Privacy Policy

Privacy Policy

This Privacy Policy sets out how we, Avaris Cycling Ltd, collect, store and use information about you when you use or interact with our website and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 01/05/2018.

Contents

  • Summary
  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • Information we collect when you interact with our website
  • Information we collect when you place an order on our website
  • How we collect or obtain information about you from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Sensitive Personal Information
  • Changes to our Privacy Policy
  • Children’s Privacy
  • Copyright, credit and logo

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: Avaris

How we collect or obtain information about you:

When you provide it to us (e.g. by contacting us, placing an order on our website, consenting to be sent marketing materials or signing up for our newsletter), from your use of our website, using cookies.

Information we collect: 

Name, contact details, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, company name or business name (if applicable), VAT number (if applicable).

How we use your information: 

For administrative and business purposes (particularly to process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to analyse

your use of our website, and in connection with our legal rights and obligations.

Disclosure of your information to third parties: 

Only to the extent necessary to run our business, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.

Do we sell your information to third parties (other than in the course

of a business sale or purchase or similar event): 

No

How long we retain your information: 

For no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

How we secure your information: 

Using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.

Use of cookies: 

We use cookies on our website. For more information, please visit our cookies policy.

Transfers of your information outside the European Economic Area: 

In certain circumstances we transfer your information outside of the European Economic Area. Where we do so, we will ensure appropriate safeguards are in place. 

Use of automated decision making and profiling: 

We do not use automated decision making or profiling. Your rights in relation to your information to access your information and to receive information about its use to have your information corrected and/or completed to have your information deleted to restrict the use of your information to receive your information in a portable format to object to the use of your information to withdraw your consent to the use of your information to complain to a supervisory authority.

Sensitive personal information: 

We do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is: 

Andrew Forrest of Avaris Cycling Ltd, 
Oaklands House, 
Church Street, 
Barrowford, 
Nelson, 
England
BB9 6QU

You can contact the data controller in writing or by sending an email to [email protected].

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website.

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

Our server is located in the Republic of Ireland. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Use of website server log information for IT security purposes

Our web server collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make any attempt to identify you from the information collected via server logs.

Legal basis for processing: 

Compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: 

We have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals.

Recording access to our website using server log files is such a measure.

Legal basis for processing: 

Our and Amazon’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: 

We have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, and analytical. For further information on how we use cookies, please see our cookies policy.

You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit All About Cookies or see our Cookies Policy.

Information we collect when you contact us.

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legal Legitimate interest(s): 

Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: 

Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6 (1)(b) of the General Data Protection Regulation).

Legal Reason why necessary to perform a contract: 

Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

We use a third-party email provider to store emails you send us. Our third-party email provider is Microsoft whose servers are located in United Kingdom. Their privacy policy is available here.

Contact form

When you contact us using our contact form, we collect your name, email address, and subject of your enquiry.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest(s): 

Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: 

Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 

Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

Messages you send us via our contact form will be stored within the European Economic Area on our ERP provider’s servers in the Netherlands.

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.

We do not record phone calls.

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest(s): 

Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: 

Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 

Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service provider.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest(s): 

Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: 

Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract:
Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Information we collect when you interact with our website.

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news, offers and promotions from us by giving your consent during the checkout process, or by opting-in via the My Account page on our website.

Legal basis for processing: 

Your consent (Article 6 (1)(a) of the General Data Protection Regulation).

Consent: 

You may give your consent to us sending you our e-newsletter while  signing up to receive it using the steps described above. We will only process your data according to your consent. 

Transfer and storage of your information

We use a third-party service to send out our e-newsletter and administer our mailing list, Klaviyo. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our Klaviyo’s servers in the UK. 

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates.

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy. For more information about our third-party mailing list provider and they use web beacons, please see their privacy policy.

Registering on our website

When you register and create an account on our website, we collect the following information: Name, Address, Contact Details and any other information you provide to us when you complete the registration form, including any optional information, such as telephone numbers, company name and VAT registration number/status.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website. If you do not supply the optional information requested by our registration form, such as phone number we will not be able to respond to your enquiry by phone.

Legal basis for processing: 

Necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 

Creating an account on our website is necessary to allow you to access the goods and services you have purchased from us.

Information we collect when you place an order on our website.

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order.

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), VAT number (if applicable).

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: 

Necessary to perform a contract (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 

We need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment, we use a third-party payment processor, Stripe . Your payment will be processed by Worldpay via their secure payment gateway.

 Stripe collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies here.

Transfer and storage of your information

Worldpay is located in the United Kingdom. Information relating to the processing of your payment is stored within the European Economic Area on our Worldpay’s servers in the United Kingdom.

Legal basis for processing: Necessary to perform a contract (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 

To fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

Our similar goods and services

You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by using the unsubscribe link in our emails or by adjusting your marketing preferences on the My Account page of our website.

We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interests: 

Direct marketing and advertising our products and services.

Transfer and storage of your information

We use a third-party service to administer our mailing list, Mailchimp. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our Mailchimp’s servers in the USA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates.

For more information on how we use web beacons in our emails, see our cookies policy. For more information about our third-party mailing list provider and they use web beacons, please see their privacy policy.

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email, text message, phone, or post by granting your consent during our checkout process.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: 

Consent (Article 6 (1)(a) of the General Data Protection Regulation).

Consent: 

You give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third-party service to administer our mailing list, Mailchimp. Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on Mailchimp’s servers in the USA. 

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates.

For more information on how we use web beacons in our emails, see our cookies policy.

For more information about our third-party mailing list provider and they use web beacons, please see their privacy policy which is available on Klaviyo’s privacy policy page.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third

parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business. Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: 

Legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: 

Where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: 

Necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 

We may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as:

Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, EXCLUDING IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. 

To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please visit Google’s partner privacy page.

Mention Me

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 (i) fraud prevention and compliance; (ii) certain direct marketing and promotional activities; (iii) the provision and operation of referral marketing programmes; (iv) network and information systems security; (v) data analytics; (vi) enhancing, modifying or improving our service; (vii) identifying usage trends; or (viii) 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) 

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest(s): 

Meeting our contractual obligations to Google under our Google Analytics Terms of Service You can opt out of Google Analytics by installing the browser plugin on Google’s tools page.

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, insurers, and fellow Group Companies.

Further information on each of these third parties is set out below.

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest: 

Running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Our accountants are Azets. Our accountants are located in England.

Advisors

Occasionally, we obtain advice from advisors, such as lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services. Our business partners are in the same market sectors as our ourselves and are based in the EEA.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function, we have hired them perform in relation to our business. 

Our independent contractors, who may have access to your information are based in the Finance, IT, HR or Operations sectors and are based in England.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our insurers are Backhouse Insurance Brokers Limited. Our insurers are located in England.

Group Companies

Sharing your information within our business’ group of companies, including Attwood Digital limited and its subsidiaries, which are all located in England for internal administrative purposes, including client, customer and employee information.

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest: 

Running and managing our business effectively.

Legal basis for processing: Necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6 (1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: 

We need to share your information with other companies in order to be able to meet our contractual obligations to you [or to take steps at your request prior to entering a contract.], for example because of the services or information you have requested.

We do not display the identities of all of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: 

Legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest(s): 

Sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties. 

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way. Legal basis for processing: our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interests: 

Preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. 

Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation). 

Legitimate interest: 

Enforcing our legal rights and taking steps to enforce our legal rights. 

In connection with a legal or potential legal dispute or proceedings 

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: 

Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest(s): 

Resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: 

Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): 

Legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed). 

Legal basis for processing: Our legitimate interests (Article 6 (1)(f) of the General Data Protection Regulation).

Legitimate interest: Where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information.

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Order information: 

When you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: 

When you make an enquiry or correspond with us for any reason, we will retain your information for as long as it takes to respond to and resolve your enquiry, after which point, we will delete your information.

E-Newsletter: 

We retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods.

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future); 
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
  • only transferring your information via closed system or encrypted data transfers Transmission of information to us by email Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third-party mailing list provider’s servers. 

Our third-party mailing list provider is: 

Klaviyo. You may access their privacy policy page.

Country of storage:

UK

Safeguard(s) used: 

Our third-party mailing list provider has incorporated the European Commission’s Standard Contractual Clauses. 

Google Analytics 

Information collected by Google Analytics (actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. Access Google’s privacy policy page.

Country of storage: 

United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: 

Google relies on Standard Contractual Clauses (SCCs) for transfers of online advertising and measurement personal data out of Europe. For more information please check: https://policies.google.com/privacy.

https://eur-lex.europa.eu/eli/reg/2016/679/oj Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to 

Avaris Cycling Ltd, 
Oaklands House, 
Church Street, 
Barrowford, 
Nelson, 
England,
BB9 6QU 

or sending an email to [email protected]:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third-party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. 

Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO).

Further information on your rights in relation to your personal data as an individual, the above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit their GDPR guide and their information policy.

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation.

Verifying your identity where you request access to your information Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information. 

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to:

Avaris Cycling Ltd,
Oaklands House, 
Church Street, 
Barrowford, 
Nelson, 
England,
BB9 6QU 

or sending an email to [email protected]:

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing). 

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • opting out via the website using the my account section of the website. For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us. If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time. 

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [email protected].

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.