See.Sense Fleet Tracker Project Privacy Policy and Terms for The Active Wellbeing Society

See.Sense contact details

Name: See.Sense (Limeforge Ltd)

Address: Sketrick House, 16 Jubilee Road, Newtownards, BT23 4YH

Phone Number: 02891 078353

E-mail: datacontroller@seesense.cc

The Active Wellbeing Society Contact Details

Name: The Active Welllbeing Society

Address: Hay Manor Hall, Redfern Road, Tyseley, Birmingham, B11 3BE

Phone Number:

E-mail: privacy@theaws.org

The type of personal information we collect and how we receive it.

When you use a bicycle equipped with a See.Sense Fleet Tracking unit, we will collect telemetry information which includes the GPS position and time. This allows us to understand journey details including duration, speed, braking, swerving, bicycle characteristics and road surface data.

See.Sense do not receive personal information about the rider of the bike, and are therefore unable to identify a specific person from the GPS records. Because GPS records attach to an individual bike this is still considered personal information as it can be assumed it relates to a single person (even though See.Sense do not know who that person is).

See.Sense may share the following information with The Active Wellbeing Society:

Number of trips taken
Total mileage travelled
CO2 savings compared to motorised vehicle journeys
An aggregate of all journeys taken on each bike, displayed as a heat map of journeys taken.

See.Sense do not share with The Active Wellbeing Society:

Individual journey details (eg: at 10am – 10:30am, Bike ID #2 travelled from A to B)

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information is your consent. You are able to remove your consent at any time. You can do this by contacting The Active Wellbeing Society at privacy@theaws.org

How See.Sense store your personal information

Your information is securely stored in data centres in Ireland and accessed securely from the UK.

We keep point level GPS data for 5 years. We will then dispose of your information by aggregating it with other data such that individual points are no longer distinguishable.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at datacontroller@seesense.cc if you wish to make a request.

Children under 16

See.Sense do not knowingly collect Personal Data online from children under 16. If you become aware that a child has provided See.Sense with Personal Data (by using a bicycle equipped with a GPS unit) without parental consent, please contact See.Sense or The Active Wellbeing Society. 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.

Governing Law

See.Sense 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.

The Active Wellbeing Society are a co-operative charity based in England.

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.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to See.Sense at datacontroller@seesense.cc or to The Active Wellbeing Society at complaints@theaws.org

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Changes to this Policy and Terms.

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

The latest version is always available at www.seesense.cc/page/pptaws

The Active Wellbeing Society’s general privacy policy is available at https://theaws.co.uk/privacy-policy/

This policy was last updated 28th April 2022.