in order to meet your expectations as user. Without your personal data, we cannot perform the contract with you. This processing may involve compiling a profile. This profiling has no effect on you, except to the extent that it allows you to benefit from the functionalities concerned.
We may also process your personal data for the direct marketing of our products/services, based upon our legitimate interests. We believe that it is important to keep you, as our user, informed about our products/services. This processing may involve compiling a profile. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience and personalized offers, which is an advantage for you. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).
In any case
We may process your personal data for the management of compliance and disputes (eg prevention/detection/sanctioning of unlawful activities and/or abuse of Cowboy’s resources, defense of legal claims), based on our legitimate interests. We believe that the management of compliance and disputes contribute to safeguarding and promoting our economic, commercial, social and financial interests. The processing may involve compiling a profile and has no effect on you, except in the context of management of compliance and disputes. We may anonymize your personal data and process aggregate data for research and development, based on our legitimate interests (eg statistics about sales, market analysis, statistics about the users and use of our products/services, development and improvement of our products/services). We believe that research and development can lead to enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services (such as customers, distributors, suppliers). Research and development may involve compiling a profile. All identifying elements, such as your name, your address, etc., are eliminated. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience, product improvement and innovation, which is an advantage for you.
The provision of your personal data for these purposes is a contractual requirement but you can object to the processing (see article 8 below).
With whom do we share your personal data?
We can transfer your personal data to companies that process personal data in our name and on our behalf (known as ‘processors’), to scientific institutions in the context of research and development, to third parties when there is a legal obligation to do so, to our commercial partners, and to the police or judicial authorities at their request if they are entitled to request the personal data.
Is your personal data transferred outside the European Union?
We can transfer your personal data to countries outside the European Union, including the United States. Each transfer will be based on appropriate safeguards (adequacy decision and/or standard data protection clauses of the European Commission). If you would like to know how to obtain a copy of the appropriate safeguards, you can contact us at the address stated above (article 2) or via email@example.com.
For how long is your personal data retained?
Your personal data is retained for as long as you are in contact with us (e.g. you use our products/services, subscribe to our newsletter) and for up to maximum 10 years after the end of this relationship.
What are your rights?
You can contact us to exercise the following rights, in accordance with the conditions laid down in the applicable legislation:
Withdrawing your consent for the processing of personal data, to the extent that the processing of your personal data was initially based upon your consent. Seeking access to, or correction, deletion or restriction of your personal data. Objecting to any processing for direct marketing and/or any processing based on the legitimate interests as processing ground (such as research and development). Seeking the portability of your personal data, which you have communicated to us.
You can exercise some of these rights via the settings in your personal account with us (if you have such a personal account).
You can exercise all of these rights by contacting us at the address stated above (article 2) or via firstname.lastname@example.org.
You also have the right to file a complaint with the competent data protection authority (e.g. in Belgium: Commission for the Protection of Privacy, rue de la Presse 35, 1000 Brussels, email@example.com, www.privacycommission.be).
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