Privacy policy

Last Updated: [3.13.2024]

Overview

This privacy policy describes how TENWAYS TECHNOVATION INC. (“Tenways”, “we”, “our” or “us”) and affiliates handle your personal information as we provide you with our products and services. Please take a moment to familiarize yourself with our privacy protection practices.

The policy covers how we might collect, store, use, and/or share personal information when you interact with us, such as when you:

  • Visit our website
  • Places orders on our websites
  • Download and use our iOS or Android mobile application
  • Use our services and devices, including enabling any functions related to the IoT features
  • Communicate with us by email, text, through online request forms, or any other ways provided by Tenways

This privacy policy excludes information collected through third-party websites, applications, or content, including advertisements, and any third-party’s data processing practices. For any inquiries, please contact us at support@tenways.com.

I. How We Collect Personal Information

1. Information Provided by You

Account Information: For the creation of your account, we ask users to provide us with a name, email address and phone number. Users may choose to provide additional account information including avatar, nick name, region, date of birth, height, weight, and gender.

Order Information: We need certain information to complete when users order products on our platforms. Information required include recipient’s name, shipping address, recipient’s phone number, email address, order item,and billing address.

Payment Information: Payment information including payment method, card type (if paid by card), card number (if paid by card), Affirm account (if paid by affirm) and PayPal account (if paid by PayPal).

Customer Support: If users contact our customer support, we will need the user’s basic information including name, contract information, relevant order ID or service ID. If the communication is related to a certain order, we will need the relevant shipping address, shipping method or tracking ID, the products at issue, and the amount paid. We will also process the content of the communications, including any images, videos, and other information the user chooses to provide.


2. Information Automatically Generated and Collected

Certain information may be automatically generated and/or collected during the provision of our services. 

Device Information: We collect information regarding user’s devices (including mobile devices and computers), including IP address, device model, App version, device resolution, browser, operation system, system language, Google account (if applicable), country, and precise location data.

Bike Information: We collect information on the bicycle including bike ID and the current battery capacity.

Smart connect Module Information: We uses IoT technology for the provision of certain bike features. Information required to perform the function includes bikes’ precise location data, signal information, battery information, flow status, usage record, activation time, and bike status. 


Riding Information: We collect detailed bike ride information, including distance, duration, speed, start and end times, ride frequency, health metrics, and achievements. This data, presented graphically for different time periods, offers insights into user biking behavior, supporting personalized services.


Logs: We process operation information, device information, and riding information as logs.

Order Information: Aside from the information provided by users, we also automatically generate information, including order number and payment method, during the payment process.

Payment Information: Aside from the information provided by users, we also automatically generate information, including the amount paid and currency, during the payment process.

Member Program Information: We collection information to calculate and record member points. Information required includes user ID, email address, activity title, approved points, pending points, order ID, and the time of creation.


3. Cookies and Similar Technologies

We use "cookies" and other technologies such as web beacons. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.


4. Categories of Personal Data Processed (for California Residents)

In such cases where the California Consumer Privacy Act of 2018 (CCPA) and California Privacy Rights Act (CPRA) are applicable to Tenways in accordance with the law, the information and the rights specified in this section are available to users residing in California.

We collected the following categories of personal information from consumers within the last twelve (12) months:

Categories

Information Collected

Identifiers

A user’s real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A user’s name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. 

Protected classification characteristics under California or Federal law. 

A user's age and sex (including gender, gender identity, gender expression.

Commercial Information

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies 

Internet or other similar network activity

A user's search history, information on the user’s interaction with a website, application, or advertisement. 

Geolocation data

Precise geolocation data

Sensory information

Electronic, audio, visual, thermal, or similar information.

Sensitive personal information

A user's precise geolocation and health information. Some personal information included in this category may overlap with other categories. 

 

II. How We Use Your Information

We use information that we collect about you or that you provide to us to present our website and mobile applications, as well as to provide you with our products and services. Specifically:

  • Provision of our Services: such as registering you for a Service, identifying and authenticating you, setting up your bike, connecting your bike and device to the network, operating the device, checking on the status of the bike, recording the usage history of your bike, and allowing any customization settings.
  • Provision of customer support: information required to communicate with you, which includes account information, users’ information, contents of the communication between you and us, and other functions enabling you to provide reviews of our products and feedback.
  • Log reports: include device data, usage history, device settings, crash and error records, abnormal activities records, and account information.
  • Operate, evaluate, and improve our business: including developing software updates, developing new products and services, analyzing our services, aggregating, and anonymizing data, performing data analytics, auditing and other internal functions.
  • Network security: specifically for the prevention, detection, and protection against fraud, abuse, criminal activities, and other abnormal activities；
  • Comply with regulation requirements: enforcement and compliance with legal requirements, for the execution of claims, including relevant industry standards, and our policies.
  • For administrative purposes: including quality assurance purposes and internal training.
  • Marketing and advertising: such as sending promotions and offers on services and products. You may also contact us at support@tenways.com to opt out of marketing.

We may combine information we obtain about you for the purposes described above. We may also use the information we obtain for other purposes for which we provide specific notice at the time of collection or otherwise with consent.


III. How We Share Information

1. With Third-party Service Providers

We may engage selected third-party service providers to support our services. These service providers may only use the data as determined in our agreements with them. Such third party’s use of personal information will be governed by their privacy policies and terms, and we are not responsible for their acts or omissions. 

2. To Comply with Regulations

We may share your personal information in certain circumstances, including:

  • To law enforcement authorities, government or public agencies or officials, regulators, and/or any other person or entity with appropriate legal authority or justification for receipt of such information, if required or permitted to do so by law or legal process.
  • When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
  • When the information is required for the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, or for the enforcement of civil law claims.

3. Business Purposes

We may share your information with our subsidiaries and affiliates for business support, marketing, or other specified purposes that are communicated to you at the time.

4. Transfers

If the ownership of all or substantially all of our company’s business, or individual business units or assets owned by our company that is related to the Services, were to change, or a bankruptcy or other change were to occur, your personal information may be transferred to the new owner or may be shared during such transaction (such as during due diligence) even if such transaction is not completed. In any such transfer of information, the Personal Information will remain subject to this Privacy Policy unless and until changed according to the terms herein.


IV. Security and Data Retention and Security  

We have implemented measures dedicated to keep your information secure and will continue to work on features to keep your information safe. While we strive to employ commercially reasonable means to safeguard personal information, it's essential to acknowledge that no internet transmission or electronic storage method is entirely secure. We cannot guarantee absolute security. If you access our Services via a third-party platform, you should also protect your account with secure account credentials and prevent unauthorized access to your account and personal information.

Subject to the rights of users set forth in this policy, we will retain information for as long as we need it to provide you the Services or to comply with applicable law. When we no longer require your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.


V. Notice for Data Subjects Residing in California  

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights. To exercise any of these rights or to appeal a decision regarding a consumer rights request, please contact support@tenways.com.

Access to Specific Information and Data Portability Rights

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm the verifiable end-user request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or sharing that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclose your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Personal Information Sales Opt-Out Rights

We do not knowingly sell your personal information, yet our use of tracking technologies may be considered a “sale”/ “sharing” under California law. Email us (support@tenways.com) to opt-out of sale on this website, or you can visit our Do Not Sell or Share My Personal Information page.

Limit the Use of Sensitive Personal Data Rights

We do not knowingly collect or use any sensitive personal data. For any inquiries, please contact us at support@tenways.com.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you products or services.
  • Charge you different prices or rates for like-products or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you with a different level or quality of like-products or services.
  • Suggest that you may receive a different price or rate for like-products or services or a different level or quality of like-products or services.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our websites, other products, services, and platforms that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights. To exercise any of these rights, email us at support@tenways.com.


VI. Children's Data Protection

Our services are not intended for children under 16 years of age, and we do not have reasonable grounds to believe that any of our users are children. If we learn that we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@tenways.com.


VII. International Transfer of Data

Your information may be processed where we have facilities or where we have service providers. The data protection rules in these countries may be different from those in the country where you reside. For further inquiries regarding data transfer, please contact us at support@tenways.com.


VIII. Updates to the Privacy Policy

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. The date the privacy policy was last revised is identified at the top of the page.


IX. Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practice, please contact us at support@tenways.com.