SCOPE
This data protection policy statement of Kalkhoff, FOCUS and Urban Arrow (“the aforementioned brands”) governs the collection, use and other forms of processing of personal data by FOCUS & Kalkhoff Holding GmbH, Kalkhoff Werke GmbH, FOCUS Bikes GmbH, Smart Urban Mobility B.V. (“the aforementioned companies”)in connection with our services, brand-name products from the aforementioned companies and their associated brands, and this website
WHO IS RESPONSIBLE FOR THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA?
FOCUS & Kalkhoff Holding GmbH (Europa-Allee 26, 49685 Emstek, Germany), is the legal entity responsible for all collection and processing of your personal data in connection with the brand-name products, services and websites of FOCUS and Kalkhoff.
Focus Bikes GmbH (Europa-Allee 26, 49685 Emstek, Germany), is the legal entity responsible for all collection and processing of your personal data in connection with the brand-name products, services and websites.
Smart Urban Mobility B.V. (Gyroscoopweg 6, 1042 AB Amsterdam), is the legal entity responsible for all collection and processing of your personal data in connection with the brand-name products, services and websites of Urban Arrow.
The aforementioned companies are part of Pon Holdings B.V. and its affiliates and subsidiaries (“Pon”). The aforementioned companiesand Pon are committed to respecting and safeguarding your privacy and the security of the personal data you share with us.
WHY DO WE COLLECT YOUR PERSONAL DATA?
Personal data are any information that identifies you as an individual or relates to an identifiable individual. If you choose to register your personal data, contact us, or visit our websites, we will process some personal data concerning you. We process these personal data for the following purposes:
To communicate with you in a personal way or to inform you about products or services from the aforementioned brands based on the options you input;
To provide services for customers, including services relating to the purchase of services and products, to fulfil warranty obligations and product recalls for our own services and those of related companies, and to deal with enquiries and complaints;
To manage and fulfil your purchases of products provided by the aforementioned brands including financial and logistical processing;
To manage your account with the aforementioned brands;
To manage your participation in any contests, promotions, surveys or website features;
To perform market research and improve our business processes, services and products from the aforementioned brands or to develop new business fields, products and services;
To perform statistical analyses and create reports;
To provide services on the internet;
To communicate with participants and offer a loyalty program;
To provide app functionality, including important promotional messages;
To communicate future promotional and marketing information including for direct marketing purposes and retargeting;
To aggregate and/or anonymize personal data in order to generate other data for our own use;
To comply with our legal obligations, resolve disputes, or enforce our contracts;
As otherwise stated at the time the data are collected or elsewhere during the collection of information.
What personal data we exactly collect depends on which websites, products or services you use and how you use them. We process the following personal data.
These is the personal data that you yourself input when you use our websites, products or services. These data include e.g. your name, address, gender, email address, phone number, age, date of birth, products you buy from the aforementioned brands, your account name and passwords, bank details for paying for products from the aforementioned brands and their associated brands, etc.
Many products are equipped with one or more sensors, or use the sensors of the devices on which the products are provided. Examples of sensors include GPS receivers, Wi-Fi or Bluetooth receivers, cameras and touchscreens.
In accordance with the purposes of processing personal data, the data collected via the sensors and the devices used will be sent to the aforementioned brands and other third parties that need the data in order to provide the agreed services to the aforementioned companies.
These data are automatically collected or generated when you use the website, products or services of the aforementioned companies. Metadata are often collected or generated when you use a computer or device and send data via a computer network, such as the Internet. These metadata include data used by the user interface or device activity, as well as IP addresses, unique device identifiers, MAC addresses or Wi-Fi and Bluetooth devices, cookies, and data from actual computer activity. For further details, please refer to the cookie policy for the aforementioned brands.
In the following, we describe the personal data we process for each processing method, the purposes we use them for, and the legal basis for this:
Personal data processed: First name, last name, email address...
Purposes of processing the personal data: The purposes described above: 1, 2, 6, 7, 8, 11, 12, 13 and 14
Legal basis: Consent or legitimate interest
Personal data processed: First name, last name, email address, phone number, customer number...
Purposes of processing the personal data: The purposes described above: 1, 2, 6, 7, 8, 11, 12, 13 and 14
Legal basis: Performance of a contract or legitimate interest
Personal data processed: First name, last name, email address, phone number...
Purposes of processing the personal data: The purposes described above: 1, 2, 6, 7, 8, 11, 12, 13 and 14
Legal basis: Consent, legitimate interest or performance of a contract
Personal data processed: First name, last name, email address, phone number...
Purposes of processing the personal data: The purposes described above: 1, 2, 3, 6, 7, 8, 9, 11, 12, 13 and 14
Legal basis: Performance of a contract or legitimate interest
Personal data processed: First name, last name, email address, phone number...
Purposes of processing the personal data: The purposes described above: 1, 2, 3, 6, 7, 8, 9, 11, 12, 13 and 14
Legal basis: Performance of a contract or legitimate interest
Personal data processed: First name, last name, email address, phone number...
Purposes of processing the personal data: The purposes described above: 1, 5, 6, 7, 8, 11, 12, 13 and 14
Legal basis: Consent or legitimate interest
Personal data processed: Note on metadata Please refer to our Cookie Policy from the aforementioned brands for further details
Purposes of processing the personal data: The purposes described above: 6, 7, 8, 11, 12, 13 and 14
Legal basis: Consent or legitimate interest
Personal data processed: Note: we never gain access to your social media account
Purposes of processing the personal data: The purposes described above: 1, 6, 7, 8, 11, 12, 13 and 14
Legal basis: Consent or legitimate interest
Personal data processed: First name, last name, e-mail address, phone number...
Purposes of processing the personal data: The purposes described above: 1, 2, 6, 7, 8, 10, 11, 12, 13 and 14
Legal basis: Consent or legitimate interest
Personal data processed: First name, last name, email address, phone number, customer number...
Purposes of processing the personal data: The purposes described above: 1, 2, 6, 7, 8, 11, 12, 13 and 14
Legal basis: Performance of a contract or legitimate interest
Our legitimate interest includes the following: marketing, advertising, security, prevention (protection against crime), IT management, investigation and analysis relating to our own products or services, company administration, legal matters, and internal management.
If you have given your consent to the processing of your personal data, you have the right to withdraw this consent at any time you wish. To do so, simply send your request for data retrieval to privacy@pon.com.
You should be aware that the aforementioned companies are part of a business group within Pon and that certain departments (such as marketing and IT) may be part of worldwide Pon companies. As a result, your personal data may be shared with and/or transferred to other business group companies or other Pon business areas worldwide. A list of the locations of our operations, among other information, can be found here: https://pon.com/en/about-pon/companies/.
The aforementioned companies may also share your personal information with third parties to enable them to perform certain activities on behalf of the aforementioned companies or to enable them to provide services to us. These third parties may include service providers such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure services, customer service, email delivery, verification and other services. The aforementioned companies may also share your personal information with third parties so that they can send you promotional information in accordance with the preferences you have registered. The aforementioned companies require these third parties to process and protect your personal data with due care. The aforementioned companies will not sell your personal data to third parties.
It is possible that the aforementioned companies or Pon may undertake a restructuring or merger, or otherwise sell or dispose of a business (or part of a business) to another entity. If it is an affiliate of the aforementioned brands, such a transfer may include transferring your personal data to the new owner and its advisor.
We will only release your personal data if permitted or required by law, if it is necessary to prevent or combat fraud, to resolve disputes or for any other legitimate needs which, given the circumstances, are more serious than the protection of your privacy, such as protecting the security of our operations and the safety of our staff.
We will store your personal data for as long as is described for the purposes of this data protection policy and as required or permitted by applicable law.
The criteria we use to determine the retention period include the following:
The length of time for which we have an ongoing business relationship with you and provide services to you (for example, the period of time for which you have an account with us or for which you use our services on an ongoing basis).
Whether there is a legal obligation that we are required to comply with (for example, certain laws require us to retain records of our transactions for a certain period of time before we may erase them); or
Whether retention is desirable in view of our legal position (e.g. with regard to limitation periods or in the event of disagreements or investigations by regulatory authorities).
When you use our websites, services, applications and communication services (such as email) and access or use tools, we may use cookies, web beacons and other similar information storage technologies to provide you with a faster and safer browsing experience.
Please refer to the Kalkhoff Cookie Policy for the aforementioned brands, in which we explain how cookies, web beacons and similar technologies work, how we use them and how you can control them.
If you wish to revise, correct, update, limit or erase the personal data concerning you that we process, if you wish to object to the processing of personal data, or if you wish to receive an electronic copy of your personal data that you wish to transfer to another company (where you have this right to data portability under the applicable law), you can contact us at privacy@pon.com. We will respond to your request in accordance with the applicable law.
We ask that you to describe as clearly as possible in your request the personal data to which your request relates. For your own security, we will only process requests for the personal data associated with the email address you use to send your request, and we may also ask you to provide proof of your identity before we comply with your request. We will endeavour to process your request as quickly as reasonably practicable and of course in any case within the time limits required by law.
Please send your questions and comments regarding this privacy policy to: privacy@pon.com
Our data protection officer (DPO) can also be contacted using the above email address. You have the right to submit a complaint to a data protection authority in your country or region, or where an alleged violation of applicable data protection law takes place.
This data protection policy may be amended over time. Amendments to this data protection policy enter into force when we publish the new version of the policy. Where necessary, we will notify you of amendments to our data protection policy. This data protection policy was most recently amended on July 12th, 2023.