Data Privacy Policy

 

 

 § 1 Legal information on data protection

We at SR Suntour Europe Ltd. Respect and protect the privacy of all our clients and visitors to our website (hereinafter referred to as “visitors”) and adhere strictly to the regulations in privacy protection laws. The high standards you expect from our products and services are our guideline for handling your data. Our aim is to create and maintain the basis for a trusting business relationship with our customers and prospects. The confidentiality and integrity of your personal data is top priority for us.

Personal data will be collected on this website only to the extent required. Under no circumstances will the data stored be sold. The following policy gives you an overview of how we ensure this protection and the information required under Article 13 of the General Data Protection Regulation on the processing of your data, in particular which categories of data SR Suntour stores in respect of the users of the website www.srsuntour-cycling.com/de/home/  and for what purpose.

This Privacy Policy applies to all SR Suntour websites and all products and services that SR Suntour offers. In this context, this Privacy Policy also applies in respect of all SR Suntour group companies which may collect and/or process data.

§ 2 Name and address of the controller

As defined by the basic EU data protection regulations, SR Suntour Europe Ltd. (hereinafter reffered to as “SR Suntour”), Riedstrasse 31, 83627 Warngau, Germany, Tel: +49 (0)802 150 793-0, Fax: +49 (0)802 150 793-29, Email: service@srsuntour-cycling.com, is responsible for the processing of your personal data.

The headquarter is in Warngau.

§ 3 Collection of general data and information

(1) SR Suntour acquires and processes your personal data in the following cases, among others:

When you contact us directly, for example via our website, via SR Suntour customer services  or SR Suntour distributorships.


(2) The data that you submit to us will be processed by us for the purposes of

 

·       customer care (Art. 6 Para. 1b) g) f) of basic EU data protection regulations. Sr Suntour uses your personal data to handle any request you have submitted. Regarding all aspects of dealing with a concern, we will contact you without separate consent, for example in writing, by telephone, per messenger service, per e-mail, depending on which contact data you have specified.

 

·       Compliance with legal obligations to which SR Suntour is subject (Art. 6, para, 1c) f) of basic EU data protection regulations

 

SR Suntour will also process personal data if there is a legal obligation to do so.

Gathered data are also processed within the framework of ensuring the operation of IT systems. Ensuring operation involves the following activities:

·            Backup and restore of data processed in IT systems

·            Detection and defense against unauthorized access to personal data

·            Incident and problem management to remedy malfunctions in IT systems.

SR Suntour is subject to other legal obligations. In order to fulfill these obligations, we process your data to the required extent and, if necessary, pass them on to the authorities responsible within the framework of legal obligations of notification.

We also process your data in the event of legal conflicts if the legal conflict makes processing the data necessary.

·     Data transfer to selected third parties

Data are forwarded to the following companies, among others, if and to the extent that the requirements in compliance with data protection legislation necessary for this are met:

To carefully selected and checked service providers and business partners with whom we cooperate to be able to offer you products and services. We do this for SR Suntour companies only within the framework of the strict conditions of data processing on your behalf or on the basis of your express consent (for more: see § 10).

To other third parties (for example public authorities) to the extent that we are legally obliged to do so.

(4) If we perform one of the actions described below, or other actions, or render services, we would like to collect and store your personal data and will request your express consent in each instance for the:

  • Implementation of a competition, a promotion, a survey or other features of the website, where we need your consent

(5) We delete this kind of data or anonymize your data as soon as it is no longer needed for the transmission of a communication, the performances of contracts or other legal obligations.

§ 4 Data processes by Using our Websites

(1) Unless stated otherwise in detail in the relevant sections of the website, personal data generated from the use of our website www.srsuntour-cycling.com/home/.

When accessing the website, the following electronic communication metadata are stored:

IP address, date and time of access, name of the file called up, sub-page as well as anonymous username, city, user’s region and country, user’s operating system, user’s browser, user’s browser version, user’s interactions on the website, pages visited by the user, duration of the session and number of sessions of the user, date of the first visit to the website, date and time of each interaction of the user, time spent on the website, duration of requests by the user, user’s requests, exception errors of the website, date and time and duration of exception errors. When using these general data and information, SR Suntour does not draw any conclusions about the data subject.

 

Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

 

(2)           The data can be evaluated anonymously for statistical purposes with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. This data is kept strictly confidential and not transferred outside the SR Suntour system or made accessible to other third parties, unless this is necessary to fulfill legal or contractual obligations or to fulfill the legal and legitimate interests of SR Suntour. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.



§ 5 Cookies

 

(1)           The Internet pages of SR Suntour use cookies.

 

Cookies are text files that are stored in a computer system via an Internet browser. Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

We use cookies for the sole purpose of carrying out the necessary electronic communication process (see Art. 6 (1) (f) of the GDPR) or if this is necessary for the provision of the services requested by customers via our website (see Art. 6 (1) (b) of the GDPR). In addition, cookies are only used if you give your express consent (see Art. 6 (1) (a) of the GDPR).

 

(2)               Cookies on this Website that do not require approval

Cookies that are essential, also known as ‘strictly necessary’ cookies, enable features without which you would not be able to use the website as intended. These cookies are used exclusively by BMW and are therefore known as first-party cookies. They are only saved on your computer while you are actually browsing the website. An example of why strictly necessary cookies are used is so that when you open the car configurator, you receive a version of it which corresponds to the data volume which your current Internet connection can handle.  

Another example of what these cookies do is facilitate a switch from http to https when you change pages, so that the security of data transmitted is maintained. Furthermore, a cookie of this kind is used to store your decision about the use of cookies on our website. Your consent is not required for the use of strictly necessary cookies. 

Strictly necessary cookies cannot be disabled using the features of this website.

(3)           Based on what function cookies have and the purpose for which cookies are used, there are four categories of cookie: strictly necessary cookies, performance cookies, functional cookies and marketing cookies.

Strictly necessary cookies
Are essential in order to enable you to move around the website and use its features. Without these cookies, some services cannot be provided – for example, remembering previous actions (e.g. entered text and vehicle configurations) when navigating back to a page in the same session.

Performance cookies
Gather information about how a website is used – for example, which pages a visitor opens most often, and whether the user receives error messages from some pages. These cookies do not save information that would allow the user to be identified. The collected information is aggregated, and therefore anonymous. These cookies are used exclusively to improve the performance of the website, and with it the user experience.

Functional cookies
Enable a website to save information which has already been entered (such as user names, languages choices, and your location), so that it can offer you improved and more personalised functions. For example, a website can offer your local, price-relevant tax information if it uses a cookie to remember the region in which you are currently located. Functional cookies are also used to enable features you request such as playing videos. These cookies collect anonymous information and cannot track your movements on other websites.

Marketing cookies
Are used to deliver adverts and other communications more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. They remember whether you have visited a website or not, and this information can be shared with other organisations such as advertisers. Cookies for improving group targeting and advertising will often be linked to site functionality provided by other organisations.

 

(4)        You can completely disable cookies in your browser at any time.

It is important to note that if you change your settings and block certain cookies, you will not be able to take full advantage of some features of our site, and we might not be able to provide some features you have previously chosen to use.

 

§ 6 Google Analytics

Our website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.

In using Google Analytics our website employs the extension “anonymizeIp”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from EU/EEA member states. Google uses this information to analyze your use of our site, to compile reports for us on internet activity and to provide other services relating to our website.

Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf. Google states that it will in never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.

Google Analytics also offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage.

Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used.

You can find additional information on how to install the browser add-on referenced above at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For the cases in which personal data is transferred to the US, Google has self-certified pursuant to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).

§ 7 Use of Social Media (Plug-Ins) on our website

 

(1) In our website we use Plug Ins for the following links:

 

Facebook

Twitter

Instagram

Vimeo

Flickr

(2) Within the framework of the SRS Suntour internet site, so-called social plug-ins of the social networks Facebook Inc., Twitter Inc., Instagram LLC., Vimeo and Flickr are used.  Web page elements are e.g. buttons (so-called “social plug-ins) or integrated content from the providers.

The integration of the plug-ins means Facebook/Twitter/ Instagram/Vimeo/Flickr receive the information that you have opened the corresponding page of the SR Suntour internet site. If you are logged in to Facebook/Twitter/ Instagram/Vimeo/Flickr,  Facebook/Twitter/ Instagram/Vimeo/Flickr can assign the visit to your Facebook/Twitter/ Instagram/Vimeo/Flickr account. As soon as you interact with the plug-ins, for example by clicking the "Like" button, the corresponding information is sent from your browser directly to Facebook/Twitter/ Instagram/Vimeo/Flickr and stored there. The purpose and scope of the data acquisition and other processing and use of the data by Facebook/Twitter/ Instagram/Vimeo/Flickr as well as your rights and setting options in this respect to protect your private sphere can be found in the data protection information provided by the social media operators.

If you activate the inactive Facebook/Twitter/Instagram/Vimeo/Flickr Plug-in on the internet site of SR Suntour under the domain www.srsuntour-cycling.com your browser sets up a direct connection to the servers of Facebook/Twitter/Instagram/Vimeo/Flickr. The content of the plug-in is transferred by Facebook/Twitter/Instagram/Vimeo/Flickr directly to your browser and then integrated in the website.

(3) Facebook and Twitter

We use plug-ins of facebook (operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or in case you are located in the EU Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) or twitter (operated by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA). And we do link to our facebook and twitter profile. This means that as soon as you have a facebook or twitter user account and you are also logged-in to this user account, facebook or twitter can establish a connection to your profile and collects information about you surfing the web when you klick on the respective buttons on our website. To avoid this, please always log-out from your social media accounts.

(4) Vimeo

The operator of Vimeo is Vimeo Inc., 555 West 18th Street, New York 10011, NY 10601, USA (“Vimeo”). These plug-ins are marked with a Vimeo logo. Website elements of Vimeo are recognizable by the Vimoe logo and lettering on the website element itself. When you visit our website with an embedded Vimeo video and you watch this video, there will be a connection to Vimeo servers with information about what site you are visiting. As soon as you have a Vimeo user account and you are also logged-in to this user account, Vimeo can establish a connection and collects information about you surfing the web. To avoid this, please always log-out from your social media accounts. Please find more information on Vimeo's privacy policy here.

(5) Facebook and Twitter

Flickr is a platform to share your pictures operated by Oath located at 701 First Avenue in Sunnyvale, CA 94089, USA. We use flickr in order to improve the online content and services of our web presence according to GDPR 6.1.

When you visit our website with a Flickr photo stream and you watch this photo stream, there will be a connection to flickr servers with information about what site you are visiting. As soon as you have a Flickr user account and you are also logged-in to this user account, Flickr can establish a connection and collects information about you surfing the web. To avoid this, please always log-out from your social media accounts. Please find more information on flickr's privacy policy here.

§ 8 Contact field for Service request

(1) The website of SR Suntour contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored.

(2) Such personal data transmitted on a voluntary basis by a data subject to the data controller are only stored for the purpose of providing service or contacting the data subject.

§ 9 Storage and protection of personal data


(1) We have taken a number of security measures to guarantee the safety of your personal data when you enter or place an order, or access your personal information. We adopt appropriate data collection, storage and processing practices, and security measures for protection against unauthorized access, changes, transfer, or destruction of personal data, user names, passwords, transactions, information and other data stored on our website. These processes can be maintained by our suppliers. The transfer of this data may include the processing and completion of information on our website, as well as the provision of support services. We take all appropriate measures to ensure that personal data is handled securely and according to our data protection guidelines.

(2) The information is protected in a secure environment by a combination of physical and technical measures. There is no public access to this information. All information provided can only be accessed by specially authorized persons with access rights to our system, who are obliged to treat the information as strictly confidential. In addition, national legislation might oblige us to store information for a certain period of time.

(3) The personal information collected on SR SUNTOUR websites is stored in a secure operating environment that is not publicly accessible. Sometimes the personal data is also encrypted with suitable security systems prior to the transaction.

(4) The exchange of sensitive and private data between SR SUNTOUR websites and visitors takes place via SSL secured communication channels, is encrypted and provided with digital signatures.

(5)           100% protection against unauthorized access in the case of data transfers across the internet or a website cannot be guaranteed, but we and our service providers and business partners do our utmost to protect your personal data in line with the prevailing data protection regulations by means of physical, electronic, and process-oriented security precautions in line with the current state of the art.

 

(6)           The following safeguards are used, for example, to protect your personal data from misuse or any form of unauthorized processing:

·        Access to personal data is restricted to a limited number of authorized persons for the stated purposes.

·        The data collected is only transmitted in encrypted form.

·        Sensitive data is also only stored in encrypted form.

·        The IT systems used for processing data are technically isolated from other systems to prevent unauthorized access and hacking.

·        Access to these IT systems is constantly monitored to detect and prevent misuse in the early stages.

(7) The data protection laws are governed by the principle that personal data is only to be stored for as long as it is necessary for the purposes for which it is processed.

We only store your personal data only as long as required for the intended purpose. If data is processed for multiple purposes, it will be deleted, or only stored in a form that cannot be directly traced back to you, as soon as no longer needed for the final specified purpose.

(8) To ensure that all of your data are deleted in line with the principle of data minimization and article 17 of the basic EU data protection regulations, SR Suntour has created an internal deletion concept.

§ 9 Links to external websites

The website may contain hyperlinks to external websites that do not belong to the SR SUNTOUR organization. If you visit such websites, SR SUNTOUR can no longer be responsible for the treatment of your data as confidential. The transmission of your data from the Internet occurs in part unencrypted. Consequently, unauthorized access by third parties cannot be entirely excluded.

§ 10 Whom do we grant international access to your data and how do we ensure protection

(1) Sr Suntour is a company that partly operates globally. Personal data are processed by SR Suntour employees, and by service providers we have commissioned, preferably within the EU.

(2) If data are processed in countries outside of the EU, SR Suntour uses EU standard contracts, including suitable technical and organizational measures, to ensure that your personal data are processed at the same level as European data protection.

(3) In some countries outside the EU, the EU has already determined a level of data protection comparable with that in Europe. The comparable level of data protection means that data transfer into these countries does not require any special permission or agreement [Is it just Taiwan where the data is received as well?].

(4) SR SUNTOUR conducts business in many countries of the world. To be able to offer our customers uniform services, regardless of their location, we maintain home pages and websites around the world. When you transfer personal information to SR SUNTOUR, you agree that this information may be transmitted across national borders and be stored and processed in each of the countries in which SR SUNTOUR and its group companies have offices. A list of all group companies can be viewed here:

·       SR SUNTOUR INC., #7 Hsing Yeh Road, Fu Hsing Industrial Zone Chang Hua, Taiwan, R.O.C., Tel: +886- (0)4-769-5115, Fax: +886- (0)4-769-4028, E-mail: orders@srsuntour.com.tw

 

·       SR SUNTOUR EUROPE Ltd., Riedstrasse 31, 83627 Warngau, Germany, Tel: +49 (0)802 150 793-0, Fax: +49 (0)802 150 793-29, Email: service@srsuntour-cycling.com

 

 

·       SR SUNTOUR North America, 7509 S 5th Street, Suite 124, Ridgefield, Washington 98642 USA, Tel: 1-360-737-6450, Sales e-mail: ssna@srsuntourna.com, Service and warranty e-mail: service@srsuntourna.com

(5) To support the provision of the services and intended purposes listed above, SR Suntour uses a number of service providers that are commissioned by SR Suntour within the framework of the strict conditions of data processing in compliance with data protection legislation.

§ 11 Rights of the data subject.

(1) As the party affected by the processing of your data, you may claim certain rights under the GDPR and other relevant data protection regulations. Under the GDPR, you are entitled to claim the following specific rights vis-à-vis SR SUNTOUR as the data subject:

Right of access by the data subject (Art. 15 GDPR):

You have the right to request information on the data we hold about you from us at any time. This information includes, but is not limited to, the categories of data we process, the purposes for which it is processed, the source of the data if not collected directly from you, and, if applicable, the recipients with whom we have shared your data. You can obtain a copy of your data from us free of charge. If you require additional copies, we reserve the right to charge you for these copies.

Right to rectification (Art. 16 GDPR):

You have the right to request that we rectify inaccurate data relating to you. We will take appropriate steps to keep the data we store and process on an ongoing basis accurate, complete and current, based on the most up-to-date information available.

Right to erasure (Art. 17 GDPR):

You have the right to request that we erase your data, as long as the legal requirements for this are satisfied. This may be the case under Art. 17 GDPR if

  • the data is no longer required for the purposes for which it was collected or otherwise processed;
  • you withdraw the consent on which data processing is based, and there is no other legal basis for processing;
  • you lodge an objection to the processing of your data and there are no legitimate reasons for processing, or you object to data processing for direct marketing purposes;
  • the data was processed unlawfully,

and provided that processing is not required

  • to ensure compliance with a legal obligation that requires us to process your data
  • especially with regard to statutory retention periods;
  • to establish, exercise or defend legal claims.

Right to restriction of processing (Art. 18 GDPR):

You have the right to request that we restrict processing of your data if

  • you dispute the accuracy of the data – in which case processing may be restricted during the time it takes to verify the accuracy of the data;
  • processing is unlawful, and you reject erasure of your data, requesting that its usage be restricted instead;
  • we no longer need your data, but you need it to establish, exercise or defend your rights;
  • you have lodged an objection to its processing, as long as it is not certain that our legitimate reasons outweigh yours.

Right to data portability (Art. 20 GDPR):

You have the right to request that we transfer your data – if technically possible – to another responsible party. However, you may only enforce this right if data processing is based on your consent or is necessary for the performance of a contract. Rather than receiving a copy of your data, you may also ask us to submit the data directly to another responsible party specified by you.

Right to object (Art. 21 GDPR):

(1) You have the right to object to the processing of your data at any time for reasons that arise from your particular situation, as long as data processing is based on your consent, on our legitimate interests or those of a third party. In this case, we will cease to process your data. This does not apply if we can show that there are compelling legitimate grounds for processing that outweigh your interests, or if we need your data for the establishment, exercise or defence of legal claims.

(2) SR SUNTOUR takes your concerns and rights very seriously. However, if you believe that we have not responded in an appropriate manner to your complaints or concerns, you have the right to lodge a complaint with your local data protection authority.

(3) We make every effort to comply with all requests within 30 days. However, this period may be extended for reasons relating to the specific right or complexity of your request.

(4) In certain situations, we may be unable to provide you with information about all your data, due to legal requirements. If we are unable to fulfil your request for information in such a case, we will notify you of the reasons.

§ 12 SR SUNTOUR' commitment to protecting the privacy of children


The protection of children's data is important to us. For this reson we do not collect or maintain any data of children who are, to our knowledge, under 14 years of age without first obtaining the verifiable consent of the parents or guardian. In addition, we require only so much personal information from children as is absolutely necessary for their participation in activities.

§ 13 Modifications to this privacy policy


Due to the fast development of the Internet and the legal situation, it may be necessary to make occasional changes to our Privacy Policy. Accordingly, please always take note the currently applicable version.

§ 14 Acceptance of this Privacy Policy


By using this Privacy Policy, visitors declare that they have read and understood it, and that they accept its exclusive validity. Acceptance of this Privacy Policy does not replace explicit consent to data processing.

§ 15 Contact


If you have any questions that have not been answered by this Privacy Policy, or if you require more detailed information on a particular point, please feel free to contact SR SUNTOUR at any time at the following address:

SR Suntour Europe Ltd.
SR SUNTOUR EUROPE Ltd., Riedstrasse 31, 83627 Warngau, Germany, Tel: +49 (0)802 150 793-0, Fax: +49 (0)802 150 793-29, Email:
service@srsuntour-cycling.com

This policy was last updated on May 24th, 2018.

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