- How We Collect and Use Personal Data
- How We Share Personal Data We Collect
- Our Data Security and Storage Practices
- How We Store and Transfer Your Personal Data
- Your Choices Regarding the Use of Your Personal Data
- Minors’ Personal Data
- How You Can Contact Us
We have tried to keep this policy as simple and easy-to-read as possible. If you have any questions, please contact us at firstname.lastname@example.org.
1. How We Collect and Use Personal Data
1.1 We Collect Personal Data When You Use Our Website
When you use our website, we may collect a variety of personal data from or about you to provide services to you. For example,
- When you purchase Urtopia’s products from our website, we will collect and use your name, phone number, address, e-mail address to fulfill your request for products, or to send you notifications, confirmations, updates, product announcements, and security alerts. We may also use such personal data to create an account for you. If you are a resident of European Economic Area (“EEA”), we process such data on the basis of Article 6.1(b) of the General Data Protection Regulation (“GDPR”), i.e., necessary for the performance of a contract.
- When you register on the mailing list or for our newsletter, your email address will be added to our contact list. If you are a resident of EEA, we process such data on the basis of Article 6.1(a) of the GDPR, i.e., data subjects’ consent.
- When you send us an email to participate in our surveys, request help from customer support, or otherwise submit information to us through our website, in order to respond to your communications and requests, provide customer service, request feedback, and otherwise contact you about your use of our Service, we may collect your e-mail and other personal data that you directly provide to us, such as your name, telephone number and address. If you are a resident of EEA, we process such data on the basis of Article 6.1(a) of GDPR, i.e., data subjects’ consent.
- When you request an exchange or refund, we may collect additional personal data about payment details and reasons for requesting an exchange or refund. If you are a resident of EEA, we process such data on the basis of Article 6.1(b) of the GDPR, i.e., necessary for the performance of a contract.
- When you use our website, we may collect your browsing behaviors to improve the performance or design of our website. If you are a resident of EEA, we process such data on the basis of Article 6.1(d) of the GDPR, i.e., necessary for the purposes of the legitimate interests pursued by the controller.
- When you use any of the public comment or interactive features of our website, we may collect any information you provide to us. If you are a resident of EEA, we process such data on the basis of Article 6.1(a) of GDPR, i.e., data subjects’ consent.
1.2 We Collect Personal Data When You Use Our App and Products
Urtopia is proud of its futuristic design and smart functions. When you use our App and our products, or when you connect your bike with your Urtopia Account, we may collect your personal data to provide services to you. Depending on which services or features you request or use, not all of these types of personal data may be applicable to you.
- When you sign up for a Urtopia Account (“Account”), you may provide us with a combination of personal data, such as your e-mail, name or nickname, and password. You may also choose to provide us with additional personal data, such as your phone number, address, birthday, and gender. If you are a resident of EEA, we process such data on the basis of Article 6.1(a) of GDPR, i.e., data subjects’ consent.
- You may provide location data of the e-bike to us, which is necessary to enable navigation, anti-theft and find-my-bike functions. For navigation purpose and find-my-bike functions, if you are a resident of EEA, we process such location data on the basis of Article 6.1(b) of the GDPR, i.e., necessary for the performance of a contract. For anti-theft purpose, if you are a resident of EEA, we process such location data on the basis of Article 6.1(d) of the GDPR, i.e., necessary for the purposes of the legitimate interests pursued by the controller.
- We may use your fingerprint information to enable you to unlock your bike, and such information is only stored on your bike and will not be transferred to us. You can also use your cellphone to unlock your bike, and we may use your Bluetooth information to provide such feature. If you are a resident of EEA, we process such data on the basis of Article 6.1(b) of the GDPR, i.e., necessary for the performance of a contract.
- You can interact with the e-bike by pressing a certain button and speaking to it. We may capture audio voice recordings and voice commands during those interactions. If you are a resident of EEA, we process such data on the basis of Article 6.1(b) of the GDPR, i.e., necessary for the performance of a contract. We cannot prevent you from providing additional personal data when you interact with the e-bike.
- We may collect your audio voice recordings and voice commands, when you use voice control feature in your e-bike. If you are a resident of EEA, we process such data on the basis of Article 6.1(b) of the GDPR, i.e., necessary for the performance of a contract.
- Our e-bike carries a bunch of IoT sensors including torque sensor, gyroscope, mm-wave radar and GPS. You may sync data collected from such sensors and other bike stats data, such as, speed, distance, battery level, boot screen, ringing sound, motor power, slope, etc. to your Account on our App. If you are a resident of EEA, we process such data on the basis of Article 6.1(b) of the GDPR, i.e., necessary for the performance of a contract. We may use such data to improve your riding experience and to provide more fascinating features on our App. If you are a resident of EEA, we process such data on the basis of Article 6.1(d) of the GDPR, i.e., necessary for the purposes of the legitimate interests pursued by the controller.
- We may collect device numbers of your e-bike, such as hardware serial number, MAC address, and unique device identifier to check status of your e-bike when you request for after-sales service and provide relevant service to you. If you are a resident of EEA, we process such data on the basis of Article 6.1(d) of the GDPR, i.e., necessary for the purposes of the legitimate interests pursued by the controller.
1.4 We Collect Personal Data from Third Parties
To the extent permitted by applicable law, we may combine personal data with other personal data we collect from your activity in our Services, personal data we receive from other companies or publicly available personal data.
1.5 We Aggregate and Anonymize Personal Data
1.6 Public Comment and User Generated Content
We provide public comment features and other interactive features to share user generated content on our website and App. Please note that any information you post or disclose using this feature will become public information, and will be available to other users of our Services and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information. If you provide feedback to us, we may use and disclose such feedback on our website, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on our website. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.
2. How We Share Personal Data We Collect
We are committed to protecting data that identifies you personally, where you have chosen to keep it private. We will only share your personal data in the following circumstances:
With Urtopia service providers. Urtopia hires several service providers to help operate our Services (including vendors and payment processors), and may give access to certain personal data necessary for service providers to undertake their work, in which case we will require those service providers to honor the privacy and your personal data. Urtopia currently uses the following third-party service providers to provide their services:
- Vendors who provide delivery service. We may share your contact information, such as address and phone number with these vendors to fulfill delivering products.
- Vendors who provide voice recognition technology. We may share your audio voice recordings with these vendors to generate voice commands and enable you to use voice control features.
- Vendors who provide email service. We may share your e-mail address with these vendors, such as MailChimp, to send you marketing messages, notifications, confirmations, updates, product announcements, and security alerts.
- Vendors who provide analytics services. Our website uses analytics services, such as Fabric, a software development and integration kit that allows Urtopia to analyze its customers’ general usage patterns, including the rates of Urtopia users on daily and weekly bases.
- Vendors who provide payment service. Our website uses Klarna for alternative payment options. You can read more about how Klarna uses your personal information here: https://cdn.klarna.com/1.0/shared/content/legal/terms/0/en_us/privacy.
With Urtopia partners. We may share some of your personal data with our partners (including a parent company, subsidiaries, other companies that we control or that are under common control with us, and joint venture partners), in which case we will require those partners to honor your personal data.
In the event of merger or sale. If Urtopia is involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of its business, personal data may be transferred with the business.
3. Our Data Security and Storage Practices
We work hard to protect Urtopia and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of personal data we hold. Urtopia follows industry standards and best practices to help protect your personal data from unauthorized access, use and disclosure. For example, we store the personal data we collect on computer systems with limited access and located in controlled facilities. When we transmit highly-confidential personal data over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Please be aware that, despite our efforts, no security measures are impenetrable. Unfortunately, we cannot guarantee that any method of data transmission will protect against any interception or other type of misuse.
4. How We Store and Transfer Your Personal Data
Urtopia stores and processes personal data in databases hosted in the country or region in compliance with applicable laws. We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected and to the extent permitted or required by law.
In some circumstances, we will, subject to law, transfer your personal data to other countries or regions where you reside or allow entities outside of countries or regions where you reside to access your personal data. Any such transfer of your personal data will be carried out in compliance with applicable laws.
5. Your Choices Regarding the Use of Your Personal Data
You may request access to and correction of your personal data we retain. If you request that we delete personal data, such personal data will be permanently deleted, and we will no longer retain that personal data in any form. If you wish to stop further collection or use of your personal data, or to delete your email address, you may choose to permanently delete your Account by emailing us at email@example.com. Please note that, by permanently deleting your Account, you will disable most of the advanced functionality of the Urtopia e-bike. To reinstate functionality at a later date, you may set up a new Account. You may also opt out of receiving emails from us anytime by following the unsubscribe instructions in those emails.
In addition, depending on applicable law, you have the right to submit a complaint or object to our collection and use of your information at any time, or to require us to review, transmit, change, or delete your personal data that we have collected and retained. We will fulfill your request to exercise any of these rights within the applicable time period subscribed by such laws. You can exercise these rights, express concerns, or obtain additional information about the use of your personal data by contacting us.
5.1 Your rights under GDPR or Data Protection Act 2018
If you are a resident in the EEA or the United Kingdom, you have the following rights:
- Right to Access. You may request access to the personal data we process about you;
- Right to Correct and Delete. You may request us to correct, update, shield or delete your personal data in our records;
- Right to Request a Copy. 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;
- Object to processing. You have the right to object to the processing of your personal data and request us to cease processing of it if, for example, this data is being processed for the purpose of direct marketing or where we are relying on a legitimate interest (or those of a third party). In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
- Restrict the processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the personal data; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you require us to hold the data even if we no longer need it as you require it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to Complain. You may file a complaint against processing your personal data. And you may file a complaint if you are under the impression that we process your data unlawfully;
- Withdraw Your Consent. 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.
- Requesting channels. Please email us at firstname.lastname@example.org to submit your data request.
5.2 California Privacy Rights
Urtopia adopted this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”), and applies solely to residents of the State of California (“California Consumers”). Without limiting the foregoing, this section provides California Consumers with the disclosures and notices required under the CCPA. Certain exceptions and limitations may apply to a California Consumer’s rights and Urtopia’s obligations under the CCPA.
- No Sale of Personal Data. If Urtopia ever chooses to sell personal data, you would have the right to opt out of the sale of your personal data.
- Right to Disclosure. California Consumers have the right to request that we disclose certain data about our collection and use of your personal data over the past 12 months.
- Right to Access. You have the right to request that we provide you with access to specific pieces of personal data we have collected about you over the past 12 months (also called a “data portability request”).
- Right to Deletion. You have the right to request that we delete any of your personal data that we collected from you and retained, with certain exceptions.
- Right to Correct. You have the right to request us to correct inaccurate personal data if and when you learn that we maintain inaccurate personal data about you.
- Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right.
- Submit a Consumer Privacy Request. To exercise any of the above rights, please submit a verifiable consumer privacy request to Urtopia by email at email@example.com.
- Verification. We cannot respond to your request or provide you with personal data unless we can verify your identity and your authority to make the request and confirm that the personal data relates to you.
- Authorized Agent. You may make a verifiable consumer request on behalf of your minor child. Otherwise, only you, or a person you have designated in writing as your authorized agent or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (“Authorized Agent”) may make a verifiable consumer request related to your personal data.
- Urtopia’s Response. We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response. We do not charge a fee to process or respond to your verifiable consumer privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Other California Privacy Rights. California Civil Code sections 1798.83-1798.84 (the Shine the Light Act) entitles California residents to request disclosure regarding personal data sharing with affiliates and/or third parties for marketing purposes. If you are a California resident and you would like to request a copy of this notice, please contact us at firstname.lastname@example.org with the subject line “Request for California Privacy Data.”
5.3 Nevada Privacy Rights
If you are a Nevada resident and have provided us with any personal identifying data, you may opt-out of sharing your data with third parties if you submit an opt-out request to the following email address: email@example.com. Please note we do not sell any of your personal data for profit, we do share some data with contracted third parties in order to provide better services and advertising to you. Please allow 60 days for completion of such request.
6. Minors’ Personal Data
Our Services are designed for adults, not children. As such, our Services are not intended for children under 16 years of age. No one under age 16 may provide any personal data to us or in our Services. If you are under 16, do not use or provide any data in our Services, make any purchases through our website, use any of the interactive or public comment features of this website or provide any data about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 16 without verification of parental consent, we will delete that data. If you believe we might have any data from or about a child under 16, please contact us at firstname.lastname@example.org.
8. How You Can Contact Us
You may also write to us at:
New Urtopia Holdings HK Limited
Attn: Urtopia Privacy
Unit 9043, Room 903-904,
9/F, Block B, Chung Mei Centre,
15-17 Hing Yip Street,