FREESKY eBike EU | Privacy Policy

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What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly from You

Information that you directly submit to us through our Services may include:
• Basic contact details including your name, address, phone number, email.
• Order information including your name, billing address, shipping address, payment confirmation, email address, phone number.
• Account information including your username, password, security questions.
• Shopping information including the items you view, put in your cart or add to your wishlist.
• Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect through Cookies

We also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels, and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address, and other information regarding your interaction with the Services.

In accordance with the GDPR, we will obtain your consent for the use of non-essential cookies (e.g., analytics and advertising cookies) before placing them on your device. You can manage your cookie preferences through the cookie consent banner or your browser settings.

Information We Obtain from Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:
• Companies who support our Site and Services, such as Shopify.
• Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third Party Websites and Links.

How We Use Your Personal Information

Providing Products and Services. We use your personal data to provide you with the Services in order to perform our contract with you, including processing your payments, fulfilling your orders, sending notifications related to your account, purchases, returns, exchanges, or other transactions, creating, maintaining, and managing your account, arranging for shipping, facilitating returns and exchanges, and enabling you to post reviews.

• Marketing and Advertising. We use your personal data for marketing and promotional purposes, such as sending marketing, advertising, and promotional communications by email, text message, or postal mail, and showing you advertisements for products or services. This may include using your personal data to better tailor the Services and advertising on our Site and other websites.

• Security and Fraud Prevention. We use your personal data to detect, investigate, or take action regarding possible fraudulent, illegal, or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.

• Communicating with you. We use your personal data to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, provide effective services to you, and maintain our business relationship with you.

Cookies

Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve, and optimize the Services). We may also permit third parties and service providers to use Cookies on our Site to better tailor the services, products, and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:
• With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment, and shipping).
• With business and marketing partners, including Shopify, to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
• When you direct, request us, or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
• With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants, and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We have, in the past 12 months, disclosed the following categories of personal information and sensitive personal information (denoted by *) about users for the purposes set out above in "How we Collect and Use your Personal Information" and "How we Disclose Personal Information":

Categories of Recipients

• Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners, and data analytics providers)
• Business and marketing partners
• Affiliates

Sensitive Personal Information

We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you.

User-Generated Content

The Services may enable you to post product reviews and other user-generated content. If you choose to submit user-generated content to any public area of the Services, this content will be public and accessible by anyone.

We do not control who will have access to the information that you choose to make available to others and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use, or misuse of any information that you disclose or receive from third parties.

Third Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated with or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of the information found on these sites.

Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children's Data

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

In compliance with the General Data Protection Regulation (GDPR), our Services are not directed at children under the age of 16 (or a lower age where permitted by local law, but no less than 13). We do not knowingly process personal data of children under this age without verifiable parental consent. If we become aware that we have collected personal information from a child without appropriate consent, we will take steps to delete such information as required by law.

Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

In compliance with the General Data Protection Regulation (GDPR), we retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. When determining the appropriate retention period, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, legal and regulatory requirements, and whether we need to retain the information for legitimate business purposes. Once the retention period expires, we securely delete or anonymize your personal data in accordance with GDPR requirements.

Your Rights and Choices

Depending on where you reside in the European Union, you may have certain rights under the General Data Protection Regulation (GDPR) regarding your personal information. These rights are not absolute and may only apply in specific circumstances. We may decline your request as permitted by law.

Right to Access – You have the right to request access to the personal information we hold about you, including details of how we process and share it.
Right to Erasure ("Right to be Forgotten") – You may request that we delete your personal information, subject to legal and regulatory retention requirements.
Right to Rectification – If your personal information is inaccurate or incomplete, you have the right to request that we correct or update it.
Right to Data Portability – In certain circumstances, you have the right to receive a copy of your personal data in a structured, commonly used format and request its transfer to another service provider.
Right to Restrict Processing – You may ask us to restrict the processing of your personal data in certain situations, such as if you contest its accuracy or object to its processing.
Right to Object – You have the right to object to processing based on our legitimate interests, including direct marketing.
Right to Withdraw Consent – If we process your personal data based on your consent, you have the right to withdraw it at any time.
Automated Decision-Making & Profiling – You have the right not to be subject to automated decisions that significantly affect you, unless such processing is necessary for contractual purposes or based on your explicit consent.

You can exercise these rights by using the designated options on our Site or by contacting us using the details provided below. If you are not satisfied with how we handle your request, you have the right to lodge a complaint with your local data protection authority.

We may need to verify your identity before processing your request. You may also appoint an authorized representative to make a request on your behalf, in which case we will require proof of authorization.

Complaints

If you have any complaints regarding how we process your personal information, please contact us using the contact details provided below.

If you are not satisfied with our response, you may have the right to appeal our decision by reaching out to us again or lodging a complaint with your local Data Protection Authority (DPA). A list of EU DPAs and their contact details can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

International Users

Please note that we may transfer, store, and process your personal information outside the country you live in, including the United States. Your personal information may also be processed by our staff, third-party service providers, and partners in these countries.

If we transfer your personal information out of the European Economic Area (EEA), we will ensure appropriate safeguards are in place as required under the General Data Protection Regulation (GDPR). This includes relying on European Commission-approved Standard Contractual Clauses (SCCs) or transferring data to countries that have been granted adequacy decisions by the European Commission.

Contact

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to exercise your data protection rights, you may contact us via email at serve.eu@freeskycycle.com or by writing to us at:

Hong Kong Yan Shan Trading Co., Ltd.
Room 02, 21/F, Hip Kwan Commercial Building,
38 Pitt Street, Yau Ma Tei Street, Kowloon,
Hong Kong SAR.

You also have the right to lodge a complaint with your local data protection authority within the European Economic Area (EEA) if you believe that your personal information has been processed in a way that does not comply with General Data Protection Regulation (GDPR).

Collecting Personal Information

When you visit our Site, we collect certain information about your device, interactions with the Site, and necessary details for processing your purchases. If you contact us for customer support, we may collect additional information. In this Privacy Policy, "Personal Information" refers to any data that can uniquely identify an individual. Below is a detailed breakdown of the information we collect and why.

Device Information

• Examples of Personal Information collected: Web browser version, IP address, time zone, cookie data, pages/products viewed, search terms, and interactions with the Site.
• Purpose of collection: To ensure accurate Site loading and analyze user interactions to improve the Site.
• Source of collection: Automatically collected via cookies, log files, web beacons, tags, and pixels.
• Disclosure for a business purpose: Shared with our processor, Shopify.

Order Information

• Examples of Personal Information collected: Name, billing address, shipping address, payment details (including credit card numbers [INSERT OTHER PAYMENT TYPES ACCEPTED]), email, and phone number.
• Purpose of collection: To fulfill our contract by processing payments, arranging shipping, providing invoices and order confirmations, communicating with you, screening orders for fraud risk, and—when aligned with your preferences—sending product/service updates or promotions.
• Source of collection: Directly collected from you.
• Disclosure for a business purpose: Shared with our processor, Shopify.

Customer Support Information

• Purpose of collection: To provide customer support.
• Source of collection: Directly collected from you.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:
• We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful request for information we receive, or to otherwise protect our rights.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative's ("NAI") educational page at: http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt-out of targeted advertising by:
• FACEBOOK - https://www.facebook.com/settings/?tab=ads
• GOOGLE - https://www.google.com/settings/ads/anonymous
• BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal information to provide our services to you, including:

Offering Products for Sale: We utilize your personal information to display, promote, and sell products that match your preferences and browsing history.
Processing Payments: Your personal information is used to securely process payments for the products you order, including billing and shipping information.
Shipping and Fulfillment of Orders: We use your personal information to arrange for the shipment and delivery of the products you purchase, including coordinating with shipping partners.
Keeping You Informed: We use your personal information to send you updates about new products, services, offers, and promotions that we believe may interest you.

In accordance with the General Data Protection Regulation (GDPR), we ensure that the processing of your personal data is lawful, fair, and transparent. You have the right to request access, correction, deletion, and to object to the processing of your personal data at any time.

Lawful basis

Pursuant to the General Data Protection Regulation ("GDPR"), if you are a resident of the European Economic Area ("EEA"), we process your personal information under the following lawful bases:

Your Consent: We process your personal information based on your explicit consent, which you provide when you interact with our services or when you sign up for marketing communications.
The Performance of the Contract: We process your personal information when necessary to fulfill the contract we have with you, such as when you make a purchase or create an account.
Compliance with Legal Obligations: We process your personal information to comply with legal obligations, such as tax and accounting requirements, or when responding to lawful requests from authorities.
To Protect Your Vital Interests: In certain situations, we may process your personal information to protect your vital interests, such as in cases of medical emergencies or to safeguard your safety.
To Perform a Task Carried Out in the Public Interest: We may process your personal information for tasks that are carried out in the public interest or in the exercise of official authority, if applicable.
For Our Legitimate Interests: We process your personal information for our legitimate business interests, provided that these interests are not overridden by your rights and freedoms. For example, we may process your information for marketing, fraud detection, and improving our services.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. Under the General Data Protection Regulation (GDPR), we retain your data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, such as processing your order, providing customer support, and complying with legal obligations.

If you wish to request the erasure of your personal information, please refer to the 'Your Rights' section below for more details on how to exercise this right.

We may retain certain data even after you request its deletion, where necessary, for legal, regulatory, or legitimate business purposes, such as preventing fraud or complying with tax laws.

Automatic decision-making

If you are a resident of the European Economic Area (EEA), you have the right to object to processing based solely on automated decision-making, including profiling, when such processing has a legal effect on you or significantly affects you.

We do not engage in fully automated decision-making that has a legal or otherwise significant effect on our customers.

However, our processor Shopify employs limited automated decision-making to prevent fraud. This type of processing does not have a legal or significant effect on you.

Examples of automated decision-making used by Shopify include:

Temporary denylist of IP addresses linked to multiple failed transactions (persisting for a few hours).
Temporary denylist of credit cards associated with denylisted IP addresses (persisting for a few days).

Selling Personal Information

We do not sell your Personal Information as defined under the General Data Protection Regulation (GDPR). However, we may share your information with third-party service providers for purposes such as analytics, marketing, and advertising, in accordance with applicable privacy laws.

If you are a resident of the European Economic Area (EEA), you have the right to opt out of certain data sharing practices. Please refer to the Your Rights section to learn how you can manage your preferences.

Your rights

GDPR

If you are a resident of the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR) regarding your Personal Information:

Right to Access – Request access to the Personal Information we hold about you.
Right to Data Portability – Request a copy of your Personal Information in a structured, commonly used, and machine-readable format for transfer to another service.
Right to Rectification – Request that we correct or update any inaccurate or incomplete Personal Information.
Right to Erasure ("Right to be Forgotten") – Request that we delete your Personal Information, subject to legal obligations.
Right to Restrict Processing – Request that we temporarily or permanently stop processing your Personal Information.
Right to Object – Object to our processing of your Personal Information for direct marketing or where our processing is based on legitimate interests.
Right to Withdraw Consent – Withdraw consent at any time if processing is based on your consent.

If you wish to exercise any of these rights, please contact us using the details provided below.

Your Personal Information is initially processed within the EEA (primarily in Ireland). If data is transferred outside of the EEA (e.g., to Canada or the United States for storage and further processing), we ensure that appropriate safeguards are in place, such as European Commission Standard Contractual Clauses (SCCs) or transfers to jurisdictions deemed to provide an adequate level of data protection.

For more information on how Shopify ensures GDPR-compliant data transfers, please refer to Shopify’s GDPR Whitepaper.

Cookies

When you visit our Site, a small amount of data (known as a cookie) is downloaded to your computer or device. We use different types of cookies to enhance your browsing experience and provide our services. These include:

Essential Cookies – Necessary for the basic functionality of the Site, such as secure login and order processing.
Performance Cookies – Help us analyze site traffic and user behavior to improve functionality.
Advertising Cookies – Used to deliver relevant advertisements and measure marketing performance.
Social Media & Content Cookies – Enable content sharing via social media platforms and enhance media interactions.

Cookies enhance your experience by remembering preferences (such as language and region settings), reducing the need to re-enter information, and tracking engagement for optimization.

Under GDPR, we obtain your consent before placing non-essential cookies. You can manage your preferences via our Cookie Settings or adjust your browser settings to disable cookies.

Cookies Necessary for the Functioning of the Store

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
cart	Used in connection with shopping cart.
cart_sig	Used in connection with checkout.
cart_ts	Used in connection with checkout.
checkout_token	Used in connection with checkout.
secret	Used in connection with checkout.
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

Reporting Analytics

Name	Function
_tracking_consent	Tracking preferences.
_landing_page	Track landing pages
_orig_referrer	Track landing pages Shopify analytics.
_S	Shopify analytics.
_shopify_s	Shopify analytics.
_shopify_sa_p	Shopify analytics relating to marketing & referrals.
_shopify_sa_t	Shopify analytics relating to marketing & referrals.
_shopify_y	Shopify analytics.
-y	Shopify analytics.

[INSERT OTHER COOKIES OR TRACKING TECHNOLOGIES THAT YOU USE]

The duration of a cookie on your device depends on whether it is a session cookie (which expires once you close your browser) or a persistent cookie (which remains until deleted or expires). Most of our cookies are persistent and expire within 30 minutes to two years from download.

You can manage cookies through your browser settings, typically found under "Preferences" or "Tools." For more details on how to control cookies, visit www.allaboutcookies.org.

Please note:

Disabling cookies may affect website functionality and limit access to certain features.
Blocking cookies does not necessarily prevent all data sharing with third parties, such as advertising partners. To manage data use by these parties, refer to the "Behavioural Advertising" section above.

Do Not Track

Please note that due to the lack of a standardized industry approach to handling "Do Not Track" (DNT) signals, our website does not alter its data collection and processing practices when such signals are detected from your browser.

However, you can manage your privacy preferences by adjusting your browser settings or using opt-out options provided in the "Behavioural Advertising" section above.

Changes

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, operational adjustments, legal requirements, or regulatory updates.

When we make significant changes, we will notify you by updating the date at the top of this page and, where required by law, providing additional notice (such as via email or a notice on our website).

We encourage you to review this Privacy Policy periodically to stay informed about how we handle your Personal Information.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please.
Contact us by e-mail at serve.eu@freeskycycle.com, Room 02, 21st Floor, Hip Kwan Commercial Building, 38 Pitt Street, Yau Ma Tei, Kowloon, Hong Kong.

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Recommendations

Privacy Policy

What Personal Information We Collect

Information We Collect Directly from You

Information We Collect through Cookies

Information We Obtain from Third Parties

How We Use Your Personal Information

Cookies

How We Disclose Personal Information

Category

Categories of Recipients

Third Party Websites and Links

Children's Data

Security and Retention of Your Information

Your Rights and Choices

Complaints

International Users

Contact

Collecting Personal Information

Sharing Personal Information

Behavioural Advertising

Using Personal Information

Lawful basis

Retention

Automatic decision-making

Selling Personal Information

Your rights

GDPR

Cookies

Cookies Necessary for the Functioning of the Store

Reporting Analytics

Do Not Track

Changes

Contact