The website carolbike.com, the CAROL bike app, and the CAROL mobile app (together the “Site”) are provided by Integrated Health Partners Limited (“we”/”us”/”our”). In doing so, we may be in a position to receive and process personal information relating to you. As the controller of this information, we’re providing this Privacy Notice (“Notice”) to explain our approach to personal information. This Notice forms part of our Terms and Conditions, which govern the use of this Site.
You may browse parts of our website without providing any information about yourself and without accepting cookies. In such cases, it is unlikely that we will obtain and process any information relating to you.
Sometimes, when you take a new service or product from us, or discuss taking a new service or product but decide against it, we might wish to provide you with further information about similar services or products by email or other written electronic communication. In that situation, we will always give you the opportunity to refuse to receive that further information—and if you change your mind, please let us know. We will endeavor to remind you of your right to opt out on each occasion that we provide such information.
1 Identity and contact details
1.1 Registered number: 6107341
1.2 Registered office: 2 Underwood Row, London, N1 7LQ, United Kingdom
1.3 Contact email: firstname.lastname@example.org
2 When we’re allowed to collect information from you
We will only collect personal information relating to you if one of the following conditions has been satisfied:
2.1 You have clearly told us that you are content for us to collect that information for the purpose or purposes that we will have specified.
2.2 The processing is necessary for the fulfillment of a contract that we have with you.
2.3 The processing is necessary so that we can comply with the law.
2.4 The processing is necessary to protect someone’s life.
2.5 The processing is necessary to perform a task in the public interest.
2.6 The processing is necessary for our or another’s legitimate interest—but in this case, we’ll balance those interests against your interests.
3 How to consent
3.1 At the point of collecting the information, we will endeavor to explain how we intend to use the information and which of these purposes apply. If we rely on consent, we will provide you with the opportunity to tell us that you are happy to provide the information.
3.2 If at any point in time you change your mind and decide that you do not consent, please let us know and we’ll endeavor to stop processing your information in a specified manner, or we will delete your data if there is no ongoing reason for us to continue possessing it.
3.3 If you do not consent to a particular bit of processing, we’ll endeavor to ensure that the Site and our service continue to operate without the need for that information.
4 Information we expect to collect from you
4.1 We envisage asking you for the following types of information (Information type: Purpose(s) and related details. Justification):
Email address: To provide marketing messages and product updates (newsletter); To contact you in response to a query you sent us; To process an order; To create a user account to use the CAROL stationary bike. You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified.
Full name: To contact you in answer to a query you sent us; To process an order; To create a user account to use the CAROL stationary bike. You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified; It is necessary for the fulfillment of a contract with you.
Telephone number: To contact you in answer to a query you sent us; To process an order. You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified; It is necessary for the fulfillment of a contract with you.
Credit card details: To process an order. It is necessary for the fulfillment of a contract with you.
Address: To process an order. It is necessary for the fulfillment of a contract with you.
Physical Activity Readiness Questionnaire: To create a user account to use the CAROL stationary bike. You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified.
Gender, date of birth, height, weight, activity level: To create a user account to use the CAROL stationary bike; To calculate settings to control CAROL stationary exercise bike. You have clearly told us that you are content for us to collect that information for the certain purpose or purposes that we will have specified.
4.2 We may collect personal information about you from a number of sources, including the following:
4.2.1 From you when you agree to take a service or product from us; this may include your contact details, date of birth, how you will pay for the product or service, and your bank details.
4.2.2 From you when you contact us with an enquiry or in response to a communication from us; this may tell us something about how you use our services.
4.2.3 From usage statistics when you use a CAROL stationary bike; this may include date and time of usage, equipment identifier, heart rate data, power data, rpm data, resistance setting, and how-do-you-feel indicator. The data will be used to calculate your fitness score (Octane Score), personal bests, track and visualize your improvement over time, participate optionally in leaderboards, and similar purposes. The data will be available for you to see in our bike, web and mobile app, for us to see for analytical, reporting and product development purposes, for the owner of the CAROL bike you used for reporting, billing and (optionally) coaching purposes.
4.2.4 From documents that are available to the public, such as the electoral register.
4.2.5 From third parties to whom you have provided information with your consent to pass it on to other organizations or persons—when we receive such information, we will let you know as soon as is reasonably practicable.
4.3 If you refuse to provide information requested, then if that information is necessary for a service we provide to you, we may need to stop providing that service.
4.4 At the time of collecting information, by whichever method is used, we will endeavor to alert you and inform you about our purposes and legal basis for processing that information, as well as whether we intend to share the information with anyone else. If at any point you think we have invited you to provide information without explaining why, feel free to object and ask for our reasons.
5 Using your personal information
5.1 Data protection, privacy, and security are important to us; we will use your personal information only for specified purposes and will not keep such personal information longer than is necessary to fulfill these purposes. The following are examples of such purposes. We have also indicated below which GDPR justification applies; however, this will depend on the circumstances of each case. At the time of collecting, we will provide further information, and you may ask us for further information at any time.
5.1.1 To help us to identify you when you contact us. This will normally be necessary for the performance our contract.
5.1.2 To help us to identify accounts, services and/or products you may have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the personal information you have provided and/or any information we hold about you as well as personal information from third-party agencies (including credit reference agencies). We will use your information for this purpose only if you agree to it.
5.1.3 To help us to administer—and to contact you about improved administration—of any accounts, services and products we have provided before, provide now, or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary, in which case we will ask whether you consent.
5.1.4 To allow us to carry out marketing analysis and customer profiling (including with transactional information) and to conduct research, including creating statistical and testing information. This will sometimes require that you consent, but will sometimes be exempt as market research.
5.1.5 To help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or when the law requires it.
5.1.6 To allow us to contact you by written electronic means (such as email, text or multimedia messages) about products and services we offer, where:
188.8.131.52 These products are similar to those you have already purchased from us
184.108.40.206 You were given the opportunity to opt out of being contacted by us at the time your personal information was originally collected by us and at the time of our subsequent communications with you, and
220.127.116.11 You have not opted out of us contacting you.
5.1.7 To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.
5.1.8 We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
18.104.22.168 Before doing so, we will always tell you of our intentions and of the specific purpose in making the recording. Sometimes, such recordings will be necessary to comply with the law. Alternatively, sometimes the recording will be necessary for our legitimate interest, but in that case we will record the call only if our interest outweighs yours. This will depend on all the circumstances—in particular, the importance of the information and whether we can obtain the information in another, less intrusive way.
22.214.171.124 If we think the recording would be useful for us but also that it is not necessary, we will ask whether you consent to the recording, and will provide an option for you to tell us that you consent. In those situations, if you do not consent, the call will either automatically end or will not be recorded.
5.1.9 When it is required by law, we will check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we intend to record this.
5.2 We will not disclose your personal information to any third party except in accordance with this Notice, and in particular in these circumstances:
5.2.1 They will be processing the data on our behalf as a data processor (where we will be the data controller). In that situation, we will always have a contract with the data processor as set out in the GDPR. This contract provides significant restrictions as to how the data processor operates so that you can be confident your data is protected to the same degree as provided in this Notice.
5.2.2 Sometimes it may be necessary to share data with another data controller. Before doing so, we will always notify you. Note that if we receive information about you from a third party, we will let you know as soon as reasonably practicable, as is required by the GDPR.
5.2.3 Alternatively, sometimes we may consider it to be in your interest to send your information to a third party. If that is the case, we will always ask for your consent before sending.
5.3 Where you give us personal information on behalf of someone else, you confirm that you have provided them with the information set out in this Notice and that they have not objected to such use of their personal information.
5.4 In connection with any transaction which we enter into with you:
5.4.1 We may carry out one or more credit checks where you have given us your express consent.
5.4.2 We may carry out one or more fraud prevention checks with licensed fraud prevention agencies.
5.4.3 We and such licensed fraud prevention agencies may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records may also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organizations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
5.4.4 If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organizations. We, as well as other credit and insurance organizations, may also use technology to detect and prevent fraud.
5.4.5 If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at Integrated Health Partners Limited, 2 Underwood Row, London, N1 7LQ, United Kingdom.
5.4.6 We may need to transmit the payment and delivery information provided by you during the order process for the purpose of obtaining authorization from your bank or from PayPal.
5.5 We may allow other people and organizations to use personal information we hold about you in the following circumstances:
5.5.1 If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.
5.5.2 If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
5.5.3 We may employ companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above—for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit and debit card payments, and providing customer service. Those parties will be bound by strict contractual provisions with us and will have access only to such personal information as is needed to perform their functions, and they may not use it for any other purpose. Furthermore, they must process the personal information in accordance with this Notice and as permitted by the GDPR. From time to time, these other people and organizations to whom we may pass your personal information may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Notice and the GDPR.
6 Protecting information
6.1 We have strict security measures to protect personal information.
6.2 We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software to encrypt information you input.
6.3 We reveal only the last five digits of your credit card number when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
6.4 We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
6.5 It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
7 The internet
7.1 If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us personal information through the Site, we will normally give you the opportunity to say whether you would prefer that we not contact you by email. You can also always send us an email (at the address set out below) at any time if you change your mind.
7.2 Please remember that communications over the internet, such as emails and webmail (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered—this is the nature of the internet. We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.
8 Cookies and other internet tracking technology
8.2 Where applicable, this section of the Notice also relates to that technology, but the term “cookie” is used throughout.
8.3 Some of these cookies are essential to services you have requested from us, whereas others are used to improve services for you—for example, by:
8.3.1 Letting you navigate between pages efficiently,
8.3.2 Enabling a service to recognize your computer so you don’t have to give the same information during one task,
8.3.3 Recognizing that you have already given a username and password so you don’t need to enter it for every web page requested, and
8.3.4 Measuring how many people are using services, so they can be made easier to use and so that there is enough capacity to ensure that they are fast.
8.5 The distinctions between the cookies used are as follows:
8.5.1 First-party versus third-party cookies: We set first-party cookies ourselves; third-party cookies are set by other entities via our Site.
8.5.2 Session versus persistent cookies: Session cookies persist only for the duration of that visit; persistent cookies last for longer.
8.5.3 Identifying information removed: Just because we have removed identifying information, the cookies will still constitute personal information if the relevant information can be reassembled.
8.5.4 Categories 1–4 found in the ICC UK Cookie Guide, are explained below. Category 1 cookies don’t require the user’s consent, although users must still be notified about the cookies. Categories 2-4 do require users’ specific and informed consent.
Category 1: Strictly necessary. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like shopping baskets or e-billing, cannot be provided.
In this category we include cookies that are used only for electronic communication. (The ICC does not refer to these cookies, but the law is the same.)
Note that cookies for which another person is the controller will never be necessary for a service requested of you. On the other hand, if you have asked another person to send a cookie on your behalf for an essential feature of your website, that would be Category 1.
Category 2: Performance. These cookies collect information about how visitors use a website—for instance, which pages visitors go to most often, and whether they get error messages from web pages. This information is used only to improve how a website works.
Category 3: Functionality. These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personalized features. For instance, a website may be able to provide you with local weather reports or traffic news by using a cookie to store the region where you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for, such as a live chat session.
Category 4: Targeting and advertising. These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website, and this information is shared with other organizations, such as advertisers. Quite often, targeting or advertising cookies will be linked to site functionality provided by the other organization.
8.6 As with any other information we may collect from you, we will work to protect the security of your information during transmission by using by using Secure Sockets Layer (SSL) software to encrypt information you input.
8.7 The Site may include links to third-party websites. We do not provide any personally identifiable customer personal information to these third-party websites unless you have consented in accordance with this privacy notice; however, as to cookies, please see the above clause, “Cookies and other internet tracking technology.”
8.8 We exclude all liability for loss that you may incur when using these third-party websites.
9 Further information
9.1 If you would like any more information, or if you have any comments about this Notice, please either write to us at Data Protection Manager, Integrated Health Partners Limited, 2 Underwood Row, London, N1 7LQ, United Kingdom, or email us at email@example.com.
9.2 Please note that we may have to amend this Notice on occasion—for example, if we change the cookies that we use. If we do that, we will publish the amended version on the Site. In that situation, we will endeavor to alert you to the change, but it is also your responsibility to check regularly to determine whether this Notice has changed.
9.3 You can ask us for a copy of this Notice by writing to the above address or by emailing us at firstname.lastname@example.org. This Notice applies to personal information we hold about individuals; it does not apply to information we hold about companies and other organizations.
9.4 If you would like access to the personal information that we hold about you, you can do so by emailing us at email@example.com or by writing to us at the address noted above. There is not normally a fee for such a request; however if the request is unfounded, repetitive or excessive, we may request a fee or refuse to comply with your request. You can also ask us to send the personal information we hold about you to another controller.
9.5 We aim to keep the personal information we hold about you accurate and up to date. If you tell us that we’re holding any inaccurate or incomplete personal information about you, we will promptly amend, complete or delete it accordingly. Please email us at firstname.lastname@example.org or write to us at the address above to update your personal information. You have the right to complain to the Information Commissioner’s Office if we do not promptly amend, complete or delete inaccurate personal information.
9.6 You can ask us to delete the personal information that we hold about you if we relied on your consent in holding that information or if it is no longer necessary for us to hold it. You can also restrict or object to our processing of your personal information in certain circumstances by emailing us at email@example.com or by writing to us at the address noted above.
9.7 We will tell you if there is a breach, or a likely breach, of your data protection rights.
10.1 In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.