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See.Sense Fleet Tracker Project Privacy Policy and Terms for Cycling UK

See.Sense contact details  

Name: See.Sense (Limeforge Ltd) 

Address: Sketrick House, 16 Jubilee Road, Newtownards, BT23 4YH 

Phone Number: 02891 078353 

E-mail: datacontroller@seesense.cc

 

CYCLING UK Contact Details 

Name: CYCLING UK (Cyclists Touring Club)

Address: Parklands, Railton Road, Guildford, Surrey GU2 9JX

Phone Number:  01483-238300

E-mail: dpo@cyclinguk.org

 

The type of personal information we collect and how we receive it. 

When you use a bicycle equipped with a See.Sense Fleet Tracking unit, we will collect telemetry information which includes the GPS position and time. This allows us to understand journey details including duration, speed, braking, swerving, bicycle characteristics and road surface data.  

See.Sense do not receive personal information about the rider of the bike, and are therefore unable to identify a specific person from the GPS records. Because GPS records attach to an individual bike this is still considered personal information as it can be assumed it relates to a single person (even though See.Sense do not know who that person is). 

 

See.Sense will share the following information with Cycling UK, DfT and appointed evaluators Steer Group and the University of Leeds: 

  • Number of trips taken 
  • Trip mileage traveled
  • Active minutes
  • Average speed 
  • CO2 savings compared to motorised vehicle journeys 
  • Aggregated analysis of all journey and sensor data

See.Sense do not share with Cycling UK, DfT and appointed evaluators Steer Group & University of Leeds 

  • Individual journey GPS details (eg: Bike ID #2 traveled from A to B) 

     

    Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information is your consent. You are able to remove your consent at any time. You can do this by contacting Cycling UK Data protection Officer at dpo@cyclinguk.org, who will arrange with See.Sense for the removal of your personal data.

     

    How See.Sense store your personal information  

    Your information is securely stored in data centres in Ireland and accessed securely from the UK.  

    We keep point level GPS data for 5 years. We will then dispose of your information by aggregating it with other data such that individual points are no longer distinguishable. 

     

    Your data protection rights 

    Under data protection law, you have rights including: 

    • Your right of access - You have the right to ask us for copies of your personal information.  
    • Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.  
    • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.  
    • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.  
    • Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances. 
    • Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. 

    You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at datacontroller@seesense.cc if you wish to make a request. 

     

    Children under 16 

    See.Sense do not knowingly collect Personal Data online from children under 16. If you become aware that a child has provided See.Sense with Personal Data (by using a bicycle equipped with a GPS unit) without parental consent, please contact See.Sense or Cycling UK. If we become aware that a child under 16 has provided us with Personal Data without parental consent, we will take steps to remove the data. 

     

    Governing Law 

    See.Sense are a Northern Ireland based company. These terms and conditions are governed by and shall be construed in accordance with the laws of Northern Ireland. The parties to these terms submit to the exclusive jurisdiction of the courts of Northern Ireland. Furthermore, any action to enforce these terms and conditions shall be brought in the Courts of Northern Ireland. You hereby agree to personal jurisdiction by such courts, and waive any jurisdictional, venue, or inconvenient forum objections to such courts. 

    The Cyclists Touring Club (trading as Cycling UK) with company number 25185 and registered as a charity in England and Wales with charity number 1147607 and in Scotland with charity number SC042541.

    Indemnification 

    You agree to indemnify See.Sense, its contractors, licensors, partners, clients and supporters and their respective directors, officers, employees and agents from and against any and all claims and expenses, including attorneys fees, arising out of your use of any See.Sense services and your use of a bicycle or any experience or incident you have with a bicycle or a cyclist. You cycle at your own risk and you are responsible for ensuring that the bicycles you ride are in a roadworthy condition. You are responsible for observing the rules of the road and cycling in a safe and careful manner. 

     

    How to complain 

    If you have any concerns about our use of your personal information, you can make a complaint to See.Sense at datacontroller@seesense.cc or to Cycling UK dpo@cyclinguk.org.

    You can also complain to the ICO if you are unhappy with how we have used your data. 

     

    The ICO’s address:             

    Information Commissioner’s Office 

    Wycliffe House 

    Water Lane 

    Wilmslow 

    Cheshire 

    SK9 5AF 

     

    Helpline number: 0303 123 1113 

    ICO website: https://www.ico.org.uk

       

    Changes to this Policy and Terms. 

    We reserve the right to change the Privacy Policy and Terms without notice. You acknowledge and agree that it is your responsibility to review the Privacy Policy and Terms periodically to familiarise yourself with any modifications. Your continued use of the Services after such modifications will constitute acknowledgement and agreement of the modified Privacy Policy and Terms. 

    The latest version is always available at www.seesense.cc/page/ppcyclinguk

    Cycling UK making cycling e-asier privacy notice is available: https://www.cyclinguk.org/article/making-cycling-e-asier-privacy-notice

    This policy was last updated 6th December 2022.