Last updated Augest 19, 2022
Windgoo Values Your Privacy
At Windgoo, we take your personal privacy seriously and recognize that you expect privacy and security for all your personal information. We understand the need to protect and safeguard sensitive information about you, and we maintain strict standards and procedures designed to prevent misuse of your information.
We encourage you to read this privacy notice (the “Privacy Notice”) carefully to understand the information we collect and what we do with it.
Windgoo Inc. and its affiliates and subsidiaries (collectively “Windgoo,” “us,” “our,” or “we”) are responsible for your information. This Privacy Notice applies to our European Union website (“Windgoo Site” or “Site”). When you access and use our Site you acknowledge that you have read this Privacy Notice, understood it, and that you do not object to our processing activities. Use of our global website (www.windgoo.co) or UK website (www.windgoo.uk) are subject to their respective Privacy Notices.
Your Windgoo Data Controller: Your data controller is the company making decisions on how and why your data is used, and for EU residents this is Windgoo Inc.
This Privacy Notice describes how Windgoo collects, protects, uses, and discloses information and data collected and created in the course of your access to and use of the Windgoo Site, products, and services, as well as your interactions with Windgoo via telephone, through mail or at our physical locations. It also explains what your rights are, which may differ depending on where you are located.
Please be advised that this Privacy Notice applies to information that we collect:
- when you visit the Site.
- when you submit your information to us on the Site.
- when you create or use a user profile on the Site.
- when we communicate with you through email and other communications.
- through Service Providers that we work with to provide our services.
- by any other means over the course of your use of our services.
How We Collect Your Information
The only personal information we collect about you is either provided by you voluntarily or as described below under “Information Collected from Your Use of the Site.” Windgoo does not collect biometrics or sensitive information relating to health, race, gender, or other special category data.
Information We Collect. If you access or submit an inquiry through our Sites, set up an account, subscribe to a service, register to receive marketing materials, participate in contests, sweepstakes or promotions, or receive other services, we may ask you to provide certain personal information such as your name, email address, phone number and zip code, and other personally identifiable information (“Personal Information”).
We take reasonable steps to make sure that we only ask for the information we need for the purposes listed in “How We Use Your Information”.
We also take steps to ensure that your contact information is accurate, complete, current, and otherwise reliable.
We will only collect and process your Personal Information if we (a) obtain your consent, (b) have a legitimate interest in collecting and processing the data for our direct marketing purposes, or (c) where required or permitted by law.
We may periodically supplement the Personal Information we collect from you with personal or non-personal information about you or another person obtained from companies with whom we have marketing or other business relationships and other third-party sources. Any aggregate information that is linked or linkable to your Personal Information will be treated by us as Personal Information under this Privacy Notice.
Children Under Age 16.Our site is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Site. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site or provide any information 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 information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
Information Collected from Your Use of the Site. We or a Service Provider may use Site analytics tools or other licensed technologies from third parties to collect information about you from your use of this Site. This information may be combined with other information that you choose to submit to us. This information may also be merged into aggregate information about site visitors and traffic. We also may use third-party Service Providers’ analytics tools to distinguish and analyze user behavior. Here are the details of how we do this and the reasons why:
- Log Files. We or a Service Provider may collect anonymous and technical information from your computer, including your Internet Protocol address, data about your computer or other device, the type of browser or operating system your device uses, the programs, services, and version of software you use, and the address of any linking site, when you request a web page while visiting the Site. We use this information for statistical purposes, to ensure that our pages on our Site will appear and function appropriately on your computer, to determine which site referred you to our Site, and to personalize your access to our Site or conduct our own analyses and research to improve our programs, products, services, and content. We use Service Providers to collect and analyze information, and we reserve the right to change which Service Providers collect and analyze said information in the future. If you do not agree with Windgoo or its Service Providers collecting and using your anonymous and technical information as described in this paragraph, your choice is discontinuing use of the Site or contact us as described under “Controlling Your Personal Information.”
- Web Beacons. Some pages of our the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us or a Service Provider, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
Information We Collect Offline. We collect information when you visit an Windgoo retail showroom to make a purchase/payment, fill out a registration agreement, take a tour, test ride an ebike or submit an inquiry at such retail showroom. This may include:
- Your personal contact information, such as your name, address, email address, and phone number.
- Your sensitive personal information, such as your emergency contact and release information, driver’s license number, and employer information.
- Your financial information as needed to process a payment.
- Video recordings of your entrance to and exit from our retail showroom.
- Information collected offline by third parties in order to facilitate services, such as credit card, banking, or other payment-related information.
How We Use Your Information
We use your Personal Information for the purposes described at the time of collection and to manage the internal operations and security of our Site consistent with this Privacy Notice. We may also use your Personal Information for analytical and direct marketing purposes, such as:
- Sending you periodic email and newsletter communications;
- Confirming, sending, and tracking your order, subscription, or registration;
- Communicating with you about your order, subscription, or registration;
- Responding to customer inquiries;
- Sending you surveys and other communications;
- Analyzing preferences, trends, and statistics;
- Informing you of our new products, services, and offers; and
- Providing you with other information from and about Windgoo.
We will only contact you in ways compatible with your communications choices. However, even if you have opted-out of receiving marketing communications from us, we may need to contact you to address questions or issues specific to the services you have requested.
Other Ways We Might Use Your Information. In addition to the specific uses and purposes described above, we might use information that we collect about you or that you provide to us, including any Personal Information:
- To present our Site and its contents to you.
- To provide you with information, products, or services that you request from us.
- To allow you to participate in interactive features on our Site or to notify you about changes to our Site or any products or services we offer or provide though it.
- To provide you with other information from and about Windgoo or a business or organization with which we are associated.
- To protect your privacy and enforce this Privacy Notice;
- If we believe it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Windgoo, or to others.
- To fulfill any other purpose for which you provide your information.
- To analyze preferences, trends, and statistics.
- To protect our rights and property.
- To comply with a law, regulation, legal process or court order.
- For any other purpose with your consent.
Legal Basis for Processing. All processing (i.e., use) of your Personal Information is based on one of several legal conditions. Generally, these will be:
- Your consent (for example, to place cookies which process Personal Information, or for marketing from our third-party partners). When we need your consent, we will collect it by using a form in which we will inform you so you can decide whether or not to give consent accordingly;
- The performance of our contract with you (e.g., to process your payment or shipping information in order to fulfil your order);
- Compliance with a legal obligation (e.g., where we are required to disclose information to a court or a tax authority); and
- Our legitimate interests, provided these do not override your fundamental rights and freedoms (e.g., where we carry out our own direct marketing to existing subscribers, subject to your right to opt-out of this at any time).
Periods After Which We Will Delete Your Personal Information: We only use your Personal Information for as long as it is necessary to fulfil each of the purposes explained in this Privacy Notice, after which we will delete your data, unless we are required to keep the data for longer to comply with a legal obligation.
Access To Your Information
We do not share, sell, rent, or transfer your personal information other than as described in this Privacy Notice. Your information will be accessible to Windgoo employees who are trained to comply with our internal policies for handling Personal Information and assisting you in exercising your legal rights over your personal information.
Service Providers may also have access to your personal information while they are carrying out their services. However, we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
We allow some Service Providers to assist us with behavioral advertising by collecting and analyzing certain information when you visit our Sites (e.g., click stream information, browser type, time and date, subject clicked or scrolled over). These Service Providers typically use a cookie or third-party web beacon to collect this information. You can find more information about opting out of behavioral advertising by visiting http://www.networkadvertising.org/choices or www.aboutads.info/choices/.
Disclosure of Your Information. We will only disclose, sell, or share your Personal Information or other information:
- To Service Providers. We may disclose, sell or share Personal Information to one or more Service Providers with which we have contracted to provide services to us or to offer the services you have requested from us. We may also disclose Personal Information to one or more Service Providers who are interested in providing services or products to you. We do not control how these Service Providers use or disclose your Personal Information.
- To Affiliates. We may disclose some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other Windgoo Group companies under common control with us, in which case this Privacy Notice will apply to the same extent it applies to Windgoo.
- For Our Internal Analyses and Operations. We may disclose Personal Information to third party vendors for our own internal statistical, design or operational purposes, such as to estimate our audience size, measure aggregate traffic patterns, and understand demographic trends among our users. The use and disclosure of your Personal Information by these third parties is restricted to performance of such tasks and subject to confidentiality.
- For Legal and Other Compliance. We may disclose Personal Information when we believe it is appropriate to: (a) comply with the law, (b) enforce or apply this Privacy Notice or our other policies or agreements, (b) protect our or our users’ rights, property or safety, (c) protect our users from fraudulent, abusive or unlawful use of, our Site, or (d) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.
- As Part of Business Transfers. We may disclose Personal Information as part of any merger, acquisition, debt financing, sale of company assets or other business transaction.
- As Aggregated Information. We may share or sell aggregated, anonymous information to our advertisers, business partners, and other third parties that includes or is based on information about you. We take technical and organizational measures to anonymize your information and combine it with other users’ information so that it does not directly identify you. This information may be used by those third parties for marketing, promotional or statistical purposes. We do not limit the third parties’ use of the aggregated information.
It is Windgoo’s policy to treat your Personal Information with complete confidentiality. We employ commercially appropriate and reasonable safeguards both online and offline to maintain the security, confidentiality, and integrity of information that we collect about you. We maintain physical, electronic and procedural security measures to safeguard your non-public personal information. We update and test our technology to improve the protection of our information about you and to assure the integrity of that information.
We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and special training programs. We take appropriate disciplinary measures to enforce employee privacy practices.
Please note, however, that no transmission of data over the internet is 100% secure. While we employ reasonable measures to protect your Personal Information, we cannot guarantee that unauthorized third parties will not defeat those measures or use nonpublic Personal Information for improper purposes. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or for actions of third parties. The safety and security of your information also depends on you, and you are responsible for keeping your password confidential. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place. All Internet users should take care with how they handle and disclose their personal information.
Third Party Sites & Advertising
This Privacy Notice applies only to information collected by Windgoo. We may provide links to third party Sites from our Sites as a service to our users, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third party Sites. When you click on links that take you to external Sites, you will be subject to their privacy policies and practices and not ours. We encourage you to review and understand the privacy policies of such Sites before providing them with any information.
Our third party partners currently include (but are not limited to): Google, Instagram, Facebook and Youtube.
Controlling Your Personal Information
Opting Out of Communications. You can modify or limit the communications we send to you by clicking the “unsubscribe” link at the bottom of any of our emails. You may also contact us directly toll free by email at email@example.com. Please be sure to include your full name, email address, mailing address, and specifically what information you do not want to receive. If you like, you may use one of the following statements in your message to us:
- I prefer not to receive email advertisements, such as updates regarding products and services, special promotions, or upcoming events.
- I prefer not to receive direct mail advertisements, such as periodic catalogs and mailings regarding products and services, special promotions, or upcoming events.
Your Rights. Subject to applicable law, as a resident of the EU, you may have some or all the following rights in respect of your Personal Information:
- To obtain a copy of your Personal Information together with information about how and on what basis that Personal Information is processed;
- To rectify inaccurate Personal Information (including the right to have incomplete Personal Information completed);
- To erase your Personal Information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);
- To restrict processing of your Personal Information where:
- The accuracy of the Personal Information is contested;
- The processing is unlawful but you object to the erasure of the Personal Information;
- We no longer require the Personal Information, but it is still required for the establishment, exercise or defense of a legal claim;
- To challenge processing which we have justified based on a legitimate interest (as opposed to your consent, or to perform a contract with you);
- To prevent us from sending you direct marketing;
- To withdraw your consent to our processing of your Personal Information (where that processing is based on your consent);
- To object to decisions which are based solely on automated processing or profiling; and
- To obtain or see a copy of the appropriate safeguards under which your Personal Information is transferred to a third country or international organization.
In addition, you have the right to lodge a complaint with your local supervisory authority (for example, the Information Commissioner’s Office in the United Kingdom).
In relation to these rights, please contact us using the details in the “Contact Information” section below. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavor to respond to your requests within all applicable timeframes of which we will inform you at the time we acknowledge your request.
Do Not Track Signals. Currently, Windgoo does not respond to Do Not Track browser settings or signals. In addition, Windgoo may use other technology that is standard to the internet to track visitors to Windgoo Sites. For information about Do Not Track, visit www.allaboutdnt.org.
Unauthorized Use. If you become aware of any unauthorized submission of information to Windgoo, including children’s information, please inform us by contacting us at the contact information listed below so that we may delete it.
International Transfers for EU Residents. You should be aware that we are a China headquartered company, and your Personal Information may be transferred to and stored in the China for processing.
In relation to both internal transfers and the use of affiliates, service providers or suppliers, if Personal Information is transferred outside the European Economic Area (“EEA”), we will take steps to ensure that the information receives the same level of protection as if it remained within the UK and the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU - China Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA. Please contact us if you wish to know more.
Changes To This Privacy Notice. We may occasionally make changes to this notice to ensure its accuracy. If we make changes, the revised notice will be posted online, and the date of the newest version will be listed. Please check back frequently, especially before you provide us with personal information, to determine the current scope of the notice.
If you have any further questions about our collection and use of your Personal Information, or if you wish to exercise any of your rights over your personal information or if you have any questions about this privacy notice, please contact us at: