Privacy Policy and Consent

 

1. Objective and responsible body
2. Basic principles and details of data processing
3. Data security
4. Transferring your personal data to other countries
5. User rights
6. Retention of your data
7. Changes to the Privacy Policy
8. Collection of access data (log files)
9. Newsletters and consent
10. Cookies & reach measurement
11. Google Analytics
12. Analytical software Hotjar
13. Google-Re/Marketing-Services
14. Facebook Social Plugins
15. Facebook Remarketing

If you have any questions or concerns about this Privacy Policy or our processing of personal data, please contact us at: legal@scott-sram.com

1. Objective and responsible body

This Privacy Policy sets out the basis on which any personal data that we collect in respect of users via or in connection with our website (www.scott-sram.com) or that you provide to us will be processed by us. The Privacy Policy applies regardless of the domains, systems, platforms, and devices (such as desktop or mobile) used to access the website.

The data controller of personal data collected via the website is Frischi Racing GmbH located at Höhenweg 5, 8714 Feldbach, Switzerland (“we” or “us”). You can email us at legal@scott-sram.com

The terms “user” and “you” covers all customers of and visitors to our website.

2. Basic principles and details of data processing

We process personal data of users in accordance with applicable data protection laws and regulations. This means that the personal data of users is processed only when there is a lawful basis for processing, as follows. Where you place an order for products via the website or make an enquiry with us, the processing is necessary for the performance of that contract or in order to take steps at your request before entering into a contract.

We may also process the data for the purpose of our legitimate interests which may include:

• administering, improving and optimizing our website and internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes);
• ensuring effective customer service and technical support.

Where we have your consent, we may use personal data that has been collected by cookies and we may use your personal data to send marketing communications (such as our newsletter) to you (as applicable depending on the consents you have provided). You may withdraw your consent at any time, but this will not affect the lawfulness of any data processing carried out on the basis of your consent before it was withdrawn.

We are entitled to provide information on the personal data we process, and to provide access to that personal data, to law enforcement or emergency response agencies in accordance with applicable law, and to process data where necessary in order for us to comply with our legal obligations.

When contacting us (for example using a contact form or email), the user’s data is stored for the purposes of processing the inquiry and in the event that questions arise.

Further details about the purposes for which we process your information, how we process your information and who your information is disclosed to are set out below.

3. Data security

We put in place organizational, contractual and technical security measures that correspond to the latest technology, in order to ensure compliance with applicable data protection laws, and to ensure that the data processed by us are protected against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.

4. Transferring your personal data to other countries

We will transfer your personal data to, and store your personal data in the European Union and in Switzerland.  

If you have signed up for our newsletter, we may transfer your personal data to Maropost Inc in Canada, who administers this on our behalf. The European Commission has made a finding of adequacy in respect of Switzerland and Canada, which means that the European Commission is satisfied that these countries ensure an adequate level of protection for personal data.

By submitting your personal data to us and/or using our website, you agree to this transfer, storing and processing.

5. User rights

Upon request, you are entitled to receive information free of charge about your personal data that we process.

You also have the right to require rectification of inaccurate data held about you, request the deletion of your personal data, assert your rights to the portability of your personal data, restrict or object to processing of your data, and file a complaint with the relevant supervisory authority in the event of the suspicion of unlawful data processing.

You may at any time withdraw any consent to processing that you have provided, but this will not affect the lawfulness of any data processing carried out on the basis of your consent before it was withdrawn.

6. Retention of your data

The data stored with us are deleted as soon as they have served their purpose and to the extent that there is no statutory retention requirement.

7. Changes to the Privacy Policy

We reserve the right to change the Privacy Policy in order to adapt it to changes to the law or to changes to the website or our data processing. However, this only applies to declarations concerning data processing. If user consent is required or if the Privacy Policy contains provisions setting out the contractual relationship with the user, then the changes will only be made with the consent of the user.

Users are therefore requested to keep themselves regularly informed about the content, in particular when they provide further personal information.

8. Collection of access data (log files)

We automatically collect information every time you access our website. We collect data on each request for access to the server on which our website is hosted (server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, transmitted data volume, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the site used prior to this visit), IP address and the requesting provider.

We will usually process the log data on an anonymous basis, without reference to other information identifying the relevant user or any other creation of a profile and only for statistical evaluations for the purposes of the operation, security and optimization of our website. However, we reserve the right to check the log data at a later date and to use this data with other information which may identify a user, if we have reasonable grounds to suspect unlawful use or activity.

9. Newsletters and consent

We send newsletters, emails and other electronic notifications with promotional information, which we will collectively refer to as “newsletters”, only with the consent of the recipient. If you subscribe to our newsletters, you agree to receive the newsletters.

In addition, we may ask if you would like to receive emails from our local retailers (for example with information about the sporting goods market, their offers and companies).

We keep a record of registrations for our newsletters in order to demonstrate that the registration process is in accordance with legal requirements. This includes the storage of the login and confirmation time as well as the IP address.

Newsletters are sent by “Maropost,” a marketing platform provided by Maropost Inc., 155 University Ave Suite 1900 Toronto, Ontario M5H 3B7, Canada.

The email addresses of our newsletter recipients, as well as their other data described in this section 9, are stored on the servers of Maropost in Canada. Maropost uses this information to send and evaluate the newsletters on our behalf. In addition, Maropost may use this information to optimize or improve its own services, such as for the technical optimization of the dispatch and the presentation of the newsletters or for financial purposes, in order to determine the recipients’ countries of residence. However, Maropost does not use the data of our newsletter recipients in order to write to them, and it does not forward the data to third parties.

We trust in the reliability as well as the IT and data security of Maropost, and we have concluded a “data processing agreement” with Maropost. This is a contract that obligates Maropost to protect the data of our users, to process it on our behalf according to their data protection obligations and, in particular, not to forward it to third parties. You can view Maropost’s Privacy Policy here: http://www.maropost.com/privacy-policy/

To register for newsletters, all you have to do is provide your email address. We also ask for your first and last name, which is optional. This information is merely for the personalization of the newsletter. We only use this information to adapt the content of newsletters to the interests of our readers.

Statistical survey and analysis – The newsletters contain a “web beacon”, which is a pixel-sized file that is retrieved from the Maropost server when the newsletter is opened. As part of this retrieval, technical information is collected, such as that regarding the browser and your system as well as your IP address and the time of retrieval. This information is collected for the technical improvement of the service on the basis of the technical data or the target groups and their reading behavior on the basis of their retrieval locations (which can be determined using the IP address) or the access times.

Statistical surveys also include determining whether newsletters have been opened, when they are opened and which links are clicked. This information can be assigned to individual newsletter recipients for technical reasons. However, neither we nor Maropost are attempting to observe individual users. The evaluations help us recognize the reading habits of our users and adapt our content to them or to send different content according to their interests.

Online Access and data management – There are cases where we direct newsletter recipients to Maropost websites. For example, our newsletter contains a link with which the newsletter recipients can access newsletters online (for example, in the case of display problems with the email program). In addition, newsletter recipients may subsequently correct their data, such as the email address, on a Marapost website and if a user wishes to view Maropost’s Privacy Policy this is only available on its website.

In this context, please note that Maropost’s websites use cookies, and so if you visit a Marapost website your personal data may be processed by Maropost, its partners and service providers (such as Google Analytics). We have no influence on this data collection. Please refer to Maropost’s Privacy Policy for further information. We would also like to point out the opportunities to raise objections against data collection for advertising purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European area).

Unsubscribing from the newsletter – If you wish to receive the newsletter, your consent to all the processing set out in this section 9 will be required. However, you may unsubscribe from our newsletter at any time, meaning you may revoke your consent, and in such event your consent to receiving the newsletter, having your data sent via Maropost and the statistical analyses, will all simultaneously expire.

You will find a link to unsubscribe from the newsletter at the end of each newsletter. Alternatively, you may contact us at legal@scott-sram.com.

10. Cookies & reach measurement

Cookies are information transmitted by our web server or the web servers of third parties to users’ devices that are stored there for later retrieval. We use these cookies in order to allow you to use certain parts of the website and to track your activities on the website, which helps us to familiarize ourselves with your preferences, to target marketing at you and to improve your use of the website.

We use the following cookies:

• Strictly Necessary Cookies – These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas. Without using these cookies, services you have asked for such as shopping baskets or e-billing cannot be provided.
• Analytical or Performance Cookies – These cookies collect anonymous information on the pages that you have visited. These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, how they move around our website and if they get error messages from webpages. These cookies do not collect data that personally identifies any user. These cookies help us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality Cookies – These cookies remember choices you make to improve your experience. These cookies are used to recognise you when you return to our website. They allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features such as greeting you by name. They can also be used to remember changes you have made to text size, fonts and other parts of our website that you can customise. They may also be used to provide services you have asked us for, such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
• Targeting or Advertising Cookies – These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies record your visit to our website, the pages you have visited and links you have followed. They are used to deliver adverts which are more relevant to you and your interests. These cookies are also placed by third parties (including advertising networks) with our permission. These cookies remember that you have visited our website and the pages you have visited, and this information is shared with other organisations such as advertisers and may be used to deliver adverts to you on third party websites or applications based on your online activity.

In most cases, the use of our website is possible without cookies. However, we would like to point out that if cookies are rejected, then the functionality of the website may be restricted and you may not have access to some features. If users do not want cookies to be stored on their computer, they are requested to disable the corresponding option in their browser settings. Stored cookies can be deleted in the browser settings. Cookies are not used for purposes other than those mentioned on this page.

You can manage many online ad cookies from companies via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/.

11. Google Analytics

To collect “clickstream” data (such as IP address, date and time of the visit, reference URL, the pages visited on our website, and information about the browser being used) we use Google Analytics and Google Optimize, a web analysis service from Google Inc. (“Google”). Google uses cookies, text files that are stored on users’ devices and which allow an analysis of the use of the website. The information generated by the cookie and the use of the website by users are generally transferred to a Google server in the USA and stored there.

Google uses this information on our behalf to evaluate the use of the website by users in order to compile reports on the activities within the website and to provide additional services related to the use of the website as well as Internet usage. Pseudonymous usage profiles of the users can therefore be created from the processed data.

We only use Google Analytics / Optimize with IP anonymization enabled. This means that the IP addresses of the users are abbreviated by Google within the member states of the European Union or in other contracting states of the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the US and abbreviated there.

The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users may also block the collection of data generated by the cookie and related to their use of the website for Google, as well as the processing of such data by Google by downloading and installing the browser plug-in available using the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For further information on Google’s use of the data for advertising purposes, settings and opportunities to raise objections, please refer to Google’s website: https://www.google.com/intl/en/policies/privacy/partners/ (“How Google uses data when you use our partners’ sites or apps”), http://www.google.com/policies/technologies/ads (“Data usage for advertising purposes”), http://www.google.com/settings/ads (“Control the information Google uses to show you ads”) and http://www.google.com/ads/preferences/ (“Make the ads you see more useful to you”).

12. Analytical software Hotjar

To analyse the consumer behavior (such as clicks, taps and scrolling behavior) we use inter alia Hotjar, an analytical software from Hotjar Ltd. (“Hotjar”), Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta. Hotjar uses cookies, tracking codes and text files that are stored on users’ devices and which allow an analysis of the use of the website. The information generated by the tracking code and the cookie about the consumer behavior on the website by users are generally transferred to a Hotjar server in Ireland and stored there.

Hotjar uses this information on our behalf to evaluate the consumer behavior on the website by users in order to compile reports on the activities within the website Pseudonymous usage profiles of the users can therefore be created from the processed data.

We only use Hotjar with IP anonymization enabled. This means that the IP addresses of the users are abbreviated by Hotjar within the member states of the European Union or in other contracting states of the European Economic Area.

The IP address transmitted by the user’s browser is not merged with other data from Hotjar. Users can prevent the storage of cookies by setting their browser software accordingly; users may also block the collection of data generated by the cookie and related to their use of the website for Hotjar, as well as the processing of such data by Hotjar by following up the instructions according to following link https://www.hotjar.com/opt-out. For further information on Hotjar’s use of the data please refer to Hotjar’s website: http://www.hotjar.com.

13. Google Marketing and Remarketing services

We use the marketing and remarketing services (“Google Marketing Services”) of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).

Google Marketing Services allow us to display targeted advertisements for and on our website, in order to show users only those ads that potentially meet their interests. If users are shown ads for products for which they have shown interest on other websites, this is referred to as “remarketing”. For these purposes, when our website and other websites are called up on which Google Marketing Services are active, a code is executed directly by Google, and (re)marketing tags (invisible graphics or code, also known as “web beacons”) are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the device (instead of cookies, comparable technologies can be used). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com and googleadservices.com. In this file it is recorded which web pages the user has visited, the contents in which he/she is interested and the offers he/she has clicked, as well as technical information on the browser and operating system, referring websites, visit time and further information on the use of the online offer. The IP address of the users is also recorded (for further information about the processing of IP addressees by Google, see section 11 above).

User data is pseudonymously processed within the framework of Google Marketing Services. This means that Google does not store and process the names or email addresses of the users, but processes the relevant cookie-related data within pseudonymous user profiles. This means, from Google’s perspective, that the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has explicitly permitted Google to process the data without this pseudonymization. The information collected by “DoubleClick” about users is transmitted to Google and stored on Google’s servers in the USA.

The Google Marketing Services we use include the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Thus cookies cannot be tracked through AdWords customers’ websites. The information collected using the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who have clicked on their ad and have been redirected to a page with a conversion tracking tag. However, they do not receive any information that allows users to be personally identified.

We include third-party advertising via the Google marketing services “DoubleClick” and “AdSense”. DoubleClick and AdSense use cookies that facilitate the display of online ads for Google and its partner websites based on visits from users to the website or other sites.

Another Google Marketing service we use is “Google Tag Manager,” which allows further Google analysis and marketing services to be included in our website (such as “AdWords,” “DoubleClick” or “Google Analytics”).

For more information on Google’s use of data for marketing purposes, see the overview page: https://www.google.com/policies/technologies/ads/, Google’s Privacy Policy is available at https://www.google.com/policies/privacy/.

If you want to opt out of Google Marketing Services, then you can use Google’s set-up and opt-out options: http://www.google.com/ads/preferences/.

14. Facebook Social Plugins

Our website uses social plugins from the social network facebook.com, operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins are recognizable by the Facebook logo (white “f” on a blue tile, the terms “like” or “thumbs up”) or are marked with “Facebook Social Plugin”. The list and the look of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

If a user calls up a function of the website that contains such a plugin, then his/her device establishes a direct connection to Facebook’s servers. The content of the plugin is transmitted directly from Facebook to the user’s device and integrated into the website. We thus have no influence on the extent of the data that are collected by Facebook with the help of this plug-in.

Through the integration of the plugins, Facebook receives the information that a user has accessed our website. If the user is logged in to Facebook, then Facebook can assign the visit to his/her Facebook account. If users interact with the plugins, for example press the Like button or comment, then the corresponding information is sent from their device directly to Facebook and stored there. If a user does not have a Facebook account, it is still possible that Facebook will find and save his/her IP address.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the rights and settings for user privacy protection, can be found in the Facebook privacy notice: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him/her through this website, and to link to his/her member data stored on Facebook, then he/she must log out of Facebook before using our website and delete his/her cookies. Further settings on and objections to the use of data for advertising purposes are possible within Facebook’s profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are independent of the platform, i.e. they are used for all devices, such as desktop computers and mobile devices.

15. Facebook Remarketing

Within our website, “Facebook pixels” of the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are an EU resident, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), are used. The Facebook Pixel enables Facebook to determine the visitors to our website as a target group for the display of ads, referred to as “Facebook Ads”. Accordingly, we use the Facebook Pixel only to display the Facebook ads we have activated to those Facebook users who have also shown an interest in our website. This means that the Facebook Pixel enables us to ensure that our Facebook ads match the users’ potential interests and do not bother them. Moreover, the Facebook Pixel allow us to determine the effectiveness of the Facebook ads for statistical and marketing purposes, since we are able to see whether users were forwarded to our website after clicking a Facebook ad.

The Facebook Pixel is integrated directly by Facebook when our websites are called up, and stores a cookie, i.e. a small file, on your device. If you subsequently log in to Facebook or visit Facebook while logged in, then the visit to our website is marked in your profile. The data collected about you are anonymized, so they do not provide us with any indications about the identity of the users. However, the data is stored and processed by Facebook, thereby enabling a connection to the respective user profile. The data processing by Facebook is implemented within the framework of Facebook’s data usage guidelines. For more information about how the remarketing pixel works, as well as general information on the display of Facebook ads, see the Facebook data usage policy: https://www.facebook.com/policy.php.

You can opt out of the collection of your data by the Facebook Pixel and their use to display Facebook ads. To do this, you can visit the page set up by Facebook and follow the instructions for the settings of usage-based advertising: https://www.facebook.com/settings?tab=ads or opt out via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are independent of the platform, i.e. they are used for all devices, such as desktop computers and mobile devices.

– Privacy Policy and Consent Version 1.0 –