1. Purposes for which we process your data
We will process your personal data set out in Annex 1 below for the following purposes:
- to manage our sales processes (e.g., invoicing);
- to manage our distributor relations, including human relations and communications, the analysis of distributors’ business needs;
- to manage on-site visits;
- to analyze and forecast distributors and end-customers demand;
- to provide an infrastructure for delivery and to efficiently deliver our products to our end customers;
- to discover new distributors;
- to provide you with information regarding our products, services and events; and
- to conduct surveys.
We collect your personal data either from you directly, in the course of our business process or through our employees, who are in contact with you or manage your on-site visit. We may also collect some of your personal data in the course of the communication or business relationship with you.
Where we ask you to provide us with your data, this provision of personal data is voluntary. However, if you do not provide your personal data different business processes might be delayed or even impossible or you will not be able to attend our events.
2. Legal basis of the processing
We process your personal data on the basis of our prevailing legitimate interest according to Article 6(1)(f) General Data Protection Regulation (“GDPR”) to achieve the purposes set out in point 1 above; or to comply with our legal obligation (Article 6(1)(c) GDPR).
As far as you are one of our distributors, we may also process your personal data on the basis of the necessity for the performance of the agreement we have concluded with you or to take steps at your request prior to entering into such an agreement (Article 6(1)(b) GDPR).
If and to the extent that we ask you in a separate process to provide your consent, we will process your personal data on the basis of this consent (Article 6(1)(a) GDPR).
3. Transfer of your personal data
We will transfer your personal data to the following recipients:
- IT service providers that we use;
- legal representatives;
- banks for management of payment transactions;
- auditors for the performance of audits;
- courts;
- competent administrative authorities, especially fiscal authorities;
- collection agencies for debt collection;
- external financer, e.g., leasing or factoring companies, cessionaries etc., as far as the delivery or service is financed in such manner;
- contract partners or business partners who are or should be participating in the performance of the delivery or service;
- insurances in the context of the conclusion of an insurance contract concerning the delivery/service or occurrence of the insured event; and
- our partner firms as far as this is necessary to provide our services.
Some of the recipients referred to above are located in or process personal data outside of your country. The level of data protection in another country may not be equivalent to that in your country. However, we only transfer your personal data to countries where the EU Commission has decided that they have an adequate level of data protection or we take measures to ensure that all recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC). Such agreements are accessible upon request from GDPR@StriderBikes.com.
4. Retention periods
We will retain your personal data for as long as we are in a business relationship with you and thereafter as long as there are statutory retention obligations or potential legal claims, where personal data is needed to raise the claim, are not yet time-barred.
5. Your rights in connection with your personal data
Under applicable law, you have, among others, the rights (under the conditions set out in applicable law): (i) to check whether and what kind of personal data we hold about you and to request copies of such data, (ii) to request correction, supplementation or deletion of your personal data that is inaccurate or processed in non-compliance with applicable requirements, and (iii) to request us to restrict the processing of your personal data, (iv) in certain circumstances, to object for legitimate reasons to the processing of your personal data or to revoke consent previously granted for the processing where such revocation does not affect the lawfulness of the processing until the revocation, (v) to request data portability, (vi) to know the identities of third parties to which your personal data are transferred, and (vii) to lodge a complaint with the competent authority.
6. Our contact details
Please address your requests or questions concerning the processing of your personal data to:
Strider Sports International, Inc.
2221 N. Plaza Dr.
Rapid City, South Dakota 57702
USA
Email: GDPR@StriderBikes.com
Last updated on December 11, 2020.
Annex 1
Personal data of distributors:
- serial number
- name
- salutation/sex
- address
- telephone and fax number and other information necessary for addressing through modern communication techniques (e.g., email)
- year of birth
- date of birth
- company register data
- creditworthiness data
- blocking indicator (contact ban, invoice block, delivery block, posting lock, payment stop)
- category of distributor (including regional allocation)
- identification number for official statistics such as VAT-number or Intrastat identification number
- allocation to a certain purchasing association, group of companies
- language of correspondence, other agreements or keys for data delivery
- object of delivery or service
- bonus or commission data etc.
- contact person at the distributor handling the processing of delivery or service
- terms of delivery or service (including data about place of delivery or service, packaging etc.)
- data about customs clearance (country of origin, customs tariff number) and export control
- data on insurance of delivery or service and related financing
- tax liability and tax calculation data
- conditions of financing and payment
- bank detail
- credit card number and credit card company
- credit management data (credit limit, bill of exchange limit)
- payment data or service performance data of data subject
- data on payment reminders or lawsuits
- bank account or payment documents data
- expenses and earnings concerning the service
- special G/L transactions (specific valuation allowance, notes receivable, down payment, bank guarantee)
- any other data you have provided to us (e.g. via web forms)
Personal data of employees at one of our distributors:
- serial number
- name
- salutation/sex
- related distributor
- additional data for addressing at distributor
- language of correspondence, other agreements or keys of data exchange
- functions of the data subject at the service recipient or service provider
- scope of power of representation
- business cases handled by the contact person
