1. General Provisions
The following Privacy Policy governs the processing of personal data by Ahooga SRL, a company incorporated and existing under the laws of Belgium, having its registered office at Avenue Louise 259, 1050 Ixelles (Brussels), Belgium, and registered in the Belgian Trade and Companies Register under nr. 0633.687.835 (hereinafter, “Ahooga” or “we” or “us” or “our”).
Ahooga is committed to protecting and respecting your privacy.
The purpose of this Privacy Policy is to specify which categories of personal data Ahooga collects through its business activities, its websites https://ahooga.bike, subdomains, directories, services and any other means relating to information or communication, including emails (hereinafter collectively referred to as the “Services”). It further specifies the lawful basis for the processing of the personal data that we collect, as well as how long we store it. It also describes how such data may be processed and disclosed to others. The Privacy Policy further sets out the different measures Ahooga has implemented to safeguard the security and confidentiality of the personal data it collects, whether you have to provide personal data to us, how you can exercise your rights and how you can contact us about our privacy practices.

Ahooga cares about the privacy of the users of its Services and all others whose personal data may be collected (hereinafter, “User” or “you” or “your”) and will only collect and process personal data in accordance with the provisions of this Privacy Policy.

Ahooga is the Data Controller. Ahooga will act in compliance with the General Data Protection Regulation (EU Regulation 2016/679 of 27 April 2016) and all other applicable data protection legislation and as further detailed in the present Privacy Policy (“Applicable Data Protection laws”).

Should you have any questions about this Privacy Policy or the feeling that your interests are not or inadequately represented, you can contact us via email (hello@ahooga.bike), or by sending a letter to the following address:

Ahooga
To the attention of the Privacy Manager
Avenue Louise 259
1050 Ixelles (Brussels)
Belgium

According to the Applicable Data Protection laws, you may be entitled to file a complaint with your local Supervisory Authority or the lead Supervisory Authority, such as the Belgian Data Protection Authority (address: Rue de la Presse 35, 1000 Brussels, Belgium https://www.autoriteprotectiondonnees.be/introduire-une-requete-une-plainte).

This will generally be the case when you are located within the European Economic Area (hereinafter, the “EEA”). We would appreciate it however that, prior to filing any complaint, you contact us so that we may assist you with your request or concern.
Ahooga may change this Privacy Policy from time to time. But when we do, we will let you know one way or another. For example, we may provide you with additional notice (such as adding a statement to our website’s homepage or sending you an email). These means of notification will depend on the extent of the modification (substantial change vs minor tweaks). Modified versions will have immediate effect, unless stated otherwise.
Please note that the Services may contain links to other websites, digital platforms or Internet resources which may collect personal data voluntarily or through cookies or other technologies. Ahooga has no responsibility, liability for, or control over those other websites or Internet resources or their collection, use and disclosure of your personal data. Ahooga recommends that you review the privacy policies of those other websites, tools and Internet resources to understand how they collect and use personal data.

2. Data Processed by Ahooga
The categories of personal data which can be processed by Ahooga depend on the relation you have with Ahooga:
(a) If you are a customer

In a nutshell: you are using Ahooga’s services as a customer (for example you bought a Ahooga Bike).
Personal data processed: identification data you provided Ahooga in this context (your name, address, telephone number and email address) or data that Ahooga links to your purchase (bike serial number); payment information processed by a third party processor (Shopify) we engage with for the operation of the webshop (see point 4. of this Privacy Policy).
Purpose of the processing: performance of the Services (registering customer order, delivering the order, contacting the customer during/after the sale, yearly maintenance, traceability between bike serial number and bike owner in case of warranty recall, …).
Legal basis for the processing: processing is necessary for the performance of the Services.

(b) If you are a supplier or partner
In a nutshell: you are working together with Ahooga for business purposes (for example as a distributor, manufacturer, …)
Personal data processed: the personal data Ahooga processes will always involve your basic identity information such as name, e-mail address, postal address, telephone number, the company you work for and your function. We may also process other personal data you provide us with, dependent on our contractual relationship with you.
Purpose of the processing: to be able to execute and perform Ahooga’s end of the contract (including though not limited to doing our normal business administration (e.g. invoicing and relationship management).
Legal basis for the processing: when you as an individual are our supplier, we rely on the necessity of processing your personal data for executing and performing the contract we have with you. However, if you act on behalf of a company or other legal entity, we rely on our legitimate interest to be able to contract with suppliers and/or partners when processing your personal data.
(c) If you are a website visitor
In a nutshell: you are visiting our website, that uses Google analytics. When you are visiting our webshop, we rely on Shopify to ensure its proper functioning.
Personal data processed: Google Analytics relies on cookies to identify users through a tracking code (user ID). For this reason, cookies themselves are said to not contain any personally identifiable information. However, it is not impossible for Google to associate the user IDs with real-world identities. Hence, user IDs are classified as personal data under the GDPR. The information collected may include your IP address, login information, browser type, operating system, the full URLs, referring URLs and information on actions taken or interaction with our Services.
Shopify ensures the proper functioning of our e-shop. When you place an order and continue to payment, you are required to enter your payments details. Payment information is processed by Shopify in this respect (see section 4 of this Privacy Policy).
Purpose of the processing: help us analyzing how visitors use our website.
Legal basis for the processing: consent to use Google Analytics (see the cookie banner).

(d) If you subscribe to our newsletter
In a nutshell: you can provide us with your email address in order to receive our newsletter (for example you can fill in the newsletter form on our website).
Personal data processed: email address
Purpose of the processing: sending of our newsletter.
Legal basis for the processing: your consent (your consent can be removed at any time – just send us an email to hello@ahooga.bike).
The User undertakes to communicate correct personal data to Ahooga. The User can change provided personal data at any time. Ahooga cannot be held liable for any malfunctioning in the Services due to erroneous personal data communicated by the User or modifications to the User’s personal data by third-party management tools.
While we make every effort to ensure that your personal data is accurate, complete and up to date, you can help us considerably in this by promptly notifying us if there are any changes to your data by contacting our us as indicated under section 1 of the present Privacy Policy.
Users can’t disclose personal data to Ahooga about another person unless this person has given consent.

Ahooga will not collect any sensitive data from Users. This includes data such as: data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation. Ahooga will, if necessary, obtain your explicit consent to collect such data.

3. Your Rights
Under Applicable Data Protection Law, you may have certain rights regarding the personal data we process about you. We also offer you certain choices about what personal data we collect from you, how we use that data, and how we communicate with you.
You can choose not to provide personal data to us. You also may refrain from submitting data directly to us. However, if you do not provide your personal data when requested, or if you exercise your rights, you may not be able to benefit from the Services (as applicable), and we may not be able to provide you with information about Services.
You will find hereunder a list of the rights you have regarding the personal data we process about you:
(a) Withdrawal of consent
To the extent provided by Applicable Data Protection Law, you may withdraw any consent you previously provided to us, or object at any time to the processing of your personal data. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal data will mean that you cannot take advantage of certain Services.

(b) Right of access
In addition, you may have the right to request access to and receive copies of the personal data we process about you.
You may also receive information about the personal data we process about you, as well as ask to be informed regarding the recipients to whom your personal data has been disclosed. This includes recipients outside of the EEA (as provided under section 6 of the present Privacy Policy).

(c) Right to rectification
You have the right to request that we update (changing of email or postal address, for instance) and correct any inaccuracies (such as misspellings, etc.) in your personal data.

(d) Right to object to the processing
You have the right to object to the processing of your personal data. This is notably the case when we decide to process your personal data based on our legitimate interest. If we disagree with your objection, we will provide you with legitimate reasons why we should continue to process your personal data. The answer we provide to you in this regard is without prejudice of your right to file a complaint with your local Supervisory Authority or the lead Supervisory Authority (see section 1 above).

(e) Right to erasure
You have a right to request that we delete your personal data, as appropriate. Please note that we may turn down your request in specific circumstances (for example, when data retention is necessary for the exercise of freedom of expression and information, or for the establishment, exercise and defence of legal claims). The answer we provide to you in this regard is without prejudice of your right to file a complaint with your local Supervisory Authority or the lead Supervisory Authority (see section 1 above).

(f) Right to restriction of processing
You have a right to restrict the use we make of your personal data. As a consequence, we will not be able to further process your data.

(g) Right to data portability
You may also have a right to data portability, which implies that Ahooga can supply (at your request) your data to you and / or to a third party in a structured and machine-readable form.

Should you wish to exercise any of the rights referred to under points (a) to (g) above, please contact us as indicated under section 1 of this Privacy Policy.
The rights can be exercised free of charge unless the requests are manifestly unfounded or excessive. In the latter cases, Ahooga can either charge a reasonable fee or refuse the requested action.
We undertake to provide you with an answer within one (1) month upon receipt of your request. In some cases, we might need additional time to consider your request and need an extra two (2) months. We will inform you accordingly if this is the case.

4. Disclosure of Personal Data
Although Ahooga may transfer personal data to so-called business partners, consultants or other service providers for the performance of the Services (as applicable) or any other contract we enter into with them or you, we will not share data with third parties for secondary or unrelated purposes unless otherwise stated when collecting these data.

Recipients Ahooga may share collected personal data with are:
– Synapsis, for IT consultancy purposes;
– Business customers (resellers), in order to process orders;
– AKTI, Ahooga’s CRM;
– Wordpress and Shopify, for website functionality purposes;
– Calendly, Meetingbird, for different types of appointments;Mailchimp, for newsletter purposes.

When exploring our website, depending on your cookie preferences, your data will also be transmitted to our partner Qover SA/NV, an insurance agent offering bicycle insurance. We recommend that you read this partner’s provisions on the protection of personal data (https://www.qover.com/terms-and-policies#parentVerticalTab4) and their use of cookies (https://www.qover.com/terms-and-policies#parentVerticalTab2).

If Ahooga gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.

Where appropriate or required, Ahooga will be entitled to transmit personal data to law enforcement authorities, regulatory or other government agencies, or third parties where necessary or desirable to comply with legal or regulatory obligations or in the context of the above-mentioned purposes.

As the case may be, one or more of the above may be located outside of the EEA. Where applicable, your personal information will be processed in compliance with section 6 of the present Privacy Policy.

5. Retention Period
Ahooga does not store the data longer than legally admissible and in any case not longer than required for the purposes for which it was collected unless otherwise required or authorized by Applicable Data Protection Law. We take measures to delete or permanently de-identify your personal data if required by law or if your personal data is no longer required for the purpose for which we collected it.

The retention period is the following:
 All personal data we collect in the framework of our contractual relationship with you, are stored during the contractual period and at least until 7 years thereafter;
 In the case where you gave your consent to receive the newsletter/further communication, the data will be processed, and the newsletter will be sent, as long as you do not unsubscribe from the newsletter/remove your consent;
 When it comes to Google Analytics, Google removes cookie information after 18 months.

6. International Data Transfers
To offer and perform our Services, Ahooga may potentially need to transfer your personal data among several countries. The personal data that we collect from you may be transferred to, and stored at, a destination outside the EEA. Those countries may not have the same data protection laws as the country in which you initially provided the information. In case such transfer would be needed, we would take all steps reasonably necessary to ensure that your personal data is processed and treated securely and in accordance with this Privacy Policy and with the Applicable Data Protection Law.

7. Security of Data
The security of personal data is important to us. Ahooga shall take all reasonable and appropriate technical and organizational measures to protect the security, confidentiality and integrity of personal data. In particular, Ahooga will take appropriate measures to prevent any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or other digital assets, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not without any risks. The User consequently acknowledges that we cannot guarantee the security of her/his personal data to our website or other digital assets (such as our applications, tools, …); any transmission is at your own risk. We will however do our best efforts to protect your personal data once we have received it and will use strict procedures and security features to try to prevent unauthorized access.