1. Purpose Of The Policy
Please note that this Policy applies in conjunction with other policies and procedures. It does not establish contractual or legal rights for any persons, but intends to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the ‘General Data Protection Regulation’ or ‘GDPR’).
2. Who Controls Your Personal Data?
Outdoor & Cycle Concepts is the controller of the personal data you submit to us and is responsible for the processing of your personal data under the applicable data protection legislation. Our registered address is Outdoor and Cycle Concepts Ltd, Unit 11 Kemble Business Park, Crudwell, Malmesbury, Wiltshire, SN16 9SH. Outdoor & Cycle Concepts is registered in the United Kingdom under company number 3382348 VAT Number: GB771695393.
3. How We Collect & Process Your Personal Data:
3.1 Personal Data We Collect About You
Because data privacy is of high importance for us, we intend to remain open and transparent about how we use your personal data. Cycle Surgery will only collect your personal data where necessary for our Services.
Depending on your use of our Services and our websites, we may thus collect, use and disclose (i.e., process) the following types of personal data about you: your contact information, such as a name, surname, address, e-mail address, IP address and telephone number. We may also collect payment, credit and order information. Moreover, if you have an existing Explore More account, we will collect and process other information that identifies or can be used to identify you for the provision of our Services and Cycle Surgery products, such as your Explore More number, your birth date, your previous purchases and shopping preferences, as well as web-browsing behaviour on our websites. For more information about the way we process personal data, we invite you to read the following sections.
Although we are technically considered ‘data controllers’, the ultimate control over your personal data remains with you at all times. Provided you give us a proof of your real identity, you have the right to request access to a copy of the personal data we currently maintain about you in a structured, commonly used and machine-readable format and obtain information regarding the processing, including whether we process your personal data for profiling purposes. In case you notice an error in your personal data, you may also request that we rectify the inaccurate personal data or complete your personal data. Following this, we will notify each third party to which we have disclosed your personal data, so that they can make sure your personal data is accurate with them too. Where technically feasible, you have the right to request that Cotswold Outdoor transmits your personal data to another company of your choice.
3.2 Legal Grounds For Processing
Under the applicable data protection legislation, personal data may only be collected and processed based on a limited number of legal grounds. At Cycle Surgery, we rely on one of the following grounds to process your personal data:
- Necessity for the performance of a contract with you (e.g. when you purchase products from us);
- Legal obligation to which Cycle Surgery (e.g. when we handle your payment details);
- Legitimate interests of Cycle Surgery (e.g. when we send you marketing e-mails regarding products similar to the ones you already purchased from us);
- Your explicit and informed consent (e.g. when you subscribe to our newsletters through your marketing preferences, or if you participate to a contest).
3.3 Creating An Explore More Account
When you visit one of our online or physical stores, you will be given the opportunity to create an individual Explore More account allowing you to enjoy a more personalised experience and various benefits such as quick checkouts by having Cycle Surgery automatically enter your billing and delivery address, payment details and preferred shipping information.
Creating an Explore More account requires your personal e-mail address as login, first name and surname. In addition, you may also register your gender, language preferences, birthday, postal address for billing and shipping purposes and telephone number. When you create an Explore More account, and only if you consented to receiving e-mails from Cycle Surgery, a welcome e-mail will be delivered to the e-mail address you submitted during your registration. This way, we can be sure you receive the latest news about your favourite outdoor brands.
We process personal data for these purposes because it is in our legitimate interests to provide Services to our customers. Under the GDPR, you have the right to object at any time to the use of your personal data by Cycle Surgery. While this means we will no longer be able to process your personal data, we may still store your personal data until you explicitly request we erase it.
3.4 Purchasing Products Through Our Websites
If you purchase products through our online stores, Cycle Surgery will require your personal data to manage your payments, handle your orders, and make sure the products you have bought are delivered to the right address by our external delivery partners.
In order to purchase products through our websites, Cycle Surgery will collect personal data such as your name, surname, e-mail address, Explore More number, telephone number, billing and shipping information, and limited payment card information. We process your personal data for the purposes explained above because it is necessary for the performance of the contract with you.
We may also need to process other personal data such as your navigation and browsing behaviour with a view to for example save items in your shopping basket, provide you with relevant product recommendations, or offer you size recommendations. Moreover, processing this personal data allows us to keep track of your purchasing history, for example in case you change your mind following your purchase, or if you need to return a product according to the applicable return policy.
3.5 Marketing E-mail Newsletters
Some of our Customers might be genuinely interested in receiving newsletters about our latest products and Services. However, we understand not everyone feels the same way. Therefore, the processing of your personal data for marketing purposes is based solely on your explicit prior consent, which means we will never send you marketing communication if you don’t want to, unless you have already bought products from us.
If you wish to receive newsletters regarding our latest products and Services, you are able to opt in to our e-mail newsletters through our websites, in which case we will process your e-mail address. If you already benefit from the Explore More experience, you have the possibility to modify your existing marketing preferences through your account settings in order to get more personalised newsletters. In that case, we will process your personal data submitted in relation to your Explore More account, such as your name, e-mail and postal address, age, shopping history, as well as the way you navigated on our websites.
Once subscribed, you may object at any time to the use of your personal data for profiling by Cycle Surgery or any of the third-party recipients we have shared your personal data with, provided that we process your personal data based on our legitimate interests. If we process your personal data for direct marketing purposes, such as sending you newsletters, you have the right to object at all times to the use of your personal data for that purpose by contacting our data protection officer using the contact details below, without any additional cost.
3.6 Information We Collect In Our Stores
When you buy products in our stores, we may process personal data such as your name, contact details and limited payment details because this information is necessary for the performance of the contract with you.
If you already have a registered account, we may use information from your previous online and in-store purchases, as this will help us facilitate purchases, process payments, manage product returns and for marketing purposes. In such case, we process personal data because it is in our legitimate interest to gather insights about our customers who buy our products, both in stores and online.
Since we process your personal data based on our legitimate interests, you have the right to object at any time to the use of your personal data for profiling by Cycle Surgery or any of the third-party recipients we have shared your personal data with. You can do so by contacting our data protection officer by using the e-mail address mentioned below this Policy.
3.7 Events & Competition Forms
Cycle Surgery regularly hosts competitions for its customers. Because we need to identify our contestants and touch base with the winners, we need your contact information as well as your age (to verify you are legally allowed to participate) and any additional information you might want to provide to us. The processing of your personal data is based on your explicit and informed consent. Moreover, your personal data may be shared with third parties, in order for them to deliver and follow up on prize deliveries.
In addition to this, Cycle Surgery also organises events in collaboration with third parties. When you register for these events, we will process your contact details for invitations and lists of attendees, based on the performance of a contractual relationship. Under no circumstances will Cycle Surgery sell your personal data to the third parties we collaborate with.
Under the GDPR, you have the right to object at any time to the use of your personal data by Cycle Surgery or any of the third-party recipients we have shared your personal data with for this purpose. While this means we will no longer be able to process your personal data, we may still store your personal data until you explicitly request we erase it.
3.8 Customer Service
It is in our legitimate interest to make sure technical support as well as complaints and queries relating to product warranties are handled quickly and efficiently. In order to do so, we may process details such as your name, contact information, Explore More number, date of birth, gender, bank account number (e.g. for refunds), purchasing history, and browsing activity. Where you contacted our Customer support through social media, we may also process some of your social media account information.
You may also request Cycle Surgery access to a copy of the personal data we currently maintain about you in a structured, commonly used and machine-readable format and obtain information regarding the processing, including whether we process your personal data for profiling purposes. In case you notice an error in your personal data, you may request that we rectify the inaccurate personal data or complete your personal data. In such case we will notify each third party to which we have disclosed your personal data, so that they can make sure your personal data is accurate with them too.
4. How We Protect Your Personal Data
Cycle Surgery is committed to the processing of your personal data in a lawful, fair and transparent manner. Accordingly, we will only use your personal data if we have a valid reason for doing so and provided you have been informed of the processing purposes beforehand, at the time we collected your personal data.
Moreover, Cycle Surgery guarantees that any processing of your personal data will be limited to what is necessary, adequate and relevant in order to achieve the purposes for which personal data is collected. Whenever possible and technically feasible, Cycle Surgery will use anonymized or pseudonymized data, e.g. for our internal statistics and financial reporting purposes.
Because the protection of your personal data is of the upmost importance to us, Cycle Surgery is also dedicated to protect your personal data and the systems it is held in. We have defined and implemented adequate technical and organisational measures against any unauthorised access, unlawful use, accidental loss, corruption or destruction. This way, Cycle Surgery is confident that your personal data will be processed on a strictly ‘need to know basis’, when and where appropriate and necessary.
As we are fully aware threats evolve and diversify and we wish to sustain your trust throughout the years, we regularly review and update our security measures and infrastructure, with a view to mitigate operational risks and maintain our security programs up to the latest industry-accepted standards and best practices.
5. External Parties With Whom We May Share Your Personal Data
Where relevant and necessary for the purpose of the processing activity, we may occasionally need to disclose your personal data to other appropriate organisations who have a need to know (so-called ‘third party recipients’), based on our legitimate interest.
With the purpose of helping us understand more about your interests and preferences, offer you more relevant advertisements, we may for example share your personal data with data analytics companies and advertisers based on our legitimate interest. Additionally, we may share some of your personal data with external parties when you provide us with feedback and review about our products.
We are also required to share some of your personal data with delivery couriers, such as when you order a product online, and with financial institutions in order to verify your payment details, based on the performance of a contract.
Each time your personal data is shared externally, this will be covered by strict data processing agreements, where Cycle Surgery remains the data controller and the third parties involved act as data processors. Cycle Surgery shall restrict the access and transfer of your personal data to trusted third party recipients who demonstrate an adequate level of data protection. Moreover, these third-party recipients will be required to delete or return all the personal data to Cycle Surgery after the end of the provision of Services relating to the processing and delete existing copies, unless the law requires storage of the personal data.
6. International Transfers Of Your Personal Data
7. How Long We Keep Your Personal Data
As a general rule, Cycle Surgery only keeps your personal data for as long as necessary to fulfil the purpose for which we initially collected it. However, because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. In addition, there are laws and regulations that apply and which set minimum periods for retention of personal data.
Cycle Surgery will always ensure you are kept informed of the criteria used to determine the effective retention period as well as the underlying reasons thereof, which will depend on whether we process your personal data in the context of a contractual relationship with you or based on your explicit consent; whether we process the personal data for our own legitimate interest, or whether Cycle Surgery is legally obligated to retain the personal data for a specific period or to comply with specific legal obligations.
8. How We Erase Your Personal Data
Under certain circumstances, and provided you give us a proof of your real identity, you may exercise your right to request the erasure of your personal data and have us inform third-party recipients to whom we provided your personal data of this request. Please be aware that this is only possible to the extent that the personal data is no longer necessary for the initial purpose (i), if the processing was based on your consent and you withdrew it (ii), or where you have already objected to the processing based on our legitimate interest (iii).
Except when we need to keep a copy of your personal data for statistical purposes, to establish, exercise or defend legal claims (e.g. regarding the warranty period applicable to products sold by Cycle Surgery) or insofar as we are legally required to retain a copy of your personal data, you can rest assured Cycle Surgery shall either securely dispose of or permanently anonymize your personal data once we have fulfilled the initial processing purpose and when further retention of your personal data is not necessary anymore.
9. Your Rights As Data Subjects
For further information or if you wish to exercise one of your above-mentioned rights, please contact us at email@example.com. We will do our best to reply to your e-mail as soon as possible, and in any case within one month. If fulfilling your request necessitates more time, we will keep you informed of this and come back to you within two additional months. Cycle Surgery will charge you nothing for this request, unless we have already provided you with the requested information previously or it appears unreasonably difficult for us to retrieve it. In such case, we will inform you beforehand of the administrative fee.
If you are not satisfied with the way we handled your request, you have the right to request the restriction of our use of your personal data and lodge a complaint with the supervisory authority responsible for the protection of personal data in your country of residence. Although we sincerely hope this won’t be necessary, we have provided the contact details of the relevant data protection authorities below.
The Information Commissioner's Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel: +44 1625 545 745