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Privacy Policy

September 12, 2022


Delfast Inc., (“Delfast” “we” or “us”) respects your privacy and is committed to protecting it.

This Privacy Policy describes how we may collect, use, and share your personal information in connection with providing our “Website” - delfastbikes.com. or any other application, product or service that refers to this Policy (collectively, with the Website, the “Services”). This Policy also explains certain rights and choices you may have regarding your personal information. By using the Services, you consent to the practices described in this Policy, unless further consent is required by applicable law.

Please read this Policy together with any Service-specific or location-specific privacy statements or notices that we may provide. Those statements or notices supplement this Policy, and to the extent they differ from this Policy, the statements or notices shall govern.

Personal Information We Collect

Generally speaking, your “personal information” or “personal data” includes your unique identifiers (for example, your full name, phone number, or email address); and information about your characteristics, conditions or behaviour that is associated with one of your identifiers or could otherwise reasonably be linked to you. “Non-personal information,” on the other hand, is information that has been anonymised, aggregated or de-identified such that it cannot reasonably be linked to an individual.

The personal information that we may collect includes:

Information You Provide

We may receive some or all of the types of information listed below when you open an account with us; fill out a form on the Website; subscribe to one of our newsletters; search, shop for, or purchase one of our electric motorbikes or other products; take a test ride; participate in our referral program; participate in a contest or giveaway; interact with us on social media; or directly contact us with questions or feedback:

• full name;

• username;

• email address;

• physical address;

• phone number;

• credit card or financial account information;

• social security number;

• demographic information;

• content in your comments, posts or communications.

If you decline to provide requested information, we may not be able to provide one or more Services to you, or you may not receive access to certain features of a Service.

Information Automatically Logged

When you visit our Website, computer servers may automatically log certain information about you or your device, including:

• username

• internet protocol (IP) address

• device ID, operating system, browser type

• web browsing history

• shopping history

• location data

Some of this information is logged through the use of “cookies” and similar technologies.

Location Tracking

Delfast | My eBike Ride app (from now on - "App") will request users to grant the location permissions in the background to enable the features using the location. The location data is used and handled by the App in the following features and scenarios:

  • "Bike auto-unlock" feature: when the user stays in the area near the bike, they need to launch the Bluetooth scanning in the app to find, identify and unlock the bike (permission: Access Background Location).

  • "Bike auto-lock" feature: when the user stays in the area near the bike, they need to launch the Bluetooth scanning in the app to find, identify and lock the bike (permission: Access Background Location).

  • Reconnect to the bike scenario: when the user leaves the area of the Bluetooth connection, the connection with the bike will be lost; however, as soon as the user is back to the area of the Bluetooth connection, the connection with the bike will be established again (permission: Access Background Location).

  • "Map" feature: the location is tracked in real-time to show the bike position on the map when no specific route was chosen (permission: Access Fine Location).
    "Security" feature: the location is tracked to show the bike's location in real-time and the bike's position in case of unauthorized movement (e.g., when the bike is stolen). Permission: Access Fine Location.

  • "Navigation" feature: the location is tracked to show the user's location in real-time when the user has chosen the route and follows the route, and to rebuild the route in case of deviation from the original route (permission: Access Fine Location).

Information Received From Other Sources

We may obtain information about you from other sources, including our service providers; product dealers or distributors; or product repair providers. For example, if you buy one of our products on eBuy.com, eBuy may give us access to basic information, including your name, order details, address and phone number. We may combine such information with information we have collected about you. We are not responsible for the accuracy of any information provided by third parties.

How We Use Personal Information

We may use the personal information we collect for a number of purposes, including:

• To verify your identity

• To provide a service to you or perform an agreement with you

• To communicate with you about services you have requested or that we are providing to you

• To communicate with you about other services that we believe may be beneficial to you

• To market our products and services more effectively and personalize our advertising

• To bill for our services

• To process payments for our services

• To complete any other transactions for which the personal information was collected

• To personalize your use of our services

• To secure, maintain and improve our Websites

• To comply with our legal obligations or protect our legal rights

• To fulfill any internal functions that are reasonably aligned with your relationship with us or the context in which you provided the information to us

• For any other purposes to which you have consented

We may use non-personal information for any purpose.

How We Share Personal Information With Others

We do not disclose your personal information to others except as follows:

Corporate parents, affiliates and subsidiaries. We may share your information with our corporate parents, subsidiaries, and other affiliated entities for a variety of purposes, including business, operational and marketing purposes.

Service providers. We may share your information with our third party service providers that perform certain functions or services on our behalf, such as to host the Services, manage databases, perform analyses, conduct surveys, or send communications and newsletters for us. Our agreements with those providers require them to limit their use of such personal information to the uses we have authorized and to comply with applicable laws regarding protection of personal information. The following service providers have asked that we direct you to their privacy policies:

  • Google. We use Google Ads to re-market to visitors to our Website elsewhere online. We also use Google Analytics, which helps us evaluate the use of our Website.

  • For information about Google’s privacy practices, please click here: google.com/policies/privacy/partners/.


Mandatory disclosures and legal proceedings. We may have a legal obligation to disclose personal information to government authorities or other third parties pursuant to a valid regulatory request, subpoena, litigation demand or court order. We may also need to disclose and otherwise process your personal information in accordance with applicable law to defend our legitimate interests, for example, in civil or criminal legal proceedings.

Mergers, Acquisitions or Reorganization. If we decide to sell, buy, merge or otherwise reorganize our businesses, this can involve us disclosing personal information to prospective or actual purchasers and their advisers, or to a new affiliate of ours.

Pursuant to your consent. We may share your personal information with others if we have your consent to do so.

Quality And Retention of Personal Information

We take reasonable steps to keep the personal information we possess accurate and to delete incorrect or unnecessary personal information. We retain personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or otherwise communicated to you, unless a longer period is required by applicable law. If you have an account with us, we encourage you to access your personal information from time to time to help us ensure that it is up to date.

Data Security

In order to safeguard personal information against unauthorized access or use, we maintain administrative, physical and technical security procedures and practices appropriate to the nature of the information. We regularly assess the performance and adequacy of those procedures and practices and will adjust them when new operations or risks require it. Unfortunately, in our increasingly connected digital world, no one can guarantee perfect data security, and we cannot promise that our procedures and practices will always prevent a breach of personal information. Should we detect such a breach, we will promptly notify affected individuals, third parties and law enforcement agencies as required by applicable law.

We encourage you to help maximize security by applying your own personal security measures. For more information about what you can do to protect your data, please see the tips and resources offered by the U.S. Federal Trade Commission at https://www.consumer.ftc.gov/topics/privacy-identity-online-security and the California Attorney General at https://www.oag.ca.gov/privacy/consumer-privacy-resources.


Do Not Track” Signals

The web browsers and applications that you use to visit our Website and Services may provide certain “Do Not Track” capabilities. Generally, browsers that have these features enabled send a signal to websites that inform the site operator that you do not wish for the site to track you online. We do not currently respond to these signals because there is not yet a common understanding of how to process these signals or a consensus on what “tracking” means.

Links to Social Media And Other Third Party Services

Our Services may contain links to third-party websites, products or services. For example, our Website contain links provided by Facebook, Instagram and other social media platforms that you can use to post directly from our Website. Information collected by those third parties is governed by their privacy policies, not ours. We encourage you to learn about the privacy practices of those third parties.

California Residents

California residents are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. We do not share your personal information with third parties for their direct marketing purposes without your consent.

We may process your personal data for the purposes described above How We Use Personal Information if at least one of the following grounds for processing applies:

• Processing is necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract;

• Processing is necessary to comply with our legal obligations;

• Processing fulfills our legitimate interests in a manner that does not outweigh your rights and freedoms. Our legitimate interests include: protecting our Services against malicious intrusions and unauthorized use; maintaining and improving our Services; understanding how our Services are used; personalizing our Services; promoting our Services effectively; and complying with legal obligations and protecting our legal rights.

• Processing is necessary to protect the vital interests of you or another individual

• You have consented to the processing

International transfers

Delfast Inc. has its headquarters in the United States. Information we collect about you will therefore be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Commission under Article 45 of the GDPR. To the extent we make transfers of personal information to third parties in the United States or other countries that have not received an adequacy finding, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we make such transfers: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also endeavor to enter into data processing agreements and European Commission-approved model clauses with service providers whenever feasible and appropriate.

Automated decision making

We do not make any decisions involving the use of algorithms or profiling that significantly affects you.

Your rights under GDPR

The GDPR provides you with the following rights, which you can exercise by contacting at [email protected]:

• The right to request access to and rectification of your personal information. You may obtain additional information about our processing and a copy of your stored information. You also have the right to request that we update your information if it is inaccurate or incomplete.

• The right to request erasure of your personal information. You may request for us to erase your information from our systems if it is no longer necessary for the reason we collected it, or you withdraw consent and no other legal basis for processing exists.

• The right to restrict our processing of your personal information. You have the right to restrict our processing if: (1) you disagree with the accuracy of your information; (2) our processing is deemed unlawful and you do not want us to erase your information; or (3) we no longer need your information for the purposes for which we collected it but we must store it to comply with our legal obligations.

• The right to data portability. You may receive and transmit your personal information to another controller where our processing is based on consent you gave us and was carried out by automated means.

• The right to object. You have the right to object to our processing of your personal information where we process it because of a legitimate interest.

You also have the right to file a complaint with the supervisory authority of your member state.

Changes To This Policy

We will update this Privacy Policy to reflect changes in applicable law, our privacy practices, or our Services. If you have given us your online contact information, we will notify you of material changes. You should periodically review this Privacy Policy to remain aware of our current practices.

Contact Us

For inquiries relating to our processing of personal information of data subjects or to exercise your rights under the GDPR, please contact us at [email protected].

For any other questions or concerns about this Privacy Policy or our practices, or to exercise your rights regarding your personal information under applicable law, please contact us at:

Delfast Inc.

16192 Coastal Highway, Lewes,

County of Sussex, DE, US, 19958

Phone: +1 213 933 2123

[email protected]

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