Privacy Policy

ENTOCYCLE LTD ("we" or “us”) are committed to protecting and respecting your privacy. This policy (together with our Terms of Use and any other documents linked to in our terms, collectively referred to as our End User Licence Agreement or EULA) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This includes data collected by the use of our website.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This privacy policy (the “Policy”) applies to personal data that we collect from you. It is important that you read this Policy so that you are fully aware of how and why we are using your data.

The Policy consists of the following sections:

1. Important information and who we are

The data controller who is responsible for your personal data is Entocycle LTD (company number 09203334), with its registered office at 29 Shand Street, London, United Kingdom, SE1 2ES. If you have any questions or concerns relating to your personal data or this Policy, please contact us using the following contact details: Email: info@entocycle.com Postal address: 29 Shand Street, London, United Kingdom, SE1 2ES

Whilst you have the right to make a complaint at any time to the Information Commissioner’s Office (www.ico.org.uk), the UK supervisory authority for data protection issues, we would appreciate the chance to deal with any concerns before you approach the ICO, so please feel free to contact us in the first instance using the contact details provided. 

The Information Commissioner’s Office can be contacted by post via: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone via 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number. 

If you are not in the UK, you can contact your local competent supervisory authority if you are in an EU or EEA member state. A list is available here: https://edpb.europa.eu/about-edpb/board/members_en.

2. Changes to this policy and your duty to let us know of changes

This Policy was last updated on 9th March 2022. We may need to make updates or changes to this Policy from time to time. We will inform you of any such changes when you visit our site or by email. Please let us know if your personal data changes during your relationship with us so that we can update our records.

3. Personal data we may collect from you

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and process the following types of personal data about you: 

Identity Data includes your name, username (or similar identifier), title, date of birth and gender. 

Contact Data includes billing address, delivery address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. 

Usage Data includes information about how you use our website and services. 

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data as it does not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

4. How we collect your personal data

We use different methods to collect data from and about you, including through: 

Information you give us: 

Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you subscribe to our mailing list and any other publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback. 

Information we collect when you visit our facility.

Information we collect about you and your device: As you interact with our website, or open a marketing email we have sent you, we may automatically collect:

Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below for further details.

Information we receive from Third Parties: We may receive personal data about you from various third parties as set out below: We may receive Technical Data from analytics providers such as Google Analytics and Contact Data from providers of technical services, including newsletter sign-up providers such as Mailchimp.

5. Uses made of your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. 

You have the right to withdraw consent to our use of this data at any time by contacting us or by amending your profile settings. We have set out below a description of all the ways we may use your personal data, and the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Purpose: To manage our relationship with you, which will include notifying you about changes to our terms or this Policy; asking you to leave a review or take a survey.

Type of data: identity, contact, profile, marketing and communications

Lawful basis for processing including basis of legitimate interest: performance of a contract with you, necessary to comply with a legal obligation, necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

Purpose/activity: to enable you to participate in a prize draw, competition, or complete a survey.

Type of data: identity, contact, profile, usage, marketing and communications.

Lawful basis for processing including basis of legitimate interest: performance of a contract with you; necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/activity: To administer and protect our business and this website and our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: identity, contact, technical

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation.

Purpose/activity: To deliver relevant website content to you and measure or understand the effectiveness of the communications we serve to you

Type of data: identity, contact, profile, usage, marketing and communications, technical.

Lawful basis for processing including basis of legitimate interest:  Your consent to cookies and other technologies, targeted marketing and use of location data; Otherwise as necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy; Your consent to the use of your photograph and image for our facial measurements software.

Purpose/activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data: technical, usage

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/activity: To enable us to make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data: identity, contact, technical, usage, profile

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

6. Maintenance and retention of personal data and your rights

You have certain rights in relation to your personal data. Please contact us by email, should you wish to:

- Request access to your personal data – enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.

- Request correction of your personal data – you may correct any inaccuracies or incomplete data although we may need to verify the accuracy of the new data you provide.

- Request erasure of your personal data - where there’s no good reason for us to continue to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with local law.

- Object to processing of your personal data – where we are relying on a legitimate interest and you object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may also object where we are processing your data for marketing purposes.Request restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

- Request transfer of your personal data – you may request that we transfer data to you or a third party. This only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

- Withdraw consent to our use of your personal data – where we are relying on consent. This will not affect the lawfulness of processing that we carried out before you withdraw consent. If you withdraw consent, we may not be able to provide products or services to you.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of these rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, in which case we will let you know and keep you updated. 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When your personal data is no longer retained, it is securely deleted and destroyed.

7. Cookies

Cookies are small amounts of information which we may store on your computer. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic to personalise the content of the site and our marketing for you. You may set up your computer to reject all or some cookies although, in that case, you may not be able to use certain features on the site. If you do not wish to receive cookies in the future, please let us know by emailing info@entocycle.com. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org . The following cookies are used by our website: 

- Google Analytics

We reserve the right to modify this Policy from time to time. Dated 9 March 2022