1. Introduction

  1. We are committed to safeguarding the privacy of the people (“you”) using the Trimm products, applications, services and/or visiting websites under trimm.bike developed and provided by Trimm LLC, originally Ratio LLC in Korea (“Trimm”, “we”, “us” and “our”).
  2. This policy applies where we are acting as a data controller with respect to the personal data of the Users; in other words, where we determine the purposes and means of the processing of that personal data.
  3. We may use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of trimm.bike, we will ask you to consent to our use of cookies when you first visit our website.

2. Credit

  1. This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

  1. In this Section 3 we have set out:
    1. the general categories of personal data that we may process;
    2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
    3. the purposes for which we may process personal data; and
    4. the legal bases of the processing.
  2. We may process data about your use of our website and services
    (“usage data”). The usage data may include your IP address,
    geographical location, browser type and version, operating system,
    referral source, length of visit, page views and website
    navigation paths, as well as information about the timing,
    frequency and pattern of your service use. The source of the usage
    data is our analytics tracking system. This usage data may be
    processed for the purposes of analysing the use of the website and
    services. The legal basis for this processing is our legitimate
    interests, namely monitoring and improving our website and
    services.
  3. We may process your account data (“account data”). The account
    data may include your name, email address and/or the account
    identifiers of the portal sites, such as Google and Facebook. You
    are the source of the account data. The account data may be
    processed to authenticate and manage your account and data. The
    legal basis for this processing is our legitimate interests,
    namely he proper administration of our Services.
  4. We may process your personal information included in your
    personal profile in our server (“profile data”). The profile data
    may include your name, height, weight, gender and date of birth. The
    profile data may be processed to restore your back-up into a new
    environment. The legal basis for this processing is our legitimate
    interests, namely the proper administration of our website and
    business.
  5. We may process your personal data that are provided in the
    course of the use of our services (“service data”). The service
    data may include your geographic location traces, exercise
    statistics such as speed, distance, altitude, calories, power,
    heart rates and cadences during the active use of the
    Services. It may also include your route plans. You are the
    source of the service data. The service data may be processed to
    be shown in multiple platforms, to maintain the back-ups and to
    restore the data onto your new application platform. We use
    de-identified service data to enhance the map and routing
    service. The legal basis for this processing is consent.
  6. We may process information that you post for publication on our
    website or through our services (“publication data”). The
    publication data may be processed for the purposes of enabling
    such publication and administering our website and services. The
    legal basis for this processing is our legitimate interests,
    namely the proper administration of our website and business.
  7. We may process information contained in any enquiry you submit
    to us regarding goods and/or services (“enquiry data”). The
    enquiry data may be processed for the purposes of offering,
    marketing and selling relevant goods and/or services to you. The
    legal basis for this processing is consent.
  8. We may process [information relating to our customer
    relationships, including customer contact information] (“customer
    relationship data”). The customer relationship data may include
    your name, your contact details, and information contained in
    communications between us and you. You are the source of the
    customer relationship data. The customer relationship data may be
    processed for the purposes of managing our relationships with
    customers, communicating with customers, keeping records of those
    communications and promoting our products and services to
    customers. The legal basis for this processing is our legitimate
    interests, namely the proper management of our customer
    relationships.
  9. We may process information relating to transactions, including
    purchases of goods and services, that you enter into with us
    and/or through our website (“transaction data”). The transaction
    data may include your contact details, your card details and the
    transaction details. The transaction data may be processed for the
    purpose of supplying the purchased goods and services and keeping
    proper records of those transactions. The legal basis for this
    processing is the performance of a contract between you and us
    and/or taking steps, at your request, to enter into such a
    contract and our legitimate interests, namely the proper
    administration of our website and business.
  10. We may process information that you provide to us for the purpose
    of subscribing to our email notifications and/or newsletters
    (“notification data”). The notification data may be processed for
    the purposes of sending you the relevant notifications and/or
    newsletters. The legal basis for this processing is the performance
    of a contract between you and us and/or taking steps, at your
    request, to enter into such a contract.
  11. We may process information contained in or relating to any
    communication that you send to us (“correspondence data”). The
    correspondence data may include the communication content and
    metadata associated with the communication. Our website will
    generate the metadata associated with communications made using
    the website contact forms. The correspondence data may be
    processed for the purposes of communicating with you and
    record-keeping. The legal basis for this processing is our
    legitimate interests, namely the proper administration of our
    website and business and communications with users.
  12. We may process any of your personal data identified in this
    policy where necessary for the establishment, exercise or defence
    of legal claims, whether in court proceedings or in an
    administrative or out-of-court procedure. The legal basis for this
    processing is our legitimate interests, namely the protection and
    assertion of our legal rights, your legal rights and the legal
    rights of others.
  13. We may process any of your personal data identified in this
    policy where necessary for the purposes of obtaining or
    maintaining insurance coverage, managing risks, or obtaining
    professional advice. The legal basis for this processing is our
    legitimate interests, namely the proper protection of our business
    against risks.
  14. In addition to the specific purposes for which we may process
    your personal data set out in this Section 3, we may also process
    any of your personal data where such processing is necessary for
    compliance with a legal obligation to which we are subject, or in
    order to protect your vital interests or the vital interests of
    another natural person.
  15. Please do not supply any other person’s personal data to us,
    unless we prompt you to do so.

4. Providing your personal data to others

  1. We may disclose your personal data to our insurers and/or
    professional advisers insofar as reasonably necessary for the
    purposes of obtaining or maintaining insurance coverage, managing
    risks, obtaining professional advice, or the establishment, exercise
    or defence of legal claims, whether in court proceedings or in an
    administrative or out-of-court procedure.
  2. Financial transactions relating to the may be handled by our
    payment services providers, such as Apple Inc. We will share
    transaction data with our payment services providers only to the
    extent necessary for the purposes of processing your payments,
    refunding such payments and dealing with complaints and queries
    relating to such payments and refunds. You can find information
    about the payment services providers’ privacy policies and practices
    at their websites.
  3. We may disclose your enquiry data to one or more of those selected
    third party suppliers of goods and services identified on our
    website for the purpose of enabling them to contact you so that they
    can offer, market and sell to you relevant goods and/or
    services. Each such third party will act as a data controller in
    relation to the enquiry data that we supply to it; and upon
    contacting you, each such third party will supply to you a copy of
    its own privacy policy, which will govern that third party’s use of
    your personal data.
  4. In addition to the specific disclosures of personal data set out
    in this Section 4, we may disclose your personal data where such
    disclosure is necessary for compliance with a legal obligation to
    which we are subject, or in order to protect your vital interests
    or the vital interests of another natural person. We may also
    disclose your personal data where such disclosure is necessary for
    the establishment, exercise or defence of legal claims, whether in
    court proceedings or in an administrative or out-of-court
    procedure.
  5. Your personal data is hosted by Google Firebase, which is comply
    with EU-US Privacy Shield framework. Its data processing and
    security terms related to the framework is shown at
    https://firebase.google.com/terms/data-processing-terms.
  6. You acknowledge that personal data that you submit for publication
    through our website or services may be available, via the internet,
    around the world. We cannot prevent the use (or misuse) of such
    personal data by others.

5. Retaining and deleting personal data

  1. This Section 5 sets out our data retention policies and
    procedure, which are designed to help ensure that we comply with
    our legal obligations in relation to the retention and deletion of
    personal data.
  2. Personal data that we process for any purpose or purposes shall
    not be kept for longer than is necessary for that purpose or those
    purposes.
  3. We will retain your personal data as follows:
    1. Your usage data will be retained up to one year.
    2. Your account, profile and service data can be retained until
      you request to erase your account or the data. The erasure can
      take up to 30 days.
    3. Your enquiry and notification data will be retained until
      you request to unsubscribe. The erasure can take up to 30
      days.
    4. Notwithstanding the other provisions of this Section 6, we
      may retain your personal data where such retention is
      necessary for compliance with a legal obligation to which we
      are subject, or in order to protect your vital interests or
      the vital interests of another natural person.

6. Amendments

  1. We may update this policy from time to time by publishing a new
    version on our website.
  2. You should check this page occasionally to ensure you are happy
    with any changes to this policy.
  3. We may notify you of significant changes to this policy by
    e-mail.

7. Your rights

  1. You have the right to confirmation as to whether or not we
    process your personal data and, where we do, access to the
    personal data, together with certain additional information. That
    additional information includes details of the purposes of the
    processing, the categories of personal data concerned and the
    recipients of the personal data. Providing the rights and freedoms
    of others are not affected, we will supply to you a copy of your
    personal data. The first copy will be provided free of charge, but
    additional copies may be subject to a reasonable fee. You can
    access your personal data by visiting https://trimm.bike when
    logged into our website or by using our Trimm applications.
  2. You have the right to have any inaccurate personal data about
    you rectified and, taking into account the purposes of the
    processing, to have any incomplete personal data about you
    completed.
  3. In some circumstances you have the right to the erasure of your
    personal data without undue delay. Those circumstances include:
    the personal data are no longer necessary in relation to the
    purposes for which they were collected or otherwise processed; you
    withdraw consent to consent-based processing; you object to the
    processing under certain rules of applicable data protection law;
    the processing is for direct marketing purposes; and the personal
    data have been unlawfully processed. However, there are exclusions
    of the right to erasure. The general exclusions include where
    processing is necessary: for exercising the right of freedom of
    expression and information; for compliance with a legal
    obligation; or for the establishment, exercise or defense of legal
    claims.
  4. In some circumstances you have the right to restrict the
    processing of your personal data. Those circumstances are: you
    contest the accuracy of the personal data; processing is unlawful
    but you oppose erasure; we no longer need the personal data for
    the purposes of our processing, but you require personal data for
    the establishment, exercise or defence of legal claims; and you
    have objected to processing, pending the verification of that
    objection. Where processing has been restricted on this basis, we
    may continue to store your personal data. However, we will only
    otherwise process it: with your consent; for the establishment,
    exercise or defence of legal claims; for the protection of the
    rights of another natural or legal person; or for reasons of
    important public interest.
  5. You have the right to object to our processing of your personal
    data on grounds relating to your particular situation, but only to
    the extent that the legal basis for the processing is that the
    processing is necessary for: the performance of a task carried out
    in the public interest or in the exercise of any official
    authority vested in us; or the purposes of the legitimate
    interests pursued by us or by a third party. If you make such an
    objection, we will cease to process the personal information
    unless we can demonstrate compelling legitimate grounds for the
    processing which override your interests, rights and freedoms, or
    the processing is for the establishment, exercise or defence of
    legal claims.
  6. You have the right to object to our processing of your personal
    data for direct marketing purposes (including profiling for direct
    marketing purposes). If you make such an objection, we will cease
    to process your personal data for this purpose. The benefits given
    for the processing will be cancelled if there exist.
  7. You have the right to object to our processing of your personal
    data for scientific or historical research purposes or statistical
    purposes on grounds relating to your particular situation, unless
    the processing is necessary for the performance of a task carried
    out for reasons of public interest.
  8. To the extent that the legal basis for our processing of your
    personal data is:

    1. consent; or
    2. that the processing is necessary for the performance of a
      contract to which you are party or in order to take steps at your
      request prior to entering into a contract,

    and such processing is carried out by automated means, you have the
    right to receive your personal data from us in a structured,
    commonly used and machine-readable format. However, this right does
    not apply where it would adversely affect the rights and freedoms of
    others.

  9. If you consider that our processing of your personal information
    infringes data protection laws, you have a legal right to lodge a
    complaint with a supervisory authority responsible for data
    protection.
  10. To the extent that the legal basis for our processing of your
    personal information is consent, you have the right to withdraw
    that consent at any time. Withdrawal will not affect the
    lawfulness of processing before the withdrawal.
  11. You may exercise any of your rights in relation to your personal
    data by written notice to us OR by e-mail to
    privacy@trimm.bike.

8. About cookies

  1. A cookie is a file containing an identifier (a string of letters
    and numbers) that is sent by a web server to a web browser and is
    stored by the browser. The identifier is then sent back to the
    server each time the browser requests a page from the server.
  2. Cookies may be either “persistent” cookies or “session” cookies:
    a persistent cookie will be stored by a web browser and will
    remain valid until its set expiry date, unless deleted by the user
    before the expiry date; a session cookie, on the other hand, will
    expire at the end of the user session, when the web browser is
    closed.
  3. Cookies do not typically contain any information that personally
    identifies a user, but personal information that we store about
    you may be linked to the information stored in and obtained from
    cookies.

9. Cookies that we use

  1. We use cookies for the following purposes:
    1. authentication – we use cookies to identify you when you
      visit our website and as you navigate our website;
    2. status – we use cookies to help us to determine if you are
      logged into our website;
    3. personalisation – we use cookies to store information about
      your preferences and to personalise the website for you;
    4. security – we use cookies as an element of the security
      measures used to protect user accounts, including preventing
      fraudulent use of login credentials, and to protect our
      website and services generally;
    5. advertising – we use cookies to help us to display
      advertisements that will be relevant to you;
    6. analysis – we use cookies to help us to analyse the use and
      performance of our website and services; and
    7. cookie consent – we use cookies to store your preferences in
      relation to the use of cookies more generally.

10. Cookies used by our service providers

  1. Our service providers use cookies and those cookies may be
    stored on your computer when you visit our website.
  2. We use Google Analytics to analyse the use of our
    Services. Google Analytics gathers information about the Services
    use by means of cookies. The information gathered relating to our
    Services is used to create reports about the use of our
    Services. Google’s privacy policy is available at:
    https://www.google.com/policies/privacy/.
  3. We may publish Google AdSense interest-based advertisements on
    the Services. These are tailored by Google to reflect your
    interests. To determine your interests, Google will track your
    behaviour on our website and on other websites across the web
    using cookies You can view, delete or add interest categories
    associated with your browser by visiting:
    https://adssettings.google.com. You can also opt out of the
    AdSense partner network cookie using those settings or using the
    Network Advertising Initiative’s multi-cookie opt-out mechanism
    at: http://optout.networkadvertising.org. However, these opt-out
    mechanisms themselves use cookies, and if you clear the cookies
    from your browser your opt-out will not be maintained. To ensure
    that an opt-out is maintained in respect of a particular browser,
    you may wish to consider using the Google browser plug-ins
    available at: https://support.google.com/ads/answer/7395996

11. Managing cookies

  1. Most browsers allow you to refuse to accept cookies and to
    delete cookies. The methods for doing so vary from browser to
    browser, and from version to version. You can however obtain
    up-to-date information about blocking and deleting cookies via
    these links:

    1. https://support.google.com/chrome/answer/95647?hl=en
      (Chrome);
    2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
      (Firefox);
    3. http://www.opera.com/help/tutorials/security/cookies/
      (Opera);
    4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
      (Internet Explorer);
    5. https://support.apple.com/kb/PH21411 (Safari); and
    6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
      (Edge).
  2. Blocking all cookies will have a negative impact upon the
    usability of many websites.
  3. If you block cookies, you will not be able to use all the
    features on our website.

12. Our details

  1. This website is owned and operated by Ratio LLC in South
    Korea
  2. We are registered in South Korea, and our registered office is at:
    12, Muwon-ro 6beongil, Rm 505, Deogyang-gu, Goyang-si, Gyeonggi, 10523
    South Korea