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Mobile Application Privacy Policy

INTRODUCTION


See.Sense exists to make cycling better for everyone. We bring See.Sense Technology and cyclists together to improve journeys for everyone. Our vision is a world where more people cycle more often.


We would ask that you please review the following Privacy Policy carefully to ensure you are fully aware of the implications of using our services.


See.Sense products and mobile applications are provided to you by Limeforge Ltd. (”us” or ”we” or ”our” or ”See.Sense”). The terms and conditions set forth below, as well as the privacy policy set forth at https://seesense.cc/pages/mobile-app-privacy-policy, apply to your use of the services and functionality provided on or through any of the See.Sense products (including both consumer and Smart Cities products) and/or mobile applications (the ”services”). By accessing and using the services, you acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions and the Privacy Policy. If you do not accept these Terms and Conditions and the Privacy Policy, you are not authorised to use the services. This document was written in English. To the extent a translated version of these Terms conflict with the English version, the English version controls.


The services are intended solely for persons who are 16 years old or older. If you are under the legal age to form a binding contract in your jurisdiction, you represent that your legal guardian has reviewed and agreed to these Terms.


DATA COLLECTION SERVICE


When you sign up to a mobile account, including opting in to sharing ride insights, then we will collect information whenever you use your See.Sense product in conjunction with the official See.Sense mobile application. We collect data pertaining to your environment when cycling, as well as your behaviour as you respond to this environment. This includes information that can help us to detect where accidents/near miss events occur and specific locations where potholes may form. As this can include location data, we consider this information to be personal data. The See.Sense mobile application gives the user the option to set privacy zones within which no data will be collected. It is recommended that the user include their home within their privacy zones. We will also collect some personal information in the signing up process, such as name, email address and demographic data.


You may choose not to provide us with your Personal Data. However, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services.


YOUR RIGHTS


We take steps to keep your Personal Data accurate and up to date. If you reside in the European Economic Area, you have certain rights to the Personal Data that we have collected about you. To exercise your rights to your Personal Data, please contact us through our Support Team or at the address listed below. Subject to applicable law and in exceptional circumstances only, we may charge for this service and we will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.


You have the following rights:
Right of access to your Personal Data (Article 15 GDPR): You have the right to ask us for confirmation on whether we are processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved).

Right to correction (Article 16 GDPR): You have the right to have your Personal Data corrected, as permitted by law.


Right to erasure (Article 17 GDPR): You have the right to ask us to delete your Personal Data, as permitted by law. This right may be exercised among other things: (i) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) when you withdraw consent on which processing is based according to Article 6 (1) (a) or Article 9 (2) (a) GDPR and where there is no other legal ground for processing; (iii) when you object to processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to Article 21 (2) GDPR; or, (iv) when your Personal Data has been unlawfully processed.


Right to restriction of processing (Article 18 GDPR): You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your Personal Data is contested; when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead; or when you have objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of Under Armour override your grounds.


Right to data portability (Article 20 GDPR): You have the right to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.


Right to object (Article 21 GDPR): You have the right to object to our processing of your Personal Data, as permitted by law. This right is limited to processing based on Article 6 (1) (e) or (f) GDPR, and includes profiling based on those provisions, and processing for direct marketing purposes. After which, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.


LEGAL BASIS FOR PROCESSING


In this section we provide information on the legal basis for our processing of your Personal Data as required by Article 13 and 14 of the GDPR:


  • When you register for an account or interact with our Services, such processing is necessary for the performance of our Services, Article 6 (1) (b) GDPR.
  • When you use or interact with a wearable or other connected device. For sensitive data (including health data and biometric data) as defined in the GDPR, we process such data on the basis of your prior consent, Article 9(2)(a) GDPR.
  • For non-sensitive Personal Data which we need in order to perform the Services, such processing is necessary for the performance of our Services, Article 6 (1) (b) GDPR. With regard to other non-sensitive Personal Data, we process such data on the basis of our legitimate interest, Article 6 (1) (f) GDPR, and our legitimate interest is to enhance our Services.
  • When we collect precise Location Data following your prior consent, we process such data on the basis of your prior consent, Article 6(1)(a) GDPR. In other cases where we process your Location Data without consent, for example in order to provide our Services, such processing is necessary for the performance of our Services, Article 6 (1) (b) GDPR.

CHILDREN UNDER 16


We do not knowingly collect Personal Data online from children under 16. If you become aware that a child has provided us with Personal Data without parental consent, please contact us. If we become aware that a child under 16 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel the child's account.


DATA SHARING


See.Sense use the data we collect to operate our business and provide our products and services to our partners. Data collected via our application will be used primarily for the purposes of providing analysis that will allow for the improvement of cyclist safety and infrastructure as a whole.


In particular, we will share some the data we collect from you with British Cycling who will analyse the data in order to draw anonymous, aggregated conclusions and inferences about cycling habits and activities in the United Kingdom. British Cycling is registered with the Information Commissioner’s Office as a data controller in its own right under registration number Z1066209. If you have any questions about British Cycling’s use of this data, please contact their Data Protection Officer at dataprotection@britishcycling.org.uk.


This data is anonymous, aggregate, de-identified or otherwise does not reveal your identity. We also work with partners and third parties. These third parties may have access to or process your data but only to the extent it is necessary for them to provide their products and services to us. For example we may share information regarding where the collision hot spot areas of a city are with local councils or city planners.

Personal information collected during sign-up may be used to personalise our advertising and marketing activities, support our analysis and communicate with you and respond to your requests. We do not sell, trade or otherwise transfer any personal information to third parties without your permission. We will only otherwise share your personal data with third parties if required to under our obligations to the relevant Government Bodies, or as it is necessary to provide a service or feature that you have requested.


GOVERNING LAW


We are a Northern Ireland based company. These terms and conditions are governed by and shall be construed in accordance with the laws of Northern Ireland. The parties to these terms submit to the exclusive jurisdiction of the courts of Northern Ireland. Furthermore, any action to enforce these terms and conditions shall be brought in the Courts of Northern Ireland. You hereby agree to personal jurisdiction by such courts, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.


INDEMNIFICATION


You agree to indemnify See.Sense, its contractors, licensors, partners, clients and supporters and their respective directors, officers, employees and agents from and against any and all claims and expenses, including attorneys fees, arising out of your use of any See.Sense services and your use of a bicycle or any experience or incident you have with a bicycle or a cyclist. You cycle at your own risk and you are responsible for ensuring that the bicycles you ride are in a roadworthy condition. You are responsible for observing the rules of the road and cycling in a safe and careful manner.


DATA PROTECTION REGISTER


We are registered with the Information Commissioner’s Office under the registration number ZA154193. If you have any queries please email datacontroller@seesense.cc.


CHANGES TO TERMS AND CONDITIONS


We reserve the right to change the Terms and Conditions and Privacy Policy without notice. You acknowledge and agree that it is your responsibility to review the Terms and Conditions and Privacy Policy periodically to familiarise yourself with any modifications. Your continued use of the Services after such modifications will constitute acknowledgement and agreement of the modified Terms and Conditions and the Privacy Policy.


TERMINATION OF USE


We reserve the right to terminate your usage of these service for any reason, including, without limitation, breach of these Terms and Conditions. You may also choose to refrain from using the services at any time.


ANY QUESTIONS...?


If you have any issues or questions please consult our FAQ’s page on our website or email us (datacontroller@seesense.cc).

JOIN THE RIDE

By signing up you agree to our T&Cs and that you have read our Privacy Policy