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Privacy & Security on The Emporium

Privacy & Security on The Emporium

Privacy Policy

Your privacy is extremely important to us and we are committed to fair practices that protect your information. This Privacy Policy is provided to explain our information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make our policies and procedures available on every page of this website. In all instances we are committed to transparency with our customers, employees and protecting your data privacy. Introduction

This Privacy Policy explains how personal data is collected and used by CyclingTips Media Pty Ltd (referred to as “CyclingTips”, “we”, “us”, “our”) about users (“you”, “your”) in connection with our website, www.CyclingTips.com (the “Site”). At CyclingTips, we respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us using the details below. By using the Site and our services, you acknowledge and accept that we will use your personal data as set out in this Privacy Policy. If you do not accept this Privacy Policy, please immediately stop using the Site and/or our services or any part of them. In these circumstances, you will not be able to sell or purchase anything using the Site.

The Site is not intended for children and we do not knowingly collect data relating to children. If you are a child under the age of 13, please do not attempt to register on or use the Site or send any information about yourself to us, including your name, address, telephone number or e-mail address. No one under the age of 13 may provide any personal data to us or on the Site. If we learn that we have collected personal information from a child under age 13 without their parent’s or parental guardian’s consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at support@CyclingTips.com.

Any terms that are capitalised that are not defined in this Privacy Policy shall have the same meaning as given to them in our terms and conditions, unless the context otherwise requires.

What does this Privacy Policy cover?

This Privacy Policy covers the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

  1. Important information and who we are
  2. Data protection principles
  3. The data we collect about you and how we collect and use your data
  4. Disclosures of your personal data
  5. International transfers
  6. Data security
  7. Data retention
  8. Your legal rights
  9. Glossary

1.0 Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how CyclingTips collects and processes your personal data, including any personal data you may provide through the Site, such as when you register or access an account, place an advertisement, buy or sell a product, make an enquiry about a product, register a retail shop, search for a bike shop, submit a general enquiry, enter a competition, subscribe to our newsletter, leave your comment or feedback, manage your marketing preferences or make a payment. Please see the Glossary section for an explanation of the meaning of “personal data” and “personal information”. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

CyclingTips is the controller and responsible for your personal data. We have appointed a data compliance manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data compliance manager using the following details:

Contact details

E-mail address: support@CyclingTips.com Postal address: Level 1, 134 Buckhurst St, South Melbourne, 3205, Victoria, Australia. Telephone number: +61 03 9257 3200

For European residents, you have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on Friday 25th May 2018.

We keep this Privacy Policy under regular review and may amend it from time to time. Please check back regularly to view the latest version. Hard copies of this Privacy Policy are available from us on request.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.0 Data protection principles

CyclingTips adheres to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:

(a) Processed lawfully, fairly and in a transparent manner. (b) Collected only for specified, explicit and legitimate purposes. (c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. (d) Accurate and where necessary kept up to date. (e) Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed. (f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. (g) Not transferred to another country without appropriate safeguards being in place. (h) Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data. We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

3.0 The data we collect about you and how we collect and use your data

We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when you: -access and use the Site and our services; -register an account on the Site; -leave a comment on the Site; -place an advertisement on the Site; -buy or sell a product through the Site; -make an enquiry about a particular product on the Site; -register a retail shop on the Site; -search for a bike shop on the Site; -submit a general enquiry to us; -enter a competition; -create a wish list on the Site; -subscribe to our newsletter; -leave your feedback or review on the Site; -manage your marketing preferences with us; or -make a payment through the Site.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data under data protection law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of the Site to calculate the percentage of users accessing a specific feature. Likewise, we may aggregate data that we collect through your use of the Site in order to produce certain benchmarking reports. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not knowingly collect or process any Sensitive Personal Data (as defined in the Glossary) about you. Please do not provide us with any Sensitive Personal Data through the Site. If we become aware that we have collected Sensitive Personal Data, we will use our reasonable endeavours to delete that information as quickly as possible.

If you fail to provide personal data

Where we need to collect personal data by law, or in order to give you access to the Site and/or our services (or any part of them), and you fail to provide that data when requested, we may not be able to give you access to the Site or provide our services to you.

The below table provides a summary of how we collect and process your personal data:

1
2
3
4
5
6
7
8

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table above.

Marketing

We will only contact you by e-mail for marketing purposes if you have given us your opt-in consent to do so. Please note that we will continue contacting you in connection with any contract that we have with you, including the use of the Site and our services. We will also continue contacting you to provide you with our newsletter if you have previously signed-up to receive it. We will not share your information for marketing purposes with any company or other entity outside of the CyclingTips group, unless we have your opt-in consent to do so.

You can ask us or third parties to stop sending you marketing messages by contacting us at any time or by clicking the “unsubscribe” button in the relevant e-mail.

We do not and will not sell any of your personal data to any third party.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Cookies

Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. “Cookies” are small files of letters and numbers which we transfer to your computer or device that allow us to recognise your browser or device and tell us how and when pages in our Website are visited and by how many people. These cookies are anonymous and they will not collect information that identify you.

The types of Cookies used by us: • Strictly Necessary Cookies. These are essential to enable navigation around our website and use its features. Without these, we would be unable to provide you with certain features.

• Functionality Cookies allow our Website to remember choices you have made and helps to provide an enhanced, more personal experience on our Website.

• Performance Cookies to help us improve our website and our online services. These cookies gather information about how our Website is used, including which pages you visit most often. These cookies are anonymous, which means that they won’t collect information which identifies you.

• Targeting and Advertising Cookies. Advertising cookies are used to help us better understand our advertising campaigns and how we can make these more relevant to you. These cookies are also anonymous. They won’t collect information which identifies you.

You can delete cookies stored on your computer or change your privacy settings at any time via your browser settings. These browsers include; • Internet Explorer • Chrome • Firefox • Safari

You may be able to change the preferences on your browser or device to prevent or limit your computer’s or device’s acceptance of cookies, but doing so may prevent you from taking advantage of our Website’s best features or accessing part or all of the Website. Our advertising partners may transmit cookies to your computer or device when you click on ads that appear on our Website. This Privacy Policy does not cover cookies delivered to you by any of our advertisers. If you are concerned about third party cookies generated by advertisers, you can turn these off. We have no control over these cookies.

4.0 Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

  • Other entities within the CyclingTips group for general administrative and operational purposes, or marketing purposes if you have given us your opt-in consent.

  • Buyers only: Sellers with whom you will have entered into a contract when you purchase a product on the Site, for the purposes of delivering the product, administering any refund, and providing order updates and other communications relevant to the contract that you have with the Seller.

  • Sellers (both Retail and Private Sellers) only: Buyers, with whom you have entered into a contract when you sell a product on the Site, for the purposes of enabling you to deliver the product, administer any refund and provide order updates and other communications relevant to the contract that you have with the Buyer.

  • Promotional partners (such as suppliers or manufacturers of products), if you have given us or them your opt-in consent.

  • Service providers who provide IT, software, marketing, advertising and system administration services.

  • Third party agencies, such as credit reference agencies and fraud prevention agencies, for fraud prevention and detection purposes.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, accountants, insurers and other third parties based who provide legal, banking, consultancy, accounting, insurance and other related services.

  • Third parties approved by you, such as social media providers.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.0 International transfers

Some of our external third party service providers or partners may be based outside the European Economic Area (EEA), in which case, their processing of your personal data may involve a transfer outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (such as New Zealand or Switzerland).

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it has under EU data protection law.

  • Where we use service providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires the service provider to apply a similar standard of protection to personal data shared between the EU and the US.

  • Alternatively, we may transfer your personal data outside the EEA where data protection law allows or requires us to do so.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the EEA.

6.0 Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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 they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7.0 Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available on request by contacting us using the details above.

8.0 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us; support@cyclingtips.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9.0 Glossary

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

LAWFUL BASIS

“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

GLOSSARY

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

QUESTIONS OR CONCERNS

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@CyclingTips.com. We will make every effort to resolve your concerns.

Last Updated: 24th May, 2018.

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