PRIVACY POLICY
General
Last Updated: April 16, 2025
This Privacy Policy (this “Policy”) is intended to support your use of the products and services offered by SZ Avinox Innovation Co., Ltd. (“Avinox,” “we,” or “us”, including its affiliated companies). The products and services offered by us include hardware, firmware, software, websites, applications, and services (each, a “Product” or “Service” and, collectively, the “Products and Services”).
Please read carefully before using the Products and Services. By using the Products and Services, you acknowledge acceptance of the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Terms of Use for the Products and Services you use. We reserve the right, at our discretion, to change, modify, add, or remove portions of these terms at any time. It is recommended to regularly review the updates. Your continued use of the Products and Services following the posting of changes to these terms will signify your acceptance of the revised terms.
This Policy outlines:
• The types of information we collected from you
• How We Use Cookies
• How we use and share information
• Your rights and choices regarding this data
• The steps we take to protect this information
• The information gathered by third-party services
• How we transfer your information
• Potential changes to this Policy
• How you may contact us
The types of information we collected from you
We may collect information about you directly from you, from third parties, and automatically through your use of the Products and Services. Some information we collect from you are referred to as “personal information” or “personal data” in this Policy. Personal information or personal data is data that can identify you, or data that we can relate to you, such as your email address.
If you do not provide your information when requested, you may not be able to use the Products and Services if that information is necessary to provide you with basic services or if we are legally required to collect it.
• Account Information. When you create an Avinox account, you may provide us with information that includes your user ID, email address, password or other information for account verification.
• Contact Information. When you voluntarily choose to fill in your contact information such as your name, phone number, email address, and business information on our website for cooperation, feedback, or after-sales support, we will receive the information and contact you.
• Photos and Videos. We do not automatically collect your photo or video without your consent and affirmative actions. You may provide us with your photos, videos or other content when you choose to upload these contents through the Products and Services to request customer service.
• Communications. When you contact us, we may collect information about your communications with us, including the time, topic, and content of your communications.
• Bike Ride Activity and Physical Performance Information. When you affirmatively enable the Ride Data Sync function, your riding history will be synchronized onto the cloud, including riding history, riding path GPS, elevation, riding time, speed and physical performance information, cadence, heart rate, and calorie consumption.
• Technical Information. When you use the Products and Services, you may provide us with technical information about the connected devices and the device running the Products and Services. Such information includes connected devices information such as product model, firmware version, device status, and application version, mobile device information such as operating system specifications, and diagnostic and usage data such as performance statistics, crash data.
How We Use Cookies
We use different types of cookies such as strictly necessary cookies as they are essential for you to use this site, preference cookies or functionality cookies that remembers your choices including language, statistics cookies or performance cookies that collect information about how you use the Service. You can manage your cookie settings at “Cookie Preferences”.
How we use and share information
We use information we collect in a variety of ways in providing the Products and Services and operating our business. The use of information that we collect includes the following:
• To operate and provide features of the Products and Services, to verify and manage Avinox accounts, to provide services and information that you request. We will process your personal data in accordance with this Policy and any of your preferences, which are expressed via the Products and Services. We may use any of the categories of personal information described above for this purpose.
• To understand and analyze the usage trends and preferences, to improve Products and Services, and to develop new products, services, features, and functionality. We may use your Technical Information for this purpose.
• To detect, prevent, and respond to fraud, abuse, security risks, and technical issues that could harm our users, us, or the public. We may use your Account Information, Device-Related Information for this purpose.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent. We may use any of the categories of personal information described above for this purpose.
• We will aggregate personal data we collect, such as the number and frequency of your visits to the Products and Services, to produce metrics and statistical information. We use aggregate data to help us understand how the Products and Services are being used and to improve its usability. We also use it to enhance the quality and availability of products and services we offer. We may use your Technical Information for this purpose.
If you are located in the European Economic Area, we will only use your information when we have a valid legal ground, including when:
• You have consented to the use of your information.
• We need to use your information to enter into or perform a contract with you, for example to provide map services, or provide you with the customer support.
• We need to use your information to comply with a legal obligation, for example to comply with a court order, subpoena, or warrant.
• We or a third party have a legitimate interest in using your information. In particular, we have a legitimate interest in using your information to understand and improve Products and Services, and to monitor for and prevent fraud. We only rely on our own or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.
We do not use profiling to make decisions that would significantly affect you.
When We Disclose Information
We will not disclose your information that we collect through the Products and Services to third parties except as described in this Policy or as we disclose to you at the time the information is collected. We may disclose the categories of information described above in “Information We Collect” to the third parties and for the purposes described below:
• We may disclose your information to our parent company, affiliates and subsidiaries globally when permitted by law, and necessary to provide you with services. This information may include all of the categories described above in “Information We Collect.”
• We work with third party service providers to provide application development, electronic messaging, and other services for us. We require these service providers to use or disclose the information they process on our behalf, only as necessary to perform services on our behalf or comply with legal requirements. This information may include all of the categories described above in “Information We Collect.”
• We may preserve and disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or enforceable request. This information may include all of the categories described above in “Information We Collect.”
• We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activities, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Products and Services and any facilities or equipment used to make the Products and Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others. This information may include all of the categories described above in “Information We Collect.”
• Information about users, including information you provided and any information collected through the Products and Services, may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. This information may include all of the categories described above in “Information We Collect.”
• We may make certain aggregated, de-identified, or non-identifying information about users available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) product safety analysis; or (iv) to assist such parties in understanding users’ interests, habits, and usage patterns for certain programs, services, and/or functionality of the Products and Services.
Your rights and choices regarding this data
You may update, correct, or delete certain Avinox account information and preferences by accessing your account preferences page.
If you are located in the European Economic Area, you may also have the right to request access to additional information, including the right to request access to and receive certain information we maintain about you; to update or correct inaccuracies in the information we maintain about you; to receive a copy of the information which you provided for its transmission to another company; to object to the processing on grounds relating to your particular situation; and to have the information blocked, deleted, or erased, as appropriate. When we process personal data on the basis of your consent, you can also withdraw your consent. If you withdraw your consent, we will apply your preferences going forward, and this will not affect the lawfulness of the processing before you withdrew your consent.
Note, however, that if you exercise your right to object or your rights of blocking, deletion or to be “forgotten” or if you decline to share certain information with us, or if you withdraw your consent to our processing of information about you, we may not be able to provide to you some, or any, of the features and functionality of the Products and Services.
Likewise, if you close your Avinox account, you will not be able to sign in to the Products and Services or access any of your information of the Products and Services. However, you can open a new account at any time. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit, as authorized under applicable law, for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information will be subject to those third parties’ policies.
If you wish to exercise any rights you have under applicable data protection law, including the right to access, amend or delete any information we hold about you, you may contact us at service@avinox.com.
We will review any information you provide with your request and may request additional information to ensure we are interacting with the correct individual. If you have an user account with us, you may be required to log-in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.
You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a notarized statement. You must submit evidence of your designation of an authorized agent in writing to: SZ Avinox Innovation Co., Ltd., Room 662D, Tower A, Building 1, Shenzhen Software Industry Base, Binhai Community, Yuehai Street, Nanshan District, Shenzhen, China, 518054. We may require verification of your authorized agent in addition to the information for verification above.
Third-Party Services
The Products and Services may contain features or links to websites and services provided by third parties. Any information you choose to provide on third-party sites or services, or any information otherwise collected by such third-party sites or services is collected directly by the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Products and Services.
We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Products and Services. If you opt in to use such third-party services, please be sure to check the Privacy Policies of these sites as well as their “Terms of Use” before engaging in any business or uploading any information.
Children’s Privacy
Except for certain products that are marked as “14+” or “for customers over the age of 14”, the Products and Services are not directed to children under the age of 16. We do not knowingly collect or process information from children under the age of 16 without obtaining parental consent.
Data Security
We use certain physical, organizational, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards.
International Transfers of Personal Data
Your information collected by us may be transferred to and accessed by Avinox entities and business partners globally to provide services to you. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers to provide features and services. By providing your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. You may obtain a copy of the standard contractual clauses by contacting us at service@avinox.com.
Retention of Your Information
We retain your information to provide service to you, or as required by applicable laws or regulations. We aim to retain your information only for the period necessary to fulfil our obligations under this Policy, unless otherwise required or permitted by law. We will carefully assess the need to collect data, the type of data collected, relevant legal framework, and the statute of limitations when determining the retention period.
Potential changes to this Policy
We may update this Policy from time to time. If we modify this Policy, we will make it available in or through the Products and Services and indicate the date of the latest revision. We will make reasonable efforts to notify you of the change.
Our Contact Information
Please contact us with any questions or comments about this Policy or our data practices by email at service@avinox.com or in writing to SZ Avinox Innovation Co., Ltd., Room 662D, Tower A, Building 1, Shenzhen Software Industry Base, Binhai Community, Yuehai Street, Nanshan District, Shenzhen, China, 518054.