Privacy Notice

This is the privacy notice of GT Electric Scooters Limited, company number 12658974 (‘we’, ‘our’, or ‘us’).

Our registered office is at 22 Wenlock Rd, Hoxton, London N1 7GU.

This notice describes how we collect, store, transfer and use personal data.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected on our website and through social media platforms, including Facebook and Instagram.

This notice also tells you what personal data we process, your privacy rights and how the law protects you.

Personal information we process

1. How we obtain personal information

The information we process about you includes information:

  • you have directly provided to us
  • we collect as a result of monitoring how you use our website and our services

2. Types of personal information we collect directly

When you use our website, for example, when you buy from us, we ask you to provide personal information. This can be categorised into the following groups:

  • identity information, such as your first and last names and your title
  • contact and delivery information, such as your email address, your telephone number, and the city and the country in which you live
  • records of communication between us including messages sent through our website, email messages and telephone conversations
  • marketing preferences that tell us what types of marketing you would like to receive

3. Types of personal information we collect from your use of our website and services

By using our website and our services, we process:

  • purchase and servicing history relating to the purchases you have made, and our servicing of your equipment
  • technical information about the hardware and the software you use to access our website and use our services, including your Internet protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
  • transaction information that includes the details of the services you have bought from us and payments made to us for those services

4. Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal information so that it can identify you in any way, we treat the combined information as personal information, and it will be used in accordance with this privacy notice.

5. Special personal data

Special personal data is information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric information.

We do not collect any special personal data about you.

6. If you do not provide personal data we need

Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that information when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information and notify you of each category’s basis.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

7. Information we process because we have a contractual obligation with you

When you buy from our website or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract, it is necessary to process your personal information.

We process this information because there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

8. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us we may ask you to provide your consent to us to process personal information.

For example, we may ask you to agree to our use of non-essential cookies when you access our website.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us. However, if you do so, you may not be able to use our website or our services further.

9. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for:

  • improving our service
  • responding with appropriate and personalised replies to communication that you have initiated
  • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
  • insuring against or obtaining professional advice that is required to manage risk within our business
  • protecting your interests where we believe we have a duty to do so

10. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a legal obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of personal data you provide

11. Information you provide under the expectation that it will be shared with others

Information you provide under the expectation that it will be shared with others

Our website may allow you to post information with a view to it being read, copied, downloaded, or used by other people.

Examples include: posting a review, tagging an image and clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks.

In posting personal data, it is up to you to satisfy yourself about the sensitivity of the information and the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion, we may agree to your request to delete personal data that you have posted. You can make a request by contacting us.

12. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of a reputable payment service provider. We use the services of Stripe. The payment page may be branded to look like a page on our website, but it is not controlled by us.

13. Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Cookies and similar technologies

14. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for the use of any cookies that are not strictly necessary for the operation of a website.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to keep you signed in to our website
  • to record and remember choices you make while browsing our website

15. Remarketing

Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for our services when you visit some other website.

The benefit of re-marketing technology is that we can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.

We may use a third-party advertising service to provide us with re-marketing services from time to time. If you have consented to our use of such tracking technologies, you may see advertisements for our products and services on other websites.

We do not provide your personal information to advertisers or to third-party re-marketing service providers. However, if you are already a member of a website whose affiliated business provides such services, that affiliated business may learn of your preferences in relation to your use of our website.

We may use a third party such as Google, Microsoft or Facebook to provide us with marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Facebook’s privacy policy can be found at https://en-gb.facebook.com/business/m/privacy-and-data

Google’s privacy policy can be found at https://policies.google.com/technologies/ads?hl=en-GB

Microsoft’s privacy policy can be found at https://about.ads.microsoft.com/en-gb/resources/policies/privacy-and-data-protection-policies

16. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Disclosure and sharing of your information

17. Payment information

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of our payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

18. Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

19. Credit reference

To assist in combating fraud, we may share information with credit reference agencies, so far as it relates to customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

Other matters

20. Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

21. Data may be processed outside the UK

Our business is based in the UK and our website is hosted in the UK.

However, from time to time, personal data obtained within the UK or any other country could be processed outside the European Union.

Where this occurs, we use one of the following safeguards:

  • either the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing; or
  • we have a contract with the data processor that includes transfer clauses that oblige the data processor to process the data to the same standards as to which we are obliged.

22. Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your privacy.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the data, and whether we require any fee for providing it to you.

Likewise, we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

23. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

24. Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us to reply with the information you need.

We may keep personally identifiable information associated with your message, such Identity Information and Contact Information to be able to respond to you.

25. Complaints about our products or services

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

26. Use of our website by children

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.

We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.

27. How you can complain about this policy

If you have any complaint regarding this policy or your privacy then you should tell us by email.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal data, you have a right to complain to the Information Commissioner’s Office (ICO) at https://ico.org.uk/make-a- complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

28. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

  • to provide you with the goods and services you have requested
  • to comply with other law, including for the period demanded by tax authorities
  • to support a claim or defence in court

29. Compliance with the law

Our privacy policy complies with the law of England and Wales, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

30. Review of this privacy policy

We may update this privacy notice from time to time as necessary.

If you have any questions regarding our policy, please contact us.

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