Privacy Policy

1. Introduction

1. We are committed to safeguarding the privacy of the people (“you”) using the Trimm products, applications, services and/or visiting websites under trimm.bike developed and provided by Trimm LLC, originally Ratio LLC in Korea (“Trimm”, “we”, “us” and “our”).
2. This policy applies where we are acting as a data controller with respect to the personal data of the Users; in other words, where we determine the purposes and means of the processing of that personal data.
3. We may use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of trimm.bike, we will ask you to consent to our use of cookies when you first visit our website.

2. Credit

1. This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

1. In this Section 3 we have set out:
   1. the general categories of personal data that we may process;
   2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
   3. the purposes for which we may process personal data; and
   4. the legal bases of the processing.
2. We may process data about your use of our website and services
   (“usage data”). The usage data may include your IP address,
   geographical location, browser type and version, operating system,
   referral source, length of visit, page views and website
   navigation paths, as well as information about the timing,
   frequency and pattern of your service use. The source of the usage
   data is our analytics tracking system. This usage data may be
   processed for the purposes of analysing the use of the website and
   services. The legal basis for this processing is our legitimate
   interests, namely monitoring and improving our website and
   services.
3. We may process your account data (“account data”). The account
   data may include your name, email address and/or the account
   identifiers of the portal sites, such as Google and Facebook. You
   are the source of the account data. The account data may be
   processed to authenticate and manage your account and data. The
   legal basis for this processing is our legitimate interests,
   namely he proper administration of our Services.
4. We may process your personal information included in your
   personal profile in our server (“profile data”). The profile data
   may include your name, height, weight, gender and date of birth. The
   profile data may be processed to restore your back-up into a new
   environment. The legal basis for this processing is our legitimate
   interests, namely the proper administration of our website and
   business.
5. We may process your personal data that are provided in the
   course of the use of our services (“service data”). The service
   data may include your geographic location traces, exercise
   statistics such as speed, distance, altitude, calories, power,
   heart rates and cadences during the active use of the
   Services. It may also include your route plans. You are the
   source of the service data. The service data may be processed to
   be shown in multiple platforms, to maintain the back-ups and to
   restore the data onto your new application platform. We use
   de-identified service data to enhance the map and routing
   service. The legal basis for this processing is consent.
6. We may process information that you post for publication on our
   website or through our services (“publication data”). The
   publication data may be processed for the purposes of enabling
   such publication and administering our website and services. The
   legal basis for this processing is our legitimate interests,
   namely the proper administration of our website and business.
7. We may process information contained in any enquiry you submit
   to us regarding goods and/or services (“enquiry data”). The
   enquiry data may be processed for the purposes of offering,
   marketing and selling relevant goods and/or services to you. The
   legal basis for this processing is consent.
8. We may process [information relating to our customer
   relationships, including customer contact information] (“customer
   relationship data”). The customer relationship data may include
   your name, your contact details, and information contained in
   communications between us and you. You are the source of the
   customer relationship data. The customer relationship data may be
   processed for the purposes of managing our relationships with
   customers, communicating with customers, keeping records of those
   communications and promoting our products and services to
   customers. The legal basis for this processing is our legitimate
   interests, namely the proper management of our customer
   relationships.
9. We may process information relating to transactions, including
   purchases of goods and services, that you enter into with us
   and/or through our website (“transaction data”). The transaction
   data may include your contact details, your card details and the
   transaction details. The transaction data may be processed for the
   purpose of supplying the purchased goods and services and keeping
   proper records of those transactions. The legal basis for this
   processing is the performance of a contract between you and us
   and/or taking steps, at your request, to enter into such a
   contract and our legitimate interests, namely the proper
   administration of our website and business.
10. We may process information that you provide to us for the purpose
    of subscribing to our email notifications and/or newsletters
    (“notification data”). The notification data may be processed for
    the purposes of sending you the relevant notifications and/or
    newsletters. The legal basis for this processing is the performance
    of a contract between you and us and/or taking steps, at your
    request, to enter into such a contract.
11. We may process information contained in or relating to any
    communication that you send to us (“correspondence data”). The
    correspondence data may include the communication content and
    metadata associated with the communication. Our website will
    generate the metadata associated with communications made using
    the website contact forms. The correspondence data may be
    processed for the purposes of communicating with you and
    record-keeping. The legal basis for this processing is our
    legitimate interests, namely the proper administration of our
    website and business and communications with users.
12. We may process any of your personal data identified in this
    policy where necessary for the establishment, exercise or defence
    of legal claims, whether in court proceedings or in an
    administrative or out-of-court procedure. The legal basis for this
    processing is our legitimate interests, namely the protection and
    assertion of our legal rights, your legal rights and the legal
    rights of others.
13. We may process any of your personal data identified in this
    policy where necessary for the purposes of obtaining or
    maintaining insurance coverage, managing risks, or obtaining
    professional advice. The legal basis for this processing is our
    legitimate interests, namely the proper protection of our business
    against risks.
14. In addition to the specific purposes for which we may process
    your personal data set out in this Section 3, we may also process
    any of your personal data where such processing is necessary for
    compliance with a legal obligation to which we are subject, or in
    order to protect your vital interests or the vital interests of
    another natural person.
15. Please do not supply any other person’s personal data to us,
    unless we prompt you to do so.

4. Providing your personal data to others

1. We may disclose your personal data to our insurers and/or
   professional advisers insofar as reasonably necessary for the
   purposes of obtaining or maintaining insurance coverage, managing
   risks, obtaining professional advice, or the establishment, exercise
   or defence of legal claims, whether in court proceedings or in an
   administrative or out-of-court procedure.
2. Financial transactions relating to the may be handled by our
   payment services providers, such as Apple Inc. We will share
   transaction data with our payment services providers only to the
   extent necessary for the purposes of processing your payments,
   refunding such payments and dealing with complaints and queries
   relating to such payments and refunds. You can find information
   about the payment services providers’ privacy policies and practices
   at their websites.
3. We may disclose your enquiry data to one or more of those selected
   third party suppliers of goods and services identified on our
   website for the purpose of enabling them to contact you so that they
   can offer, market and sell to you relevant goods and/or
   services. Each such third party will act as a data controller in
   relation to the enquiry data that we supply to it; and upon
   contacting you, each such third party will supply to you a copy of
   its own privacy policy, which will govern that third party’s use of
   your personal data.
4. In addition to the specific disclosures of personal data set out
   in this Section 4, we may disclose your personal data where such
   disclosure is necessary for compliance with a legal obligation to
   which we are subject, or in order to protect your vital interests
   or the vital interests of another natural person. We may also
   disclose your personal data where such disclosure is necessary for
   the establishment, exercise or defence of legal claims, whether in
   court proceedings or in an administrative or out-of-court
   procedure.
5. Your personal data is hosted by Google Firebase, which is comply
   with EU-US Privacy Shield framework. Its data processing and
   security terms related to the framework is shown at
   https://firebase.google.com/terms/data-processing-terms.
6. You acknowledge that personal data that you submit for publication
   through our website or services may be available, via the internet,
   around the world. We cannot prevent the use (or misuse) of such
   personal data by others.

5. Retaining and deleting personal data

1. This Section 5 sets out our data retention policies and
   procedure, which are designed to help ensure that we comply with
   our legal obligations in relation to the retention and deletion of
   personal data.
2. Personal data that we process for any purpose or purposes shall
   not be kept for longer than is necessary for that purpose or those
   purposes.
3. We will retain your personal data as follows:
   1. Your usage data will be retained up to one year.
   2. Your account, profile and service data can be retained until
      you request to erase your account or the data. The erasure can
      take up to 30 days.
   3. Your enquiry and notification data will be retained until
      you request to unsubscribe. The erasure can take up to 30
      days.
   4. Notwithstanding the other provisions of this Section 6, we
      may retain your personal data where such retention is
      necessary for compliance with a legal obligation to which we
      are subject, or in order to protect your vital interests or
      the vital interests of another natural person.

6. Amendments

1. We may update this policy from time to time by publishing a new
   version on our website.
2. You should check this page occasionally to ensure you are happy
   with any changes to this policy.
3. We may notify you of significant changes to this policy by
   e-mail.

7. Your rights

1. You have the right to confirmation as to whether or not we
   process your personal data and, where we do, access to the
   personal data, together with certain additional information. That
   additional information includes details of the purposes of the
   processing, the categories of personal data concerned and the
   recipients of the personal data. Providing the rights and freedoms
   of others are not affected, we will supply to you a copy of your
   personal data. The first copy will be provided free of charge, but
   additional copies may be subject to a reasonable fee. You can
   access your personal data by visiting https://trimm.bike when
   logged into our website or by using our Trimm applications.
2. You have the right to have any inaccurate personal data about
   you rectified and, taking into account the purposes of the
   processing, to have any incomplete personal data about you
   completed.
3. In some circumstances you have the right to the erasure of your
   personal data without undue delay. Those circumstances include:
   the personal data are no longer necessary in relation to the
   purposes for which they were collected or otherwise processed; you
   withdraw consent to consent-based processing; you object to the
   processing under certain rules of applicable data protection law;
   the processing is for direct marketing purposes; and the personal
   data have been unlawfully processed. However, there are exclusions
   of the right to erasure. The general exclusions include where
   processing is necessary: for exercising the right of freedom of
   expression and information; for compliance with a legal
   obligation; or for the establishment, exercise or defense of legal
   claims.
4. In some circumstances you have the right to restrict the
   processing of your personal data. Those circumstances are: you
   contest the accuracy of the personal data; processing is unlawful
   but you oppose erasure; we no longer need the personal data for
   the purposes of our processing, but you require personal data for
   the establishment, exercise or defence of legal claims; and you
   have objected to processing, pending the verification of that
   objection. Where processing has been restricted on this basis, we
   may continue to store your personal data. However, we will only
   otherwise process it: with your consent; for the establishment,
   exercise or defence of legal claims; for the protection of the
   rights of another natural or legal person; or for reasons of
   important public interest.
5. You have the right to object to our processing of your personal
   data on grounds relating to your particular situation, but only to
   the extent that the legal basis for the processing is that the
   processing is necessary for: the performance of a task carried out
   in the public interest or in the exercise of any official
   authority vested in us; or the purposes of the legitimate
   interests pursued by us or by a third party. If you make such an
   objection, we will cease to process the personal information
   unless we can demonstrate compelling legitimate grounds for the
   processing which override your interests, rights and freedoms, or
   the processing is for the establishment, exercise or defence of
   legal claims.
6. You have the right to object to our processing of your personal
   data for direct marketing purposes (including profiling for direct
   marketing purposes). If you make such an objection, we will cease
   to process your personal data for this purpose. The benefits given
   for the processing will be cancelled if there exist.
7. You have the right to object to our processing of your personal
   data for scientific or historical research purposes or statistical
   purposes on grounds relating to your particular situation, unless
   the processing is necessary for the performance of a task carried
   out for reasons of public interest.
8. To the extent that the legal basis for our processing of your
   personal data is:
   1. consent; or
   2. that the processing is necessary for the performance of a
      contract to which you are party or in order to take steps at your
      request prior to entering into a contract,
   and such processing is carried out by automated means, you have the
   right to receive your personal data from us in a structured,
   commonly used and machine-readable format. However, this right does
   not apply where it would adversely affect the rights and freedoms of
   others.
9. If you consider that our processing of your personal information
   infringes data protection laws, you have a legal right to lodge a
   complaint with a supervisory authority responsible for data
   protection.
10. To the extent that the legal basis for our processing of your
    personal information is consent, you have the right to withdraw
    that consent at any time. Withdrawal will not affect the
    lawfulness of processing before the withdrawal.
11. You may exercise any of your rights in relation to your personal
    data by written notice to us OR by e-mail to
    privacy@trimm.bike.

8. About cookies

1. A cookie is a file containing an identifier (a string of letters
   and numbers) that is sent by a web server to a web browser and is
   stored by the browser. The identifier is then sent back to the
   server each time the browser requests a page from the server.
2. Cookies may be either “persistent” cookies or “session” cookies:
   a persistent cookie will be stored by a web browser and will
   remain valid until its set expiry date, unless deleted by the user
   before the expiry date; a session cookie, on the other hand, will
   expire at the end of the user session, when the web browser is
   closed.
3. Cookies do not typically contain any information that personally
   identifies a user, but personal information that we store about
   you may be linked to the information stored in and obtained from
   cookies.

9. Cookies that we use

1. We use cookies for the following purposes:
   1. authentication – we use cookies to identify you when you
      visit our website and as you navigate our website;
   2. status – we use cookies to help us to determine if you are
      logged into our website;
   3. personalisation – we use cookies to store information about
      your preferences and to personalise the website for you;
   4. security – we use cookies as an element of the security
      measures used to protect user accounts, including preventing
      fraudulent use of login credentials, and to protect our
      website and services generally;
   5. advertising – we use cookies to help us to display
      advertisements that will be relevant to you;
   6. analysis – we use cookies to help us to analyse the use and
      performance of our website and services; and
   7. cookie consent – we use cookies to store your preferences in
      relation to the use of cookies more generally.

10. Cookies used by our service providers

1. Our service providers use cookies and those cookies may be
   stored on your computer when you visit our website.
2. We use Google Analytics to analyse the use of our
   Services. Google Analytics gathers information about the Services
   use by means of cookies. The information gathered relating to our
   Services is used to create reports about the use of our
   Services. Google’s privacy policy is available at:
   https://www.google.com/policies/privacy/.
3. We may publish Google AdSense interest-based advertisements on
   the Services. These are tailored by Google to reflect your
   interests. To determine your interests, Google will track your
   behaviour on our website and on other websites across the web
   using cookies You can view, delete or add interest categories
   associated with your browser by visiting:
   https://adssettings.google.com. You can also opt out of the
   AdSense partner network cookie using those settings or using the
   Network Advertising Initiative’s multi-cookie opt-out mechanism
   at: http://optout.networkadvertising.org. However, these opt-out
   mechanisms themselves use cookies, and if you clear the cookies
   from your browser your opt-out will not be maintained. To ensure
   that an opt-out is maintained in respect of a particular browser,
   you may wish to consider using the Google browser plug-ins
   available at: https://support.google.com/ads/answer/7395996

11. Managing cookies

1. Most browsers allow you to refuse to accept cookies and to
   delete cookies. The methods for doing so vary from browser to
   browser, and from version to version. You can however obtain
   up-to-date information about blocking and deleting cookies via
   these links: 
   1. https://support.google.com/chrome/answer/95647?hl=en
      (Chrome);
   2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
      (Firefox);
   3. http://www.opera.com/help/tutorials/security/cookies/
      (Opera);
   4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
      (Internet Explorer);
   5. https://support.apple.com/kb/PH21411 (Safari); and
   6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
      (Edge).
2. Blocking all cookies will have a negative impact upon the
   usability of many websites.
3. If you block cookies, you will not be able to use all the
   features on our website.

12. Our details

1. This website is owned and operated by Ratio LLC in South
   Korea
2. We are registered in South Korea, and our registered office is at:
   617-2, 330, Seongam-ro, Mapo-gu, Seoul, Republic of Korea