1.- Privacy Policy

In BH BIKES EUROPE, S.L. (hereinafter BH BIKES) we are committed to protecting the privacy and ensuring the proper use of the personal data that we process and which you provide to use, both online through this website and, where applicable, any of its subdomains, microsites and/or mobile applications, and offline.

Please carefully read this policy and make sure that you understand it and agree with it before providing us with your personal data. If you do not agree with it, do not use this website or its services or provide us with your data. If you access this site, use any of its services or provide us with your data, whether online or offline, this shall be deemed to be a clear affirmative action whereby you give us your consent (when this is necessary) to process your data for the purposes outlined below.

2.- Who is the processor of your data?

BH BIKES EUROPE, S.L.

Mailing address: C/ Perretagana 10 01015 VITORIA

Email: to rgpd@bhbikes.com

Telephone n.: 945142700

3.- How have we obtained your data?

Obtained from the interested party themselves:  If you are a current or potential customer, or just a user of our website, you have provided us with your data, either offline or online when requesting our services to maintain the contractual relationship with you, or by contacting us to request information, or for example, if you have come to our offices or plant, you have provided us with your data when accessing our facilities as a visitor. Similarly, your data may have been communicated to us by our sales network after providing your data to one of our sales representatives. The categories of data we process are: identification data; postal or email addresses; commercial information; and economic data. We do not process specially protected data.

This information includes, for example:

- Your contact details, including your name and surname, address (billing or delivery), date of birth, and email address, and optionally, your phone number. We need your email address and (optionally) your phone number to contact you if we have questions or information about your order;

- Other information necessary to process your order, such as information about the products you have ordered, billing and delivery address, and your bank or credit card details;

- If you have created an online profile, the preferences and interests stored in this profile

- If you have contacted customer service, the details and history of that contact.

- If you send us a video, photographs, or any other type of text or audiovisual content (articles, drawings, etc.) protected by industrial or intellectual property rights to participate in any event, activity, promotion, or contest organized by us, sending such content implies the sender's authorization for its use by BH BIKES on this website, and thus making it available to third parties, as well as on our profiles on any social networks, and on YouTube to inform about the event/activity, document it, and be part of the photographic/videographic record of the same, as well as in advertising brochures, posters, stationery, and promotional signage, etc. Therefore, you grant BH BIKES a non-exclusive, royalty-free, unlimited duration, and worldwide right, sublicensable, to reproduce, distribute, translate, publish, and disclose in whole or in part such content in any medium known now or developed in the future, for any purpose. The ownership of the copyright on such content remains with its author, who guarantees it. However, sending or posting content on this website or on our social media pages implies the transfer of reproduction and public communication rights of such content, while the author retains the right to exploit it in any form that does not interfere with the normal publication by the aforementioned means.

- The sender guarantees their ownership or that they have all the necessary rights, capacity, and/or permissions to license such content and that it does not infringe any third-party rights, including any industrial and intellectual property rights, being responsible for obtaining all necessary authorizations, public or private, and making all payments for the use of intellectual and industrial property rights required. The sender will be solely responsible for any claims made by third parties, including public administration, regarding the content and ownership of such content, as well as for any damages that may be caused to BH BIKES EUROPE, who is expressly authorized to exercise the actions provided by law to defend its rights.

When you provide us with your personal data, you guarantee that you are authorized to provide this information and that it is true, accurate, up-to-date, not confidential, does not violate any contractual restrictions or third-party rights, and you agree not to impersonate other Users.

Automatic collection when visiting our website: If you have provided your data through this website, we collect information, for example, when you access the page, when you register as a user, fill out any form with personal data, or when you contact us directly by email.

When you visit our website, data is sent from your browser to our server to optimize our services and improve your user experience, for example, when you access the page or when you log in to our Services through third-party services such as social networks or Google. These data may be collected and stored automatically by us or by third parties on our behalf. This data may include:

- the user's IP address

- the date and time of the visit

- the URL of the site from which the user came

- the pages visited on our website

- information about the browser used (type and version of the browser, operating system, etc.).

We may process and record such uses, sessions, and related information, either independently or with the help of third-party services, including the use of “cookies” and other tracking technologies such as flash cookies and web analytics.

In connection with the above, we offer location services in some of our mobile applications, such as Google Maps and Bing Maps. If you use these mobile applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate your location. Generally, you can enable or disable location services on your device or browser settings.

We use Google Maps or Bing Maps services to help you find the nearest BH Bikes store. To facilitate this process, we load a Google Maps or Bing Maps image and store the route data and map image on our server.

For more information about Google Maps and Bing Maps and their Privacy Policies, please refer to their privacy policies.

Our website and mobile application use retargeting technology on the Internet. We believe that viewing personalized advertising based on user interests is more interesting to our customers than non-personalized advertising, and this technology allows us to show our visitors, who were already interested in our store and products, our ads on other third-party websites. To do this, we work with companies that use tracking technologies to display ads on our behalf on the Internet. These companies may collect information about your visits to our website or mobile applications and your interaction with our communications, including advertising.

Retargeting technologies analyze your cookies and display ads based on your browsing behavior, but we do not store your personal data with this technology, and it complies with applicable Data Protection requirements.

Our website has social media connectors. When you choose to interact with us through a social network, we cannot be responsible for the privacy settings chosen by the user. The social network may provide information about your IP address or what page you are visiting on our website and may set a cookie to enable them to function correctly, or for example, your name will appear in the “likes” you give or in the comments you make on our page on a social network. If you do not want personal data associated with those “likes” or comments to appear, configure your privacy settings to prevent it, such as using a pseudonym or alias that does not reveal your full name.

If you log in to one of these social networks during your visit to our website, the social network may add that information to your profile, and that information will be transferred to the social network. If you do not want this data transfer to occur, log out of the social network before entering our websites or mobile applications, as we cannot influence this data collection and transfer through social connectors.

If the user, through our official page on a social network, decides to post and/or share texts, photos, videos, and other types of information and/or content, they will be solely responsible for ensuring that such content complies with the applicable legal regulations. Please remember that regarding the data of other people, you must respect their privacy, being particularly careful when communicating or publishing their personal data. Only the data subject can authorize the processing of their personal data. The user may only post on this page or our official page on social networks personal data, photographs, and information or other content whose ownership and property belong to them or for which they have authorization from third parties. If you provide or post third-party data, it is your responsibility to have their prior and express consent to use, communicate, and publish it, and it is your responsibility to inform them of the processing of their data by us or its publication by you. Posting third-party data without their consent may violate, in addition to data protection regulations, laws related to the right to honor, privacy, or image of those third parties.

In any case, we may remove any content published by the user from this website or our social media pages when we detect that the user has violated current legislation and the provisions of this privacy policy.

Social Networks are not directly hosted on our Services. Your interactions with them are governed by their policies and not ours. Read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, your rights, and your privacy settings.

Communication by a third party of the interested party's data: In the case that it is not the interested party themselves but a third party who provides us with their data, your data may have been communicated to us by our sales network or distributors after providing your data to one of our sales representatives.

In that case, the categories of data we process may include: Identification data, economic, financial, and insurance data, and transactions of goods and services.

In the case of requesting financing for purchased items, the financing entity may inform us whether the financing you requested has been granted or not.

4.- Data of third parties:

Regarding data of other individuals, you must respect their privacy by taking special care when publishing their personal data. We remind you that, as a user, you can only provide and consent to the processing of your own personal data, not that of third parties. If you provide us with third-party data, you are transferring personal data and are responsible for obtaining the prior and express consent of those third parties to use and provide their data to us. You must also inform them of the inclusion of their data in our records.

Publishing third-party data without their consent may infringe not only data protection regulations but also the right to honor, privacy, or image of those third parties, rights protected by Organic Law 1/1982 of May 5, on the civil protection of the right to honor, personal and family privacy, and one's own image.

5.- Data of minors:

The submission of data on this website by minors under 14 years old is not allowed. If you are under this age, we will need permission from your parents or guardians to provide us with your data. Minors under 14 years old can only register on this website with the authorization and consent of their parents, guardians, or legal representatives, who will be solely responsible for all actions carried out on this website by the minors under their charge, including completing forms with the personal data of those minors and checking, if applicable, the accompanying boxes. It is advised that parents, guardians, or legal representatives must enable the necessary mechanisms to prevent minors from accessing this website and/or providing personal data without supervision, as this organization does not accept any responsibility in this regard.

If it is detected that a minor under 14 years old has registered without authorization, the parents or guardians may be requested to send the appropriate documents to verify the mentioned authorization. Otherwise, the user or registration will be canceled as soon as possible.

If the parents, guardians, or legal representatives of minors detect unauthorized data processing, they can submit their complaints or queries by contacting: rgpd@bhbikes.com

6.- Purpose | Why do we process your data?

We may process your data for various purposes, such as:

a) If you are a current or potential customer, to maintain contact and communication with you, manage the contractual and/or commercial relationship, including post-sale and warranty services, and handle requests you make online, and if applicable, your invitation, registration, and/or participation in activities or events promoted or organized by BH BIKES. It is also informed that in events and activities, photographs and/or videos may be taken that could be published on this website, on our profiles on any social networks, as well as on YouTube to inform about the event/activity, document it, and be part of the photographic/videographic record of it.

b) If you are merely a user of our website or the sender or recipient of an email, to maintain contact and communication with you and handle any requests you make online;

c) To offer, develop, personalize, and improve our products and services according to your interests and enhance your user experience, we will create a "commercial profile" based on the information provided. Automated decisions will be made based on this profile, applying criteria such as your geolocation to indicate purchase prices in your country or to direct you to the nearest store, your purchases in our online store and/or physical BH Bikes stores, your use of loyalty programs, your product ratings and reviews, your contact history with our customer service department, your newsletter open and click rates, your browsing behavior (web tracking), the types of newsletters you are subscribed to, your participation in promotions or events, your interactions with "My Coach," and your use of our mobile applications. To evaluate your creditworthiness, BH Bikes is authorized to consult third parties such as financial institutions, credit and solvency report companies, etc., to request additional economic and financial data that may be necessary to complete the information about your creditworthiness.

d) If you provide us with your resume or send us your curriculum vitae, to contact you and manage the selection processes we conduct.

e) If you access our facilities as a visitor, to manage access and visitor control.

f) To conduct opinion and/or satisfaction surveys and send you, via electronic communications, information about our activities, products, and/or services similar to those requested (including advertising and/or commercial communications under Article 21 of LSSICE 34/2002). If we have a previous contractual relationship, such communications will be sent based on our legitimate interest. If there is no prior contractual relationship, we will only send such communications if you authorize us by marking the option expressly included in the relevant forms. The electronic communications we send will include the option to opt-out of receiving them in the future. If you choose to do so, we will stop sending you such communications moving forward.

7.- Retention period | How long will we keep your data?

We will keep the personal data you provide as long as you do not request its deletion. Even after such a request, we may retain it for the necessary time, limiting its processing only to comply with legal/contractual obligations and/or during the legal periods foreseen for the prescription of any responsibilities on our part and/or the exercise or defense of claims arising from the relationship maintained with the data subject.

8.- Legitimacy | What is the legitimacy for processing your data?

The legal basis that legitimizes us to process your data may vary:

On one hand, it may be the legal relationship we have if you are a current customer/supplier, or the pre-contractual relationship of any kind existing between the parties if you are a potential customer/supplier (for example, if you have requested information, an offer, or a quote…). Providing the requested data is mandatory as it is essential to formalize and/or maintain the contractual or pre-contractual relationship and comply with the legal obligations derived from it; if you do not provide it, we will not be able to provide the service derived from such a relationship.

It may also be your consent if you have made a request through our website as a mere user or if you have sent us your resume, or if you are a visitor to our facilities or in the case of image capture. Such consent is given unequivocally by providing us with your data online or offline, considering such provision as a clear affirmative act that manifests this consent. You may withdraw this consent at any time by sending an email to rgpd@bhbikes.com but such withdrawal may mean that we cannot respond to your request, consider your resume, or give you access to our facilities.

It may also be the compliance with consumer and user regulations, anti-money laundering laws, tax laws, or the criminal code regarding the establishment of a whistleblowing channel according to Article 31 bis of that code…

Our legitimate interest as an organization also constitutes a legal basis for processing your data for:

- Conducting opinion and/or satisfaction surveys

- Informing you about our activities, products, and/or services (including through electronic communications) If we have a prior contractual relationship, such communications will be sent based on our legitimate interest. Otherwise, we will only send such communications if you give us your consent by marking the option expressly included in the relevant forms. In any case, the electronic communications we send will include the option to opt-out of receiving them in the future.

9.- Recipients | To which recipients may we communicate your data?

We inform you that the data you provide may be communicated to third parties for the fulfillment of purposes directly related to the legitimate functions of the transferor and the transferee, such as:

1. To transportation companies responsible for the logistics of shipping and delivering our goods.

2. To other companies within the BH corporate group for internal administrative purposes, including the processing of customer personal data.

3. To stores or distributors for the assembly and delivery of the purchased bicycle.

4. To entities or organizations to which there is a legal obligation to communicate data (tax administration, etc.).

5. To various entities necessary at any given time to provide different payment services and manage payments and collections made through this website, as well as obligations arising from payment systems that facilitate them; all in compliance with the functions specific to these entities for the provision of such services.

6. To insurance entities in cases of credit and surety insurance for ensuring the collection of operations or for liability or defective products insurance in case of possible claims by the end user.

7. To our subsidiaries in other countries, or to agents or distributors in our commercial network, to handle queries that reach our website and need to be addressed by them. If this involves an international data transfer to a country outside the European Economic Area, the data subject gives unequivocal consent to such transfer by providing their data.

International Transfers

We may use service providers located outside the European Union, who may have access to personal data, for the provision of auxiliary services to our activity (hosting, housing, SaaS, remote backups, IT support or maintenance services, email management, email sending and email marketing, file transfers, etc.).

These companies may vary over time, but in all cases, we will choose companies that provide an adequate level of protection, which means they are required to meet standards equivalent to European data protection regulations.

In any case, by accepting this data protection policy, you expressly and unequivocally authorize the communication of data to these companies, acknowledging that this involves an international data transfer to a country outside the European Economic Area and giving your unequivocal consent to such transfer.

10.- What are your rights when you provide us with your data?

You can, when applicable, exercise your rights of access, rectification, deletion, restriction, and opposition to the processing of your data, as well as not to be subject to decisions based solely on automated processing of your data,

at the postal or email address indicated at the beginning of this privacy policy; in both cases by written and signed request, attaching a copy of your ID card or passport or other valid identification document. In case of modification of your data, you must notify it to the same address, with this company declining any responsibility if you do not do so.

Right of Access: You can ask us which personal data we are processing, including requesting a copy of it.

Right of Rectification: You can request the rectification of inaccurate personal data or completion of incomplete data, including through an additional declaration.

Right of Deletion (Right to be Forgotten): You can request the deletion of your personal data when: it is no longer necessary for the purposes for which it was collected, you withdraw your consent, there has been unlawful processing, or to comply with a legal obligation.

Right to Restrict Processing: You can request the restriction of the processing of your data, in which case we will only keep it for the exercise or defense of claims.

Right to Object: You can object to the processing of your data if such processing is based on the legitimate interest of the data controller or is for advertising purposes.

Once any of the above requests are received, we will respond within the legally established timeframes. You can lodge a complaint with the Spanish Data Protection Agency. If you want more information about the rights you can exercise and to request forms for exercising rights, you can visit the Spanish Data Protection Agency website at www.aepd.es

11.- Categories of Data

The categories of data we process are: identification data; professional data; economic, financial data; transactions of goods and services.