Privacy declaration
Windgoo Inc.

Last updated August 19, 2022

Windgoo values ​​your privacy
At Windgoo, we take your personal privacy seriously and recognize that you expect privacy and security for all of your personal information. We understand the need to protect and secure sensitive information about you, and we maintain strict standards and procedures designed to prevent misuse of your information.

We encourage you to read this privacy statement (the "Privacy Statement") carefully to understand the information we collect and what we do with it.

Windgoo Inc. and its affiliates and subsidiaries (collectively, "Windgoo," "us," "our," or "we") are responsible for your information. This privacy statement applies to our European Union website (“Windgoo Site” or “Site”). By accessing and using our site, you acknowledge that you have read, understood and do not object to our processing activities. Use of our global website (www.windgoo.co) or UK website (www.windgoo.uk) is subject to their respective privacy statements.

Your Windgoo Data Controller: Your data controller is the company that makes decisions about how and why your data is used, and for EU residents, Windgoo Inc.

This privacy statement describes how Windgoo collects, protects, uses and discloses information and data collected and created during your access and use of the Windgoo site, products and services, as well as your interactions with Windgoo by telephone, email or on our website. physical locations. It also explains your rights, which may differ depending on where you are located.

At certain points in your interaction with the Site, certain third-party service providers engaged by Windgoo (“Service Providers”) may be responsible for collecting information about you, your interactions with the Site, your preferences, your settings, or other general information. In other respects, you must provide various information to a Service Provider in order to use the services offered by Windgoo, including but not limited to making a purchase, financing a purchase, applying for a job or entering a competition. This privacy statement identifies instances where your information is collected, transmitted, or stored by a service provider, and in such instances, your information is subject to that service provider's terms and conditions and privacy policy. For more information about our service providers, see the "Accessing Your Information" section below.

Domain
Please note that this privacy statement applies to information we collect:

• when you visit the Site.
• when you provide your information to us on the site.
• when you create or use a user profile on the Site.
• when we communicate with you via email and other communications.
• through service providers we partner with to provide our services.
• in any other way during your use of our services.

How we collect your information

The only personal information we collect about you is either provided by you voluntarily or as described below under “Information Collected Through Your Use of the Site.” Windgoo does not collect biometric data or sensitive information related to health, race, gender or other special category data.

Information We Collect. If you visit or submit an application to our Sites, create an account, subscribe to a service, register to receive marketing materials, enter contests, sweepstakes or promotions, or receive other services, we may ask you to provide certain personal information , such as your name, email address, telephone number and zip code, and other personally identifiable information (“Personal Information”).

We take reasonable steps to ensure that we only ask for the information we need for the purposes stated in "How we use your information".

We also take steps to ensure that your contact information is accurate, complete, current and otherwise reliable.

We will only collect and process your personal information if we (a) obtain your consent, (b) have a legitimate interest in collecting and processing the data for our direct marketing purposes, or (c) where required or permitted by law .

We may periodically supplement the personal information we collect from you with personal or non-personal information about you or another person obtained from companies with which we have marketing or other business relationships and other outside sources. Any aggregated information associated with or linkable to your personal information will be treated by us as personal information under this privacy statement.

Children under 16 years old. Our site is not intended for children under the age of 16. No one under the age of 16 may provide any personal information to or on the Site. If you are under the age of 16, do not use or provide any information on this website or on or through any of its features/register on the site, do not make purchases through the site, do not use any of the interactive or public comment features of this site or provide us with information about yourself, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn that we have collected or received personal information from a child under the age of 16 without verification of parental consent, we will delete that information. If you believe we have information from or about a child under the age of 16, please contact us.

Payment Information. Windgoo does not collect or store any payment information. When you order an ebike or other products, all payments are processed through Shopify Inc. When you provide payment information on this site, it's submitted through Shopify's payment portal. All payment information and transactions are subject to Shopify's privacy policy and terms of use. If there are any issues processing an order, we will use your contact details to contact you to resolve such issues. We do not share your personal and financial information with third parties except as specified in this privacy statement.

Information Collected Through Your Use of the Site. We or a service provider may use Site analytics tools or other licensed technologies from third parties to collect information about you based on your use of this Site. This information may be combined with other information you provide to us. This information may also be aggregated into aggregate information about site visitors and traffic. We may also use analytics tools from third-party service providers to distinguish and analyze user behavior. Here are the details of how we do this and the reasons why:

• Log files. We or a service provider may collect anonymous and technical information from your computer, including your Internet Protocol address, information about your computer or other device, the type of browser or operating system your device uses, the programs, services, and version of software you use. used. use, and the address of any linking site, when you request a web page while visiting the Site. We use this information for statistical purposes, to ensure that our pages on our site appear and function correctly on your computer, to determine which site referred you to our site, and to personalize your access to our site or to perform our own analysis and research to improve our programs, products, services and content. We use service providers to collect and analyze information, and we reserve the right to change which service providers collect and analyze this information in the future. If you disagree with Windgoo or its service providers collecting and using your anonymous and technical information as described in this section, your choice is to stop using the site or contact us as described under "Controlling of your personal information".
• Cookies are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. Windgoo and our service providers use cookies to track usage of our sites and online services. Cookies may also be used to monitor traffic, improve the Sites, make the Sites easier and/or more relevant to your use, and improve the performance of our advertising on other Sites. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you receive a cookie. However, certain features of our Sites or other services may not work if you delete or disable cookies. For more information about cookies and how to disable them on your computer, visit: https://www.consumer.ftc.gov/articles/0042-online-tracking.
• web beacons . Some pages of our site and our emails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags and single-pixel gifs) that allow us or a service provider, for example, to count users who have visited those pages or opened an email and for other related site statistics (for example, registering the popularity of certain site content and verifying system and server integrity).
• Social Networking . If you visit one of our Sites from a social networking site (e.g., Facebook or Twitter), or otherwise agree to link your account with us through a social networking site, we may also receive personal information about you from such social networking site . Our receipt of your personal information through a social networking site is governed by the social networking site's terms of use and privacy policy. We may keep this information with the information we collect directly from you.

Information We Collect Offline. We collect information when you visit a Windgoo retail showroom to make a purchase/payment, complete a registration agreement, take a tour, test ride an ebike or submit an application to such retail showroom. This can be:

• Your personal contact details, such as your name, address, e-mail address and telephone number.
• Your sensitive personal information, such as your emergency contact and release information, driver's license number, and employer information.
• Your financial information needed to process a payment.
• Video recordings of your entrance and exit of our retail showroom.
• Information collected offline by third parties to facilitate services, such as credit card, bank or other payment related information.

How we use your information

We use your personal information for the purposes described at the time of collection and to manage the internal operations and security of our site in accordance with this privacy statement. We may also use your personal information for analytical and direct marketing purposes, such as:

• Send you periodic email and newsletter messages;
• Confirm, send and track your order, subscription or registration;
• Communicate with you about your order, subscription or registration;
• Answering customer questions;
• To send you surveys and other communications;
• Analyze preferences, trends and statistics;
• To inform you about our new products, services and offers; and
• Providing other information from and about Windgoo.

We will only contact you in ways that are compatible with your communication choices. However, even if you have opted out of receiving marketing communications from us, we may need to contact you to answer questions or concerns specific to the services you have requested.

Other Ways We May Use Your Information. In addition to the specific uses and purposes described above, we may use information that we collect about you or that you provide to us, including personal information:

• To present our Site and its contents to you.
• To provide you with information, products or services that you request from us.
• To enable you to participate in interactive features on our site or to notify you of changes to our site or products or services we offer or provide.
• To provide you with other information from and about Windgoo or any company or organization with which we are affiliated.
• To protect your privacy and to enforce this privacy statement;
• If we believe it is necessary to identify, contact, or take legal action with any person or entity that could cause harm to you, Windgoo or others.
• To fulfill any other purpose for which you provide your information.
• To analyze preferences, trends and statistics.
• To protect our rights and property.
• To comply with any law, regulation, legal process or court order.
• For any other purpose with your permission.

Legal basis for processing. All processing (ie use) of your personal information is based on one of several legal terms. In general these will be:

• Your consent (for example, to place cookies that process personal information, or for marketing from our third-party partners). When we need your consent, we collect it using a form where we inform you so that you can decide whether or not you want to give your consent;
• The performance of our contract with you (for example, to process your payment or shipping information to fulfill your order);
• Compliance with a legal obligation (e.g. where we are required to disclose information to a court or tax authority); and
• Our legitimate interests, provided they do not override your fundamental rights and freedoms (e.g. where we conduct our own direct marketing to existing subscribers, subject to your right to opt-out at any time).
• Periods after which we will delete your personal information: we will only use your personal information for as long as necessary to fulfill each of the purposes set out in this privacy statement, after which we will delete your data, unless we are required to keep the data longer to comply with a legal obligation.

Access your information
We do not share, sell, rent or transfer your personal information other than as described in this privacy statement. Your information will be accessible to Windgoo employees who have been trained to comply with our internal policies for handling personal information and to assist you in exercising your legal rights in relation to your personal information.

Service providers may also have access to your personal information while performing their services. However, we require all service providers to maintain standards of confidentiality that are commercially reasonable to ensure the security of your personal information.

We allow some service providers to help us with behavioral advertising by collecting and analyzing certain information when you visit our sites (e.g. clickstream information, browser type, time and date, topic clicked or scrolled). These service providers typically use a third-party cookie or web beacon to collect this information. You can learn more about opting out of behavioral advertising by visiting http://www.networkadvertising.org/choices or www.aboutads.info/choices/.

Disclosure of Your Information. We will only disclose, sell or share your personal information or other information:

• To service providers. We may disclose, sell or share personal information with one or more service providers with whom we have contracted to provide services to us or to provide the services you have requested from us. We may also disclose personal information to one or more service providers who are interested in providing services or products to you. We have no control over how these service providers use or disclose your personal information.
• To affiliates. We may disclose some or all of your personal information to our parent company, subsidiaries, joint ventures or other Windgoo Group companies under common control with us, in which case this privacy statement will apply to Windgoo to the same extent.
• For our internal analyzes and operations. We may disclose personal information to third-party vendors for our own internal statistical, design, or operational purposes, such as estimating our audience size, measuring aggregate traffic patterns, and understanding demographic trends among our users. The use and disclosure of your personal information by these third parties is limited to the performance of such duties and is subject to confidentiality.
• For legal and other compliance. We may disclose personal information when we believe it is appropriate to: (a) comply with the law, (b) enforce or apply this Privacy Statement or our other policies or agreements, (b) our or our user rights, property, or safety, (c) protect our users from fraudulent, unlawful, or unlawful use of our Site, or (d) if we reasonably believe that an emergency involving imminent death or serious bodily harm to any person requires disclosure of communications or disclosure justifies of records without delay.
• As part of business transfers. We may disclose personal information as part of a merger, acquisition, debt financing, sale of company assets or other business transactions.
• As aggregated information. We may share or sell aggregated, anonymous information to our advertisers, business partners and other third parties that contains or is based on information about you. We take technical and organizational measures to anonymize your information and combine it with the information of other users, so that you cannot be directly identified. This information may be used by those third parties for marketing, promotional or statistical purposes. We do not restrict the use of the Aggregated Information by third parties.

Safety

It is Windgoo's policy to treat your personal information with complete confidentiality. We use commercially appropriate and reasonable precautions, both online and offline, to maintain the security, confidentiality and integrity of the information we collect about you. We maintain physical, electronic, and procedural safeguards to protect your non-public personal information. We update and test our technology to improve the protection of our information about you and to ensure the integrity of that information.

We educate our employees about the importance of customer confidentiality and privacy through standard operating procedures and special training programs. We take appropriate disciplinary action to enforce employee privacy practices.

However, keep in mind that no transmission of data over the Internet is 100% secure. While we take reasonable steps to protect your personal information, we cannot guarantee that unauthorized third parties will not defeat these measures or use non-public personal information for inappropriate purposes. We are not responsible for the circumvention of privacy settings or security measures on the Site or for the actions of third parties. The safety and security of your information also depends on you, and you are responsible for keeping your password confidential. Also remember to log out of your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you share a computer with someone else or use a computer in a public place. All Internet users should be careful about how they interact with and disclose their personal information.

Third Party Sites and Ads
This privacy statement applies only to information collected by Windgoo. We may provide links to third-party sites from our sites as a convenience to our users, but we do not control, and are not responsible for, the privacy and data collection, use, and disclosure practices of third-party sites. When you click on links that take you to external sites, you are subject to their privacy policies and practices and not ours. We encourage you to read and understand the privacy policies of such sites before providing them with information.

Third party advertisers or ad networks may use cookies or other technologies on our Sites for a variety of purposes, including to measure the effectiveness of their advertising and to analyze and personalize advertising or other content delivered to you. We do not control the privacy and data collection, use, and disclosure practices of such third party Sites and the privacy policies of such Sites may differ from the Sites. Therefore, we encourage you to read and understand the privacy policies of such sites before providing them with information.

Our third-party partners currently include (but are not limited to): Google, Instagram, Facebook and YouTube.

Manage your personal information

Unsubscribe from communication. You can change or limit the communications we send you by clicking the "unsubscribe" link at the bottom of any of our emails. You can also contact us directly for free via email at contact@windgoo.co. Be sure to include your full name, email, postal address, and specifically what information you do not wish to receive. If you prefer, you can use one of the following statements in your message to us:

• I prefer not to receive email ads, such as product and service updates, special promotions, or upcoming events.
• I prefer not to receive direct mail advertisements, such as periodical catalogs and mailings about products and services, special promotions or upcoming events.

Your rights. Depending on applicable law, as an EU resident, you may have some or all of the following rights in relation to your personal information:

• To obtain a copy of your personal information along with information about how and on what basis that personal information is processed;
• To correct inaccurate personal information (including the right to have incomplete personal information completed);
• To erase your personal information (in limited circumstances, when it is no longer necessary in relation to the purposes for which it was collected or processed);
• To restrict the processing of your personal information when:
• The accuracy of the personal information is disputed;
• The processing is unlawful, but you object to the erasure of the Personal Data;
• We no longer need the personal information, but it is still required for the establishment, exercise or defense of a legal claim;
• To challenge processing that we have justified on the basis of a legitimate interest (as opposed to your consent, or to perform a contract with you);
• To prevent us from sending you direct marketing;
• To withdraw your consent to our processing of your personal information (where that processing is based on your consent);
• To object to decisions based solely on automated processing or profiling; and
• To obtain or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organization.

In addition, you have the right to lodge a complaint with your local supervisory authority (for example, the Information Commissioner's Office in the United Kingdom).

In connection with these rights, please contact us using the details in the "Contact Us" section below. Please note that we may ask for proof of identity and reserve the right to charge a fee where permitted by law, for example if your request is manifestly unfounded or excessive. We will do our best to respond to your requests within any applicable timeframes of which we will notify you when we acknowledge your request.

Do not follow signals. Currently, Windgoo does not respond to Do Not Track browser settings or signals. In addition, Windgoo may use other technology standard on the Internet to track visitors to Windgoo sites. For information about Do Not Track, visit www.allaboutdnt.org.

Unauthorized use. If you become aware of any unauthorized submission of information to Windgoo, including information about children, please let us know by contacting us using the contact details below so that we can remove it.

International transfers for EU residents. You should be aware that we are a company headquartered in China and that your personal information may be transferred to and stored in China for processing.

With respect to both internal transfers and the use of affiliates, service providers or suppliers, if personal information is transferred outside of the European Economic Area ("EEA"), we will take steps to ensure that the information is given the same level of protection as if it were remained within the UK and EEA, including entering into data transfer agreements, using the standard contractual clauses approved by the European Commission, or relying on certification schemes such as the EU-China Privacy Shield. You may be entitled to details of the mechanisms by which your data is transferred outside the EEA. Contact us if you want to know more.

requirements
Terms and Conditions. The EU Terms of Purchase, Terms of Use and Warranty of this site and the Windgoo services apply to all matters not set forth in this privacy statement.

Changes to this privacy statement. We may make changes to this notice from time to time to ensure its accuracy. If we make changes, the revised notice will be posted online and will include the date of the latest version. Please check back regularly, especially before providing us with any personal information, to determine the current scope of the notice.

Contact details
If you have any further questions about our collection and use of your personal information, or if you would like to exercise any of your rights in relation to your personal information, or if you have any questions about this privacy statement, please contact us at:

Windgoo Inc

Email: contact@windgoo.co