RIDE THE WORLD
PRIVACY POLICY
INTRODUCTION
This privacy policy applies between you, the visitor to this website or user of any of our applications and us, the owner and provider of this website and the RTW App. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website and the provision of our services to you.
We take our privacy obligations seriously and we’ve created this privacy policy to explain how we collect and treat your personal information. Personal information is that information which is identifiable as being about you.
LAWS AND STANDARDS WE COMPLY WITH
We comply with
the Australian Privacy Principles established by the Privacy Act 1988 (Cth).
Where you access or use the RTW App or our website from outside Australia, other data protection laws may also apply to how we handle your personal information. In particular, where you are located in the European Economic Area (EEA) or the United Kingdom (UK), we also comply with the General Data Protection Regulation (EU) 2016/679 (GDPR) and, in the UK, the UK GDPR and the Data Protection Act 2018 (UK), in each case to the extent they apply to our processing of your personal information.
In this privacy policy, a reference to personal information includes personal data as that term is defined in the GDPR and the UK GDPR.
DATA CONTROLLER AND EU AND UK REPRESENTATIVE
For the purposes of the GDPR and the UK GDPR, the data controller responsible for your personal information is RTW APP PTY LTD (ABN 67 693 589 847), the owner and provider of the RTW App. This means we decide how and why your personal information is collected and used.
We have appointed representatives in the EEA and the UK under Article 27. Our EU representative under Article 27 GDPR is Europe Services, SE, Na Cecelicce 425/4, Smichov, 150 00 Praha 5, Czech Republic. Data subjects may contact the EU representative at info@gdprrepresentative.com regarding the processing of their personal data. Our UK representative under Article 27 of the UK GDPR is REP27 LTD (company number 17385889), Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom. Data subjects in the United Kingdom may contact the UK representative at info@gdprrepresentative.com.
TYPES OF PERSONAL INFORMATION WE COLLECT
The personal information we collect may include the following:
name;
mailing or street address;
email address;
social media information;
telephone number and other contact details;
age;
date of birth;
credit card information;
information about your business or personal circumstances;
motorcycle riding experience and preferences;
make and model of motorcycles owned or used by you;
information in connection with client surveys, questionnaires and promotions;
your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
information about third parties; and
any other information provided by you to us via this website or our online presence, or otherwise required by us or provided by you.
HOW WE COLLECT PERSONAL INFORMATION
We endeavour to ensure that information we collect is complete, accurate, accessible and not subject to unauthorised access.
We may collect personal information either directly from you, or from third parties, including where you:
contact us through our website or applications;
receive goods or services from us;
communicate with us via email, telephone, SMS, social media applications (such as LinkedIn or Facebook) or otherwise;
interact with our website, social applications, services, content and advertising; and
We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. Cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.
If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.
Where you access the RTW App or our website from the EEA or the UK, we will only place non-essential cookies and similar tracking technologies on your device, including those used for advertising, where you have given your consent. You can withdraw your consent at any time by adjusting your browser settings or any cookie controls we make available.
USE OF YOUR PERSONAL INFORMATION
We collect and use personal information for the following purposes:
to provide services or information to you;
for record keeping and administrative purposes;
to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing services to you;
to improve and optimise our service offering and customer experience;
to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth)). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
to consider an application of employment from you.
We may disclose your personal information to cloud-providers, contractors and other third parties located inside or outside of Australia. If we do so, we will take reasonable steps to ensure that any overseas recipient deals with such personal information in a manner consistent with how we deal with it.
We’ve endeavoured to ensure that our use and collection of your data is clear and as transparent as possible, but in the interests of keeping this policy concise it’s not possible to list every circumstance in which we will use your data.
We may use third party service providers for disaster recovery services. To the extent necessary to receive those disaster recovery services, we will provide your data to that third party service provider.
We may also use third party service providers to audit the infrastructure and applications we use to store your data. To the extent necessary to receive those audit services, we will provide your data to that third party service provider.
OUR LAWFUL BASES FOR PROCESSING PERSONAL INFORMATION
Where the GDPR or the UK GDPR applies to our processing, we must have a lawful basis for collecting and using your personal information. Depending on the purpose, we rely on the following lawful bases:
performance of a contract, where we process your personal information to provide the RTW App and our services to you and to manage your account and any subscription;
our legitimate interests, where we process your personal information to operate, improve, secure and promote the RTW App, to understand how it is used, and to protect our users and our business, provided those interests are not overridden by your interests or rights;
your consent, where we rely on your consent to send you direct marketing, to place non-essential cookies, or to make your approximate location visible to other users through the heat map feature, which you can withdraw at any time;
compliance with a legal obligation, where we process your personal information to meet our legal and regulatory obligations; and
protection of vital interests, where processing is necessary to protect someone’s life.
Where we rely on your consent, you can withdraw it at any time by contacting us or using the controls in the RTW App. Withdrawing your consent does not affect the lawfulness of any processing we carried out before you withdrew it.
We do not seek to collect special categories of personal data, such as information about your health, racial or ethnic origin, or political opinions, through the RTW App. Please do not share this kind of information with us or with other users through the RTW App.
INTERNATIONAL DATA TRANSFERS
We are based in Australia and use service providers located in Australia and overseas. This means your personal information may be transferred to, and stored in, countries other than the one in which you are located.
Where we transfer personal information about individuals in the EEA or the UK to a country that has not been recognised by the European Commission or the UK as providing an adequate level of protection, we put appropriate safeguards in place. These safeguards include the European Commission’s Standard Contractual Clauses, the UK’s International Data Transfer Agreement or Addendum, or another lawful transfer mechanism. You can ask us for a copy of the safeguards we use by contacting us using the details in the ‘Contact Us’ section below.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We keep your personal information only for as long as we need it for the purposes set out in this privacy policy, including to provide the RTW App to you, to comply with our legal, accounting and reporting obligations, and to resolve disputes or enforce our agreements.
The period for which we keep your personal information depends on the type of information and the reason we hold it. Your data is deleted as soon as you close your account with us. When we no longer need your personal information, we take reasonable steps to delete it or to de-identify it.
SECURITY
We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information.
If a data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay, and where feasible within 72 hours of becoming aware of it, and we will notify affected individuals where we are required to do so. We will act in accordance with our obligations under applicable data protection laws, including the GDPR, the UK GDPR and the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).
LINKS
Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites, and we suggest you review the privacy policies of those websites before using them.
REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION
If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.
Where you are a resident of the European Union and the GDPR applies to your personal information, you have the right to ask for ‘subject access request’ or ‘SAR’ being a copy of your personal data held by us. Where we do hold such data about you we will provide you with a copy of the data we hold about you. This will be in a commonly used machine-readable file where you request us to e-mail the information to you. We will also give you a description of the data, tell you why we are holding it and tell you who we could have disclosed it to.
If you think that any personal information, we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected. We will also stop processing data on your request, and you may also request that we delete the data held about you.
If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us using the contact details set out in the ‘Contact Us section below.
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act 1988 (Cth).
YOUR RIGHTS UNDER THE GDPR AND UK GDPR
If you are located in the EEA or the UK, you have the following rights in relation to your personal information:
the right to be informed about how we collect and use your personal information, which this privacy policy is designed to provide;
the right to access the personal information we hold about you and to receive a copy of it;
the right to have inaccurate or incomplete personal information corrected;
the right to have your personal information erased in certain circumstances, sometimes called the right to be forgotten;
the right to restrict our processing of your personal information in certain circumstances;
the right to data portability, meaning the right to receive certain personal information in a structured, commonly used and machine-readable format and to have it transferred to another controller where this is technically feasible;
the right to object to our processing of your personal information where we rely on our legitimate interests, and to object at any time to processing for direct marketing;
the right to withdraw your consent at any time where we rely on your consent to process your personal information; and
the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects for you or similarly significantly affects you.
We do not make decisions that produce legal effects for you, or similarly significantly affect you, based solely on automated processing.
To exercise any of these rights, please contact us using the details in the ‘Contact Us’ section below. We may need to verify your identity before we act on your request. We will respond within one month, although we may extend this period for complex or numerous requests and will let you know if we do.
You will not usually have to pay a fee to exercise your rights. We may charge a reasonable fee, or decline to act, if your request is clearly unfounded, repetitive or excessive, and we will explain our reasons if we do.
CHANGE OF CONTROL
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
COMPLAINTS
If you wish to complain about how we handle your personal information or held by us, please contact us using the details set out below including your name and contact details. We will investigate your complaint promptly and respond to you within a reasonable time.
If you are located in the EEA or the UK and you are not satisfied with how we have handled your personal information or your complaint, you also have the right to lodge a complaint with your local data protection supervisory authority. In the UK, this is the Information Commissioner’s Office. A list of the supervisory authorities across the EEA is available from the European Data Protection Board.
Our UK representative under Article 27 of the UK GDPR: REP27 LTD (company number 17385889, rep27.com), Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom. Data subjects in the United Kingdom may contact the representative at info@gdprrepresentative.com. Appointment verifiable at: https://gdprrepresentative.com/verify.php?code=UK27-CAB8-AD1B
Contact Us
For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
Email: support@rtwapp.com
By providing personal information to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy.
We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.
