PRIVACY POLICY OF MICROPROGRAM INFORMATION Co., Ltd.
09 January 2020 Update

This Privacy Policy (hereinafter this “Policy”) is on 26 August 2019 adopted by Microprogram Information Co., Ltd. (hereinafter “Microprogram”), which is a company incorporated under laws of Taiwan with registered address at 7F, No.402, Shizheng Rd, Xitun Dist.,Taichung City 407.,Taiwan. Microprogram commits to respect and protect users’ privacy. This Privacy applies to usage of and all service available on BICONNECT App (hereinafter “App”) and the website https://www.bikonnect.com/ (hereinafter the “Web”) which are created and maintained by Microprogram Information Co., Ltd. Microprogram creates this Policy to inform users on how Microprogram collects, saves, processes and uses users’ personal information, and how can users do to exercise relevant rights granted under applicable laws. Users are encouraged to read this Policy carefully and contact Microprogram with any questions or concerns about Microprogram’s privacy practices.

Only after users agree to the collection and use of information in relation to this Policy, may users utilize Microprogram’s service. Personal information Microprogram collects will be used only for improving and providing the service. Microprogram will not use, share, rent or sell users’ information to anyone except as described in this Policy.

The protection of personal information collected through any website which is linked from the Web and is independently managed and operated by a third party shall be subject to privacy policies or websites of third parties. Microprogram neither endorses such policies or websites of third parties nor assumes any joint liability thereof.

Microprogram reserves rights to modify this Policy at its sole discretion, and if users continue to use Microprogram’s website services after Microprogram publish or send the notification of any change to this Policy, such users will be deemed to have acknowledged that modification.

1. Personal information to be collected and used by Microprogram

When users initiate contact Microprogram intending to utilize services provided through Microprogram’s website, users may need to provide their personal information including name, phone number, and email. Microprogram will process and use users’ personal information for such request of service. Without users’ written consent, Microprogram will not use users’ personal information for any other purpose. The Web does not collect any information about an individual’s identity if users only browse the Web or download files.

When users use Microprogram’s app or other services, Microprogram needs to use users’ personal information for specified purposes. As a general rule, when users open users accounts, at first Microprogram will request the following personal information from users: name, password, E-mail address, gender, birthday, height, weight, country, profile photo,bike photo. And the App will require to access to users’ position related data (GPS), Bluetooth connection, camera and photo album in users’ mobile device to enable specific functions in the App.

Users’ personal information is required in order to enable Microprogram to enter into a user agreement and any other agreement with users and perform under these agreements. Personal information provided by filling and submitting a contact form is also necessary to enable Microprogram to respond appropriately to any inquiries. Microprogram will store users’ personal information in Taiwan and database server in Amazon Web Service as long as necessary for aforementioned purposes. Thereafter, it will be deleted from Microprogram’s system. To enable users to use Microprogram’s App service, Microprogram will collect personal information and technical data in the context of the provision of Microprogram’s App service, which including: users’ profile data, bike information, maintenance appointment data, maintenance history, emergency contact email address, IP address, position related data (GPS), drive unit data, e-bike manufacturer and model, e-bike diagnostic data, display data on bike, addresses of stores and navigation records, heart rate, movement speed, watts of movement, odograph records, data of battery power, cadence, altitude ,consumed calories, torque sensor records, other logs, assistance mode usage. The personal and technical data will be collected, saved, processed and used to have users able to avail themselves of Microprogram’s App service, to offer new services to the users, to improve the services, and to satisfy the users' needs. The purpose to collect such data is to provide users wishing to make use of the features with information about their bikes, e-bikes and also about rides and activities of bikes and e-bikes depending on their particular requirements. Microprogram retains and uses de-identificated personal data in order to develop and improve applications in line with users’ requirements. Microprogram reserves the right to evaluate the data on an de-identificated basis, to publish it on the platform in the form of statistics and to use such data.

Profile, activity and usage information is collected when users choose to upload a picture, activity information(including date, time and geo-location information as well as used bike, ride duration, ride distance, users’ speed, e-bike battery usage) or post a text, join a group activity or challenge, add users’ equipment for usage, view others’ activities, or otherwise use the Services. Microprogram will use users’ contact information to respond to users’ support requests and comments.

Microprogram collect and process location information when users sign up for and use the services. Microprogram do not track users’ device location while users are not using Microprogram’s App, but in order to provide App’s core services, it is necessary for us to track users’ device location while users use our App. If users would like to stop the device location tracking, users may do so at any time by adjusting users’ device settings.

Microprogram gather information from the posts, comments, ratings, reviews, and other content users share on the services when users join a group, including when users participate in partner events. And the members of the group which users have joined can see the posts users share in the groups.

l   Third-Party Accounts

Microprogram allows users to sign up and log in to the services using accounts users create with third-party products and services, such as Facebook, Google, or Apple (collectively, “Third-Party Accounts”). If users access the services with Third-Party Accounts Microprogram will collect information that users have agreed to make available such as users’ name, email address, profile information and preferences. This information is collected by the Third-Party Account provider and is provided to Microprogram under their privacy policies. Users can generally control the information that Microprogram receives from these sources using the privacy controls in users’ Third-Party Account management pages.

2. Cookies

Cookies are files with a small amount of data that is commonly used as an anonymous unique identifier. These are sent to users’ browser from the website that users visit and are stored on users’ devices’ internal memory. The App may use third party code and libraries that utilizing “cookies” to collect information and to improve their services.

Users will be alarmed when a cookie is sent to users’ devices, and Users may either accept or refuse these cookies. If users choose to refuse Microprogram’s cookies, such users may not be able to use some parts of service.

Microprogram’s website uses cookies to identify users’ preferences on the website. In these cookies, Microprogram uses the so-called “Track ID” function to track a user’s behavior, for example, tracking the web pages browsed by the user, stay time, device information, and Microprogram will use such information as a reference for adjusting the website content. Microprogram also uses Google Analytics to analyze the users’ online behaviors as part of website traffic statistics. The privacy policy of Google Analytics is available on https://policies.google.com/technologies/cookies?hl=en

The “Track ID” function used by the Web is an anonymous tracker. A user is not required to provide any personal information if he/she just browse the website anonymously. Therefore, Microprogram will not be able to link this Track ID to any private information, including email, mobile number, or address. That means Microprogram will not know the true identity of any user through this Track ID function.

Besides cookies, Microprogram also collects additional information as below:

  • URL visited by the user
  • User’s source address and IP address
  • Brand, model no. and operating system of user’s connection device
  • Browser type, resolution and color support of user’s connection device
  • Geographical information about where user connect to internet (for example, reserved lookup records indirectly through a third-party GeoIP)
  • The ISP service provider of user who connect to internet (for example, reserved lookup records indirectly through a third-party GeoIP)

3. Collection of personal data

Microprogram collects or obtains personal data of users from the following sources:

(1)     Data provided to us: Microprogram obtains personal data when those data are provided to Microprogram (e.g., where users contact Microprogram via email or telephone, or by any other means

(2)     Relationship data: Microprogram collects or obtains personal data in the ordinary course of Microprogram’s relationship with users (e.g., Microprogram provides a service to users.)

(3)     App data: Microprogram collects or obtains personal data when users download or use any of Microprogram’s Apps.

(4)     Web’s data: Microprogram collects or obtains personal data when users visit any of Microprogram’s Webs or use any features or resources available on or through a Web.

(5)     Registration details: Microprogram collects or obtains personal data when users use, or register to use, any of Microprogram’s Webs, Apps, products, or services.

4. Categories of personal data Microprogram processes

 

Microprogram processes the following categories of personal data about users:

(1)     Personal details: user name; nickname and photograph.

(2)     Demographic information: gender; date of birth / age; nationality.

(3)     Contact details: telephone number; email address

(4)     Consent records: records of any consents users have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).

(5)     Purchase details: bike purchased date; purchased store

(6)     Data relating to Microprogram’s Webs and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Web; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute personal data); username; password; security login details; usage data; aggregate statistical information.

(7)     Content and advertising data: records of users’ interactions with Microprogram’s online advertising and content, records of advertising and content displayed on pages or App screens displayed to users, and any interaction users may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms users complete in whole or in part) and any touchscreen interactions.

(8)     Views and opinions: any views and opinions that users choose to send to Microprogram, or publicly post about Microprogram on social media platforms.

5. Sensitive Personal Data

Microprogram does not seek to collect or otherwise process sensitive personal data in the ordinary course of Microprogram’s business. Where it becomes necessary to process users’ sensitive personal data for any reason, Microprogram relies on one of the following legal bases:

(1)     Compliance with applicable law: Microprogram may process users’ sensitive personal data where the processing is required or permitted by applicable law (e.g., to comply with Microprogram’s diversity reporting obligations);

(2)     Detection and prevention of crime: Microprogram may process users’ sensitive personal data where the processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);

(3)     Establishment, exercise or defence of legal rights: Microprogram may process users’ sensitive personal data where the processing is necessary for the establishment, exercise or defense of legal rights; or

(4)     Consent: Microprogram may process users’ sensitive personal Data where Microprogram has, in accordance with applicable law, obtained users’ prior, express consent prior to processing users’ Sensitive personal data (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

If users provide sensitive personal data to Microprogram, users must ensure that it is lawful for users to disclose such data to Microprogram, and users must ensure a valid legal basis applies to the processing of those sensitive personal data.

6. Purposes of processing and legal grounds for processing

The purposes for which Microprogram processes personal data, subject to applicable law, and the legal bases on which we perform such processing, are as follows:

Processing activity

Legal basis for processing

Provision of Webs, Apps, products, and services: providing Microprogram’s Webs, Apps, products, or services; providing promotional items upon request; and communicating with users in relation to those Webs, Apps, products, or services.

(1)     The processing is necessary in connection with any contract that users have entered into with us, or to take steps prior to entering into a contract with Microprogram; or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of providing Microprogram’s  (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms); or

(3)     Microprogram has obtained users’ prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

Operating Microprogram’s business: operating and managing Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, and Microprogram’s services; providing content to users; displaying advertising and other information to users; communicating and interacting with users via Microprogram’s Webs, Microproram’s Apps, Microprogram’s products, or Microprogram ‘sservices; and notifying users of changes to any of Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, or Microprogram’s services.

(1)     The processing is necessary in connection with any contract that users have entered into with Microprogram, or to take steps prior to entering into a contract with Microprogram; or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of providing Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, or Microprogram’s services to users (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms); or

(3)     Microprogram has obtained users’ prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

Improving Microprogram’s Webs, Apps, products, and services: identifying issues with Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, or Microprogram’s services; planning improvements to Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, or Microprogram’s services; and creating new Webs, Apps,  products, or services.

(1)     Microprogram has a legitimate interest in carrying out the processing for the purpose of improving Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, or Microprogram’s services (to the extent that such legitimate interest is not overridden by users interests, fundamental rights, or freedoms); or

(2)     Microprogram has obtained users’ prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

Communications and marketing: communicating with users via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which users may be interested, subject always to obtaining users’ prior opt-in consent to the extent required under applicable law; maintaining and updating users’ contact information where appropriate; and obtaining users’ prior, opt-in consent where required.

(1)     The processing is necessary in connection with any contract that users have entered into with Microprogram, or to take steps prior to entering into a contract with Microprogram; or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of providing Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, or Microprogram’s services to users (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms); or

(3)     Microprogram has obtained users’ prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

Product safety communications: communications in relation to product safety, including product recalls and product safety advisory notices.

(1)     The processing is necessary for compliance with a legal obligation; or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of ensuring the safety, and proper use, of Microprogram’s products (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms).

Management of IT systems: management and operation of Microprogram’s communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

(1)     The processing is necessary for compliance with a legal obligation; or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of managing and maintaining Microprogram’s communications and IT systems (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms).

Surveys: engaging with users for the purposes of obtaining users’ views on Microprogram’s Webs, Microprogram’s Apps, Microprogram’s products, or Microprogram’s services.

(1)     Microprogram has a legitimate interest in carrying out the processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms); or

(2)     Microprogram has obtained users’ prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law

(1)     The processing is necessary for compliance with a legal obligation; or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of detecting, and protecting against, breaches of Microprogram’s policies and applicable laws (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms).

Legal proceedings: establishing, exercising and defending legal rights.

(1)     The processing is necessary for compliance with a legal obligation; or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of establishing, exercising or defending Microprogram’s legal rights (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms).

Legal compliance: compliance with Microprogram ‘slegal and regulatory obligations under applicable law.

The processing is necessary for compliance with a legal obligation.

Fraud prevention: detecting, preventing and investigating fraud.

(1)     The processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

(2)     Microprogram has a legitimate interest in carrying out the processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by users’ interests, fundamental rights, or freedoms).

 

7. How Does Microprogram Use the Information

  • To respond to users’ inquiry

To professionally response to the users’ inquiries, and provide relevant product information for the users’ reference.

  • To learn and optimize website content and App service

Microprogram’s website uses the information collected as aforementioned to research on how to optimize the website content through artificial intelligence, machine learning, big data, and other analytic methods.

8. How Does Microprogram Share the Information

  • The party with whom Microprogram share the information

The personal device records and cookie records of the users collected through Microprogram’s website services or App service as mentioned above are solely for Microprogram’s internal use, and will not be shared with any third party, nor will Microprogram provide the browsing history and other sensitive personal information of individual users to any third party, unless:

    • Users have agreed in writing;
    • It is required by any applicable laws, regulations, orders, or lawful governmental request;
    • It is to detect, prevent, or deal with any security or technical issue (such as investigating a possible violation).
  • Information retention period

The original log files of the personal device records and cookie records of the users collected by Microprogram’s website services as above will be kept at Microprogram’s data center for 1 month. Past log files will be deleted month by month.

 

9. How do Microprogram Protect Personal information

Microprogram will undertake necessary procedures to (1) protect data against accidental loss, (2) to prevent unauthorized access, use, destruction or disclosure,(3) to ensure business continuity and disaster recovery, (4) to restrict access to personal information, (5) to conduct privacy impact assessments in accordance with applicable laws and Microprogram’s business policies, which including but not limited to the following:

  • Install firewalls to prevent hacking, destruction or theft of data, avoid illegal use of the website, and protect users’ interests.
  • Conduct daily back-ups.
  • Run weakness screening and enhance the security of the operating system and the webserver.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although Microprogram will implement all reasonable measures to protect users’ personal data, Microprogram cannot guarantee the security of users’ data transmitted to us using the internet – any such transmission is at users’ own risk and users are responsible for ensuring that any personal data that users send to Microprogram are sent securely.


 10. Data retention

Microprogram will take reasonable step to ensure that users’ personal data are only processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which Microprogram will retain users’ personal data are as follows:

(1)     Microprogram will retain personal data in a form that permits identification only for as long as:

A.       Microprogram maintains an ongoing relationship with users (e.g., where users are a user of Microprogram’s Apps, or users are lawfully included in Microprogram‘s mailing list and have not unsubscribed); or

B.       Users’ personal data are necessary in connection with the lawful purposes set out in this Notice, for which Microprogram has a valid legal basis (e.g., Microprogram has a legitimate interest in processing those data for the purposes of operating Microprogram’s business and fulfilling Microprogram’s obligations under that contract; or where Microprogram has a legal obligation to retain users’ personal data),

(2)     the duration of:

A.       any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against Microprogram in connection with users’ personal data, or to which users’ personal data are relevant); and

B.       an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, Microprogram is still afforded a reasonable amount of time in which to identify any personal data that are relevant to that claim),

(3)     in addition, if any relevant legal claims are brought, Microprogram continues to process personal data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)A and (2)B above, Microprogram will restrict Microprogram’s processing of users’ personal data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, Microprogram will either:

· permanently delete or destroy the relevant personal data; or

· de-identificate the relevant personal data.

 

11. Users’ Rights

Users may (1) access to personal information, (2) request for correction and deletion of personal information, (3) withdrawal of consent (4) request for data portability (5) restrict or object to processing of persona; information (6) lodge a complaint with EU Information Commissioner’s Office.

Subject to applicable law, users may have the following rights regarding the processing of users’ relevant personal data:

(1)     the right not to provide users’ personal data to Microprogram (however, please note that Microprogram will be unable to provide users with the full benefit of Microprogram’s Sites, Apps, products, or services, if users do not provide Microprogram with users personal data – e.g., Microprogram might not be able to process users’ requests without the necessary details);

(2)     the right to request access to, or copies of, users’ relevant personal data, together with information regarding the nature, processing and disclosure of those relevant personal data;

(3)     the right to request rectification of any inaccuracies in users’ relevant personal data;

(4)     the right to request, on legitimate grounds:

A.       erasure of users’ relevant personal data; or

B.       restriction of processing of users’ relevant personal data;

(5)     where Microprogram processes users’ relevant personal data on the basis of users’ consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which Microprogram receives notice of such withdrawal, and does not prevent the processing of users’ personal data in reliance upon any other available legal bases); and

(6)     the right to lodge complaints regarding the processing of users’ relevant personal data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which users live, or in which users work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, users may also have the following additional rights regarding the processing of users’ relevant personal data:

(1)     the right to object, on grounds relating to users’ particular situation, to the processing of users’ relevant personal data by Microprogram or on Microprogram’s behalf; and

(2)     the right to object to the processing of users’ relevant personal data by Microprogram or on Microprogram’s behalf for direct marketing purposes.

This does not affect users’ statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about Microprogram’s processing of users’ personal data, please use the contact details provided in Section 15 below. Please note that:

(1)     in some cases it will be necessary to provide evidence of users’ identity before Microprogram can give effect to these rights; and

(2)     where users’ request requires confirmation of additional facts (e.g., a determination of whether any processing is non-compliant with applicable law) Microprogram will investigate users’ request reasonably promptly, before deciding to take specific actions.

12.  Direct marketing

Microprogram processes personal data to contact users via email, telephone, direct mail or other communication formats to provide users with information regarding Sites, Apps, products, or services that may be of interest to users. If Microprogram provides Sites, Apps, products, or services to users, Microprogram may send information to users regarding Microprogram’s Sites, Apps, products, or services, upcoming promotions and other information that may be of users‘ interest, using the contact details that users have provided to Microprogram, subject always to obtaining users’ prior opt-in consent to the extent required under applicable law.

Users may unsubscribe from Microprogram’s promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email Microprogram sends. After users unsubscribe, Microprogram will not send to users any promotional emails, but in some circumstances Microprogram will continue to contact users to the extent necessary for the purposes of any Sites, Apps, products, or services users have requested.

13. Cross-border transmission

As stated in paragraph 4.1, the personal information collected through Microprogram’s website services and App service are solely for internal utilization. All network communications of direct or cross-border transmission of personal information will only occur under an encrypted environment for secure internet connection such as SSL or HTTPS. All communications are subject to the SSL 2048 bits encryption or TLS 256 bits to ensure data security throughout the transmission.

14. Privacy Policy Information

Microprogram reserves the right to modify this Privacy Policy at any time. Please read it occasionally. If Microprogram makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if Microprogram makes material changes, Microprogram will provide a prominent notice. If users object to any of the changes to this Privacy Policy, users should stop using the Services and delete users’ account.

15. Contact information:

If users have any question about this Policy or need to file any complaint, please contact us by the following methods:

  • Company: Microprogram Information Co., Ltd.
  • Tel: +886-4-2369-2699
  • Email: [email protected]