Last modified: July 31, 2023
Effective date: August 1, 2023
We are Tenways. We respect your privacy and private life, but sometimes we need your Personal Data. In this privacy policy, we explain which data we use and how we save, protect and process these data.
If you are younger than sixteen years old, you cannot use our Website, Services and App without the permission of your parents or legal guardian.
To offer our Website, Services and App we process Personal Data and Non Personal Data. "Personal Data" means any information relating to an identified or identifiable natural person as defined in the Relevant Legislation. “Non- Personal Data” is information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity.
We can collect and process your data at various moments, for example when you visit our Website, create an account via our Website for example for making a purchase, use our Services, install and use our App or Rides feature, or when you contact us. The lawful basis for our processing can be:
the necessity to carry out the agreement between you and us,
compliance with legal obligations,
your consent,
our legitimate interests or the legitimate interests of a third party,
a legal requirement to share Personal Data.
When you use our Platform, we need the following contact data. We need these data for your interactions with Tenways via digital/electronic tools such as e-mail or telephone; for example to process your order efficiently and correctly, to connect you to your bike, for pre and post sale services, for the use of your account, to improve our services, for marketing purposes, and for any other business/commercial purposes:
Your name
Your address
Your residence
Your phone number
Your e-mail address
Your IP-address
Your payment details
Your shipping address
Your username and password
Your reference number
We may also collect and process the following Non-Personal Data if you use our Platform:
The type of your browser
The operating system that you use
The internet service provider
Website behaviour
We may also collect and process the following Non-Personal Data if you use our App. We use these data to provide support and improve our services:
Operating system & version
Type of Device
App version
Firmware version
Bike settings, e.g. Speed Limit, Total distance, Battery Level
User’s bike size, color, abnormal error codes
User’s order information, such as purchase time, price
After your explicit consent, you allow the App to collect and process Non-personal Bike event data from your bicycle, e.g. Distance, Speed, Battery level, Boost Behaviour, when you are using our Rides feature. We use these data to execute the feature, provide support, improve our services and products and for marketing purposes. The App does not share the Bike event data with third parties.
After your explicit consent, you allow the App to access Bluetooth and GPS data (each also called location data). The App allows you to use Bluetooth data locally on your telephone. The App does not share the location data with third parties. Tenways does not collect the location data on its servers, nor uses or shares it.
After your explicit consent, you allow the App or the Bike, or both, to use location data for explicitly specified features. The App does not share the location data with third parties. Tenways collects the location data on its servers and uses it for the execution of the feature.
You have the right to revoke the authorization you granted us to collect your private data collection. If you do not want us to continue to collect your riding data, you can contact us and we will immediately stop collecting all your data.
You can also request your personal data and we will send it to you free of charge within one month.
The purposes for which we process your personal data depend on how you enter in contact with us.
You contact us (e.g. by filling in a form on our website, by sending us an e-mail). We process your personal data in order to answer and manage your request (e.g. request for information, subscription to our newsletter, complaint). This processing is based on your consent.
You purchase Tenways products/services and you download the Tenways app:
We process your personal data for the purpose of client management, based upon the performance of the contract with you regarding the provision of the smart bike.
This includes the processing of your name/e-mail/bike reference/private key in order to activate your personal Tenways account and to start/stop the bike; the processing of the location of your bike in order to allow you to track and record the duration/distance/speed of the
rides with your bike; the processing of the information (including photos) you may send us in the context of our bike maintenance and reparation service; the processing of the location of your bike in the context of the bike retrieval functionality.
Aforementioned functionalities are essential characteristics inherent to our smart bikes, which are necessary in order to meet your expectations as user. Without your personal data, we cannot perform the contract with you. This processing may involve compiling a profile. This profiling has no effect on you, except to the extent that it allows you to benefit from the functionalities concerned.
We may process your personal information for our legitimate business interests.
Legitimate Interests' means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. It can and does also apply to processing which is in your interests too.
Processing for our legitimate interests may include processing for the purposes of :
fraud prevention and compliance;
certain direct marketing and promotional activities;
the provision and operation of referral marketing programmes;
network and information systems security;
data analytics;
enhancing, modifying or improving our service;
identifying usage trends;
determining the effectiveness of promotional campaigns or advertising.
In connection with the above activities, we may share your personal information with trusted suppliers who assist us in our data processing activities. For a list of our current suppliers with whom we share data and what they do with that data, please click here.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests -we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
You have the right to object to this processing if you wish and if you wish to do so please contact support@tenways.com
In any case
We may process your personal data for the management of compliance
and disputes (eg prevention/detection/sanctioning of unlawful activities and/or abuse of Tenways' resources, defense of legal claims), based on our legitimate interests. We believe that the management of compliance and disputes contribute to safeguarding and promoting our economic, commercial, social and financial interests. The processing may involve compiling a profile and has no effect on you, except in the context of management of compliance and disputes. We may anonymize your personal data and process aggregate data for research and development, based on our legitimate interests (eg statistics about sales, market analysis, statistics about the users and use of our products/services, development and improvement of our products/services). We believe that research and development can lead to enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services (such as customers, distributors, suppliers). Research and development may involve compiling a profile. All identifying elements, such as your name, your address, etc., are eliminated. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience, product improvement and innovation, which is an advantage for you.
The provision of your personal data for these purposes is a contractual
requirement but you can object to the processing by contacting support@tenways.com.
We observe reasonable procedures to prevent unauthorised access to, and the misuse of, Personal Data.
We use appropriate business systems and procedures to protect and safeguard the Personal Data you give us. We also use security procedures and technical and physical restrictions for accessing and using the Personal Data on our servers. Only authorized personnel are permitted to access Personal Data in the course of their work.
We do not sell, trade or share your data with others, nor do we make it public.
We will not retain your Personal Data longer than is legally allowed, and only as long as is necessary to enable you to use our Platform, including maintaining the online user account if created), to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All Personal Data we retain will be subject to this Privacy Policy.
Processors and other business partners
We may share your Personal Data with Processors, within the meaning of the Relevant Legislation. We may also share Personal Data with third parties who are not processors, as per contractual obligation, for example, other Controllers who provide services connected to the use of our Platform. With these parties, we make clear agreements about the use and protection of Personal Data. We may share your Personal Data for example with IT service providers, marketing analytics, advertising platforms, payment platforms, cloud based data warehousing, lease companies and consumer review platforms. They will, for example, store and visualize data, process transactions, and perform marketing activities.
Others, for legal reasons
We may also share data with Tenways affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. We may also share Personal Data if we believe it is required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
Others, with your consent
We may ask for your voluntary participation in online or offline communication about Tenways, for marketing or informational purposes.
The Personal Data that we collect from you is stored within the European Economic Area (“EEA”), but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your Personal Data will be carried out in compliance with applicable laws.
You may find advertising or other content on our Website that link to other websites. We do not control the content on these websites and are not responsible for the content or the privacy protection of these websites. We advise you to read the privacy policies of those websites.
A cookie is a text file that is placed by the server of a website on your computer or on your mobile device when you consult that website. The cookie contains a unique code that allows recognizing your browser during the visit of the website (a so-called “session cookie”) or later repeated visits (a so-called “persistent cookie”).
Cookies can be placed by the server of the website you visit or by partners this website collaborates with. The server of a website can only
read the cookies he has placed. That server has no access to other information on your computer or mobile device.European Union will be understood as consent to the updates to the extent permitted by law.
Cookies can be essential for the operation of our Website, make sure that you can visit our Website safely and track bugs and errors at our Website. We may use cookies to improve your user experience on our Website.
Keypad-friendly cookies
They make automatic text proposals (identification, address, passwords, …)
Statistical or analytical cookies
They collect information about the use of the website to improve its operation.
Cookies origin of the visit
The website administrator can know the origin of the visit (e.g. search on search engine).
Visit and follow-up cookie
They allow to follow the surfing route on the website.
Tracking cookies
They are used by third parties to check the browsing behaviour of the internet user. This information allows advertisers to adjust their advertising based on the habits of the Internet user.
Advertising cookies
Advertisements by banners can also store cookies. They also contain information about the user's browsing behaviour and aim to offer him advertising that falls within their area of interest.
(e) Reference cookies
Third parties providing additional services (e.g. the social networking icons on an online shopping site, provide those social networks access to the list of purchases from the Internet user by using the reference cookies).
Multimedia carrier cookies
They make multimedia easier to play.
Content sharing cookies
Social networks offer buttons for content sharing.
You may request access to the Personal Data we process about you;
You may request us to correct, update, shield or delete your personal information in our records;
You may request a copy of the Personal Data we have processed about you. We can - on your request - send this copy to another party, so you don't have to send the Personal Data yourself;
You may file a complaint against processing your Personal Data;
You may file a complaint with the European Data Protection Authority (EDPA) if you are under the impression that we process your data unlawfully;
You may always withdraw your consent to process your Personal Data. In that case, we will no longer process your Personal Data for the purpose for which consent is necessary.
We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Platform or through other means, such as e-mail. We encourage users to periodically review this notice for the latest information on our privacy practices.
After such notice, the use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.
If you have any questions or suggestions regarding our Privacy Policy, please contact us support@tenways.com. Please allow up to four weeks for us to reply.