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 contact@BikeExchange.co.uk.
Important information and who we are
Data protection principles
The data we collect about you and how we collect and use your data
Disclosures of your personal data
Your legal rights
1.0 Important information and who we are
BikeExchange is the controller and responsible for your personal data.
E-mail address: firstname.lastname@example.org
Postal address: c/o Incisive Accounting, Netwise House, 24 Old Jamaica Road, Bermondsey, London SE16 4AW
Telephone number: +44 207 784 6453
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.
This version was last updated on Friday 18th May 2018.
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.
2.0 Data protection principles
BikeExchange adhere 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;
-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 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:
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.
We will only contact you by e-mail or text message 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 BikeExchange 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.
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
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 BikeExchange group for general administrative and operational purposes, or marketing purposes if you have given us your opt-in consent.
-3Sixty1 Pty Ltd, a company registered in Australia, for the purpose of data analytics.
-Buyers only: Sellers (both Retail and Private 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.
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.
55/ 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.
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.
“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.
“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.