1. The data handling companies:

Handlebars Repairs Ltd, trading as Fettle ("we" or "us") and Hubtiger Pty Ltd (together “The Companies” take the privacy of your information very seriously. This policy explains how and for what purposes we use the information collected about you via our website, and apps (referred to below as "the Service"). Please read this privacy policy carefully. By using the Service you are agreeing to be bound by this policy in respect of the information collected about you via this Site.The Companies work in partnership to deliver service. Your data is handled by the companies in line with the below requirements. If you have any queries about the policy, please get in touch and we will do our best to answer your questions.

2. Understanding personal information:

(a) The term “personal information” has the meaning given to it in the above Act, or that which is given to it under the law of the country in which you are based or use the platform. Generally, it is any information that can be used to personally identify You. This may include Your name, surname, address, telephone number, email address and/or occupation. Should the information we collect personally identify You, or You are reasonably identifiable from it, the information will be considered personal information. Your Personal Information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

(b) The processing of Personal Information shall include the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation, use; dissemination by means of transmission, distribution or making available in any other form; or merging, linking, as well as blocking, degradation, erasure or destruction of information.

(c) The companies strive to ensure that the conditions set out in the Act and all the measures that give effect to such conditions, are complied with when processing Personal Information or data. The companies strive to ensure that Personal Information and Personal data is processed in a manner that is lawful, adequate, relevant and not excessive given the purpose of collection.

(d) You hereby grant consent for Strava to provide registration and other relevant information fields of your account to The companies. Use of such third-party credentials to log you into your account entails the agreement to the third-party network terms, conditions and policies.

3. Personal information collected:

(a) The Platform collects and processes information that can be used to identify You personally (“Personal Information”) that is necessary to providing, facilitating and maintaining the The companies services.

(b) We collect Personal Information from the following entities:natural persons over 18;Users who have signed up to use the Application;Facebook, Apple or Strava for Users who wish to log into the The companies Application using an existing Facebook, Apple or Strava account;Data caches and logs from our internet service provider;

Personal Information collected by The companies may include:

i. Name and surname;
ii. Email address;
iii. Age and date of birth;
iv. Gender;
v. Telephone number;
vi. Location information;
iiv. Computer IP address

(d) Where You register or log-in to your account by means of Facebook or Strava, You hereby grant consent for Facebook or Strava to provide registration and other relevant information fields of your account to The companies. Use of such third-party credentials to log You into Your account entails the agreement to the third-party network terms, conditions and policies.

(e) Geographic location information is only collected when your device has location settings enabled. You are permitted to use the Application without sharing Your geographic location. However, You are informed that disabling Your geographic location settings will hinder The companys’ ability to provide You with the full extent of The companies services.


(f) We may also collect Personal Information through Your access and use of the Platform and through Your participation in various activities on the Platform.

(g) There may be instances where we may also collect some information that is not Personal Information because it does not identify You or anyone else (we may collect aggregated information about how You use our Application).

(h) If You use our Platform, you understand that The companies collect and track non-personal information such as booking history, photos, reviews, mileage, gear settings and service history, routes planned and events attended. This information is required for The companies to provide You with the services.

(i) If You do not want us to collect Personal Information about You, do not submit Your Personal Information to The companies.

4. Payment details
Payment method details you provide (including card number, expiry date, CVV, name, email address and sometimes address) are sent directly to PCI-compliant third party payment providers. They are not stored on the Companies’ servers and the Companies’ employees do not have access to these details.

5. Purpose of collecting personal information
The primary purpose for collecting and processing Your Personal Information is to enable us to provide You access to the Platform. The companies also collects and processes Your Personal Information in order:

i. to create and administer Your account;
ii. to track bicycle components usage in order to provide Users with service indicators;
iii. to enable cycling service providers to better understand the needs of cyclists;
iv. to track cycling routes, distance and times;
v. to track incidents and alert cyclists;
vi. to process and respond to any complaint made by You;
vii. to process and respond to any complaint made by You;
viii. to engage in legitimate electronic communications with You;
ix. to provide feedback on any related enquiries;
x. to provide You with direct marketing material;
xi. to update our records and keep Your contact details up to date;
xii. to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.

b) We are also able to use the information collected to improve our internal technical and business processes. Measure cycling route patterns and bicycle parts usage in the aggregate, analyse trends, administer the The companies service, track Users’ actions and gather broad demographic information.

6. Consent to processing personal information

a) By using the Platform, You hereby consent to Your Personal Information being used for the above mentioned purposes, associated purposes and to:

i. update our records;
ii. keep Your contact details up to date;
iii. to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or co-operate with any governmental authority of any country.

b) By Using the Platform You affirm that you have read and understood this privacy policy and that you consent to the processing of Personal Information as set out in this privacy policy.

c) Personal Information may be processed by The companies in the country where it was collected as well as other countries where laws regarding processing of Personal Information differ. The consent to receive direct marketing from The companies is obtained during the registration process. By completing that registration process and continuing to use the platform, You agree and confirm that you have provided informed consent to the receipt of direct marketing communications regarding all business activities and news, subject always, to your right to unsubscribe from our direct marketing communications or to withdraw Your consent from receipt of the same.

7. Handling of personal information

a) The companies seek to ensure the quality, accuracy and confidentiality of Personal Information in its possession. You warrant that all Personal Information supplied by You is both true and correct at the time of provision. In the event of any aspect of Your Personal Information changing post submission, it is Your responsibility to update Your profile information either via the Platform.

b) You warrant that You have the authority, permissions and consent to provide The companies with any third party information submitted to The companies.

c) The companies will take all reasonable measures in order to ensure Your Personal Information is appropriately safeguarded, these precautions include, but are not limited to: access control mechanisms via username and password, and software protection for information for security.

d) Should an unauthorised person/s gain access to Your Personal Information The companies will contact You within a reasonable time to inform You of such access.

e) The companies share Your Personal Information with authorised third parties such as the bicycle retailers and servicing shops. Additionally The companies may share aggregated personal information with Service Providers as well as internet service providers. The companies does not permit these parties to use such information for any other purpose than to perform the services that The companies has engaged with them to provide. All processing is compatible with such purpose.

8. Retention and restriction of records

a) On receipt of instructions from You, The companies will destroy or delete a record of Personal Information about You which The companies is no longer authorised to retain. This is subject to certain exceptions such as retaining records that The companies are required by law to retain. The companies are entitled to retain de-identified information for authorised or legitimate purposes.

b) In the event that You wish to revoke all consent pertaining to Your Personal Information and/or You would like The companies to remove and/or delete Your Personal Information entirely, You should cancel your account and You may request The companies to delete all of Your Personal Information by emailing hello@fettle.cc.

c) You expressly consent to The companies retaining Your Personal Information once Your relationship with The companies has been terminated for evidential purposes and using the information for aggregate, statistical and reporting purposes.

d) Records relating to the provision of information to and/or by You can be retained by The companies in terms of legislative records retention provisions and includes Your Personal Information.

e) The companies retain records for a period that is longer than is required by law for statistical or research purposes and You hereby consent to such retention of Personal Information.

9.Updating of personal information

a) You may request access to any Personal Information we hold about You at any time by sending an email to hello@fettle.cc.

b) If You believe that Personal Information we hold about You is incorrect, incomplete or inaccurate, then You may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment or that we cannot amend the information as required, we will retain a note about the request.

c) Your Account information is accessible by You at any time. You are entitled to amend, delete or add information to your Account at any time.

d) There may be instances where we cannot grant You access to the Personal Information we hold. We may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. Should this be the case, we will give You written reasons for any refusal.

10.Sharing your personal information

a) Business records relating to the provision of information or the application to You can be retained by The companies in terms of legislative records retention provisions and includes Your Personal Information. Records can be retained for operational purposes or for evidential purposes. Where The companies share Your Personal Information with employees and other Users, The companies do not permit such parties to use the information for any other purpose than those pertaining to using, maintaining and/or running the service.

b) We may disclose Your Personal Information to:
i. our employees to enable us to operate;
ii. fulfil requests by You, and to otherwise provide information and services to You;
iii. Service Providers to allow them to assist in the provision of products or services to You;
iiv. any organisation for any authorised purpose with Your express consent.

c) Where The companies share Your Personal Information with others, The companies do not permit such parties to use the information for any other purpose than those pertaining to using, maintaining, administering and/or running the The companies services.

d) We may further disclose Your Personal Information in the following instances:

i. To comply with the law or legal process;
ii. To protect The companies rights, facilities and other property;
iii. To protect The companies against any misuse or unauthorised use of the Platform; and
To protect Users or third parties affected negatively by Your action in using the Platform.
v. We will disclose Personal Information to our Service Providers who use software programmes and hardware devices to monitor usage in order to identify unauthorised attempts to access, upload, damage and/or alter information that it has stored.

e) Personal Information is stored on servers outside of the United Kingdom and South Africa. Your Personal Information may be stored on servers and be subject to different data protection laws. You hereby consent that your Personal Information may be sent cross border to be stored on such servers.

f) We have placed security safeguards to protect Your Personal Information through agreements concluded with third party Service Providers. We will not be held liable for any illegal activity or other activity that may result in a claim for damages due to lack of protection of Your Personal Information whilst under the care of the third party.

11. Uploading personal information

a) If You are uploading Personal Information in connection with Your use of the Platform, You undertake that You are responsible for compliance with privacy and confidentiality regulations impacting You and hereby warrant that:

i) You have the right and/or consent to upload the Personal Information. Such consent must be given by You as it relates to Your use of the Platform.
ii) You are cognisant that processing of types of Personal Information regarded as sensitive without consent is prohibited.
iii) You are aware of specific purposes of collection of Your Personal Information.
iv) The company's processing of Personal Information is reasonably associated with the purpose for which it was collected and/or the consent obtained.
v) You do not object to the processing of Your Personal Information by The companies.
vi) You have taken reasonably practicable steps to ensure that the Personal Information is complete, accurate, not misleading and updated where necessary, taking into account the purposes for which it was collected.
vii) You agree that The companies will not be held liable for any illegal activity or other activity that may result in a claim for damages due to lack of protection of the Personal Information whilst under the care of third parties.

12. Security of safeguards

a) We take reasonable steps to ensure that Your Personal Information is protected from misuse, loss and from unauthorised access, modification or disclosure. We cannot guarantee, however, the absolute security of Your Personal Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond our reasonable control.

b) We use third parties who have access to Your Personal Information and who have undertaken to protect Your Personal Information.

c) We will notify You via both email and cell-phone should we have cause to believe that Your Personal Information may have been accessed or used in an unauthorised manner.

d) As our Application is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information You communicate to us online. We also cannot guarantee that the information You supply will not be intercepted while being transmitted over the internet. Accordingly, any Personal Information or other information which You transmit to us online is transmitted at Your own risk.

13. Indemnity

a) You agree to indemnify and hold The companies, its officers, directors, employees, agents, licensors, suppliers and members harmless from and against any claims, damages, actions and liabilities including without limitation, loss of profits, direct, indirect, incidental, special, consequential or punitive damages arising out of reliance Your Personal Information should Your Personal Information contain any errors, inaccuracies or be irrelevant to the use of the Application.

14. Data subject participation

a) Should You have enquiries concerning Personal Information processed by The companies, You can request feedback that describes the Personal Information held by The companies, and information about third parties, or categories of third parties who provide services to The companies, who have, or have had, access to the information. You may request that The companies correct or delete Your Personal Information in its possession or under its control that is inaccurate, irrelevant, excessive, misleading or obtained unlawfully; or destroy or delete any Personal Information that The companies is no longer authorised to retain. As a User, You have access to Your Personal Information via the Application and the Website.

b) In addition to the above, users entitled to broader protection standards may exercise any of the rights described below:

i) Learn whether data relating to you is being processed.
ii) Request further information if personal data relating to you has been processed.
iii) Learn the purpose for the processing of personal data and whether data is being processed in compliance with such purpose.
iv) Request a copy of your personal data which The companies hold.
v) Learn to which third party recipients your data is disclosed.
vi) Request rectification of the processed personal data which is incomplete or inaccurate and request such process to be notified to any third persons to whom personal data is transferred.
vii) Request deletion or destruction of personal data in the event that the data is no longer necessary in relation to the purpose for which the personal data was collected, despite being processed in line with the law and other applicable laws and request such process to be notified to any third persons to whom the personal data is transferred.
viii) Obtain the personal data you provided upon setting up your account or with your consent in a structured, machine-readable format, and to ask The companies to share (port) this data to another controller.
ix) Object to negative consequences that you experienced as a result of analysis of the processed personal data by solely automatic means.
x) Object to the processing of your personal data in some circumstances (in particular where The companies does not have to process the data to meet a contractual or other legal requirement, or where The companies is using the data for direct marketing purposes.

c) If you have unresolved concerns you have the right to complain to a EU or UK data protection authority where you live, work or where you believe a breach may have occurred.

d) Under the GDPR, these rights may be limited, for example it fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including The companies’ rights) or if you ask for the deletion of information which The companies is required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in the GDPR. The companies will inform you of relevant exemptions relied upon when responding to any requests you make.

15. Openness

a) If You have any additional questions or concerns about our privacy practices, we invite You to contact us by email at hello@fettle.cc and we will address Your concerns to the best of our ability.

b) We will treat Your requests or complaints confidentially.

16. Lawful bases (EEA or UK)

a) Lawfulness of personal data processing is an important principle under the GDPR. For purposes of the data protection law of the EU or UK, we typically process personal data were:

b) We need to perform the contract we are about to enter into or have entered into with you, such as when we process a payment.

c) It is in our legitimate interest or those of a third party and your data protection rights and freedoms do not override those interests such as when we secure the services, engage in fraud prevention and certain direct marketing.

d) We need to comply with a legal or regulatory obligation.

e) We have your consent to use your personal data.

f) Notice to users from the EEA or UK

g) Personal Information that we collect and use may be processed outside your country or region. When we share personal information with third parties in other countries, we apply appropriate safeguards. For example, data covered by the data protection laws of the EEA and UK are typically protected by EU Model clauses. By using our services you:

h) Acknowledge that your information will be processed as described in this Privacy Policy; and

i) Consent to having your information transferred to the facilities of third parties with whom we share information as described in this Privacy Policy, including the USA where the servers of some of the third-party platforms we use are located. Such third-party partners and/or staff operating outside the EEA or UK may process this information. The information may then be transferred back out of the United States to other countries outside of your country of residence, depending on the type of information and how we store it. These countries (including the USA) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personal data will at all times continue to be governed by this Privacy Policy.

j) By supplying your personal information to us you expressly agree to the transfer of your personal information out of the EEA or UK and to the processing of your information in the USA, subject to this Privacy Policy.

17. Cookies

i. When you visit the Site we may store some information (commonly known as a "cookie") on your computer.
ii. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords and credit card numbers are not stored in cookies. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service. We use cookies for the following purposes:
1. Enabling our web server to track your session between pages of the site and provide a continuity of experience.
2. You can block or erase cookies from your computer if you want to (your browser's help screen or manual should tell you how to do this), but certain parts of the Site are reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.

18. Other Sites

a) If you’ve managed to get this far, you’ve got way better endurance then we have. Drop us an email at ireadtsandcs@fettle.cc to redeem a little surprise.

b) We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Site and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

c) In addition, if you linked to this Site from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.




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