Aventon Privacy Policy

Last updated: October 23, 2024

Ride Aventon, Inc. and its parents, subsidiaries, and affiliated entities (“Aventon”” “we,” “us,” or “our”) respects your privacy and are committed to protecting it through our compliance with this Privacy Policy (the “Policy”). We have created this Policy to inform you of our policies regarding the collection, use and disclosure of Personal Information as well as the rights and choices you have associated with your Personal Information in connection with our websites and the related mobile applications and services.

This Policy applies to Personal Information we collect both from you and from third parties, online and offline, during any written, electronic, and oral communications, including when you:

• Interact with our website located at https://www.aventon.com/, and all corresponding webpages, software applications, or mobile applications (the “Sites”) that link to this Policy;
• Interact with our advertising and applications on third-party websites and services, if the advertising and applications include links to this Policy; or
• Contact us for customer service or provide information via our store locations (collectively, the “Services”).
• By using our Services, you consent to the collection and use of the Personal Information in accordance with this Policy. If you do not feel comfortable with any part of this Policy, you should not use or access our Services. You should also review our Terms of Service (the “Terms”) located here: https://www.aventon.com/pages/terms-of-service, which is incorporated herein by this reference, to understand what you are agreeing to by using our Services.

We may change this Policy to reflect new laws, new services or for other reasons. When we make a change, we will provide you with notice of such updates as required by applicable law, and will revise the date at the top of this Policy. Your continued use of our Sites and Services following the posting of changes to this Policy will be considered your consent to those changes. You are advised to review this Policy periodically for any changes.

We collect Personal Information when you interact with our Sites and Services. For purposes of this Policy, “Personal Information” is any personally identifiable information that is specific to you (e.g. name, address, phone number, email address, etc.). The types of Personal Information we may collect about you include both information you voluntarily provide to us, and information collected automatically through the Sites.

If you buy our products online, register for an online account with us, use our mobile application, sign up for updates and marketing communications from us, participate in our sweepstakes, surveys, programs or events, request specific product customizations from us, submit a product review on our Sites, contact us for customer service, or otherwise interact with us via our online Services, we may collect the following information about you:

• Contact Information, which may include your name, username, postal address, email address and telephone number. We process this information to communicate with you, including about products and services you have ordered, or to send you updates about our products or services that may be of interest.
• Order Information and Account Information, which may include your contact information, payment card information, billing address, shipping address, and the details of the products or services you have ordered, purchased, or requested from us. We process this information to create and manage your account on our Sites (for example to enable you to access, update and save your preferences to the account); fulfill your orders, including product customization requests.
• Communication Information, which you voluntarily provide to us when making inquiries to customer care, comments on our social media, product reviews on our Sites, survey feedback, uploading a picture, activity (including date, time and geo-location information as well as your speed and pace and perceived exertion) or your equipment usage, view others’ activities, or otherwise use the Services. We use this information to respond to any specific queries you may have when you contact customer care, to understand your preferences so that we can provide you with updates about our products, events, or services that may be of interest, provide you with a more tailored shopping experience, to administer sweepstakes and giveaways, or to improve our product offerings and customer experience based on your responses to a survey or product review. Please note that if you communicate with us by phone, subject to applicable laws, we may monitor or record the call to maintain the integrity of your account, provide effective and timely service, and for improvement of our products.
• Connected Devices and Apps, which includes information from devices that you connect to our mobile application such as the Aventon ebike you are using.
• Giveaways or Sweepstakes Information, which may include your contact information and the details of the giveaway or sweepstakes you have voluntarily entered. We process this information so that you can participate in our giveaway or sweepstakes.
• Social Media Information, which may include your social media interactions with us (e.g., if you “like” or “share” or “comment” on something you see on content we post on our social media accounts, usually located on third-party platforms), and any information you actively provide to us for social media marketing purposes. We process this information to interact with you through social media or email; and administer social media marketing initiatives or social media advertising campaigns.
• Information Shared in Public Area, which includes the information you choose to share with other users when you interact in the public areas of our Sites with other users, such as to provide a review of a product. Please note such information may be viewed by all users and may be publicly distributed outside the Sites. If you interact with other users or register through a third-party social media site, your contacts on the third-party social media site may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

When you access or otherwise use our Sites or Services, we may automatically collect certain Personal Information about you, including:

• Usage Data, which may include details of your visits to our Sites, including, but not limited to, traffic data, logs and other communication data and the resources that you access and use on the Services.
• Device Data, which may include information about your device and internet connection, including your IP address, operating system, and browser type, and information about the type of device you are using, mobile ad identifiers, the time and length of your visit, the website that referred you to our Sites, and the subject of the ads you click or scroll over.
• Via Cookies and Other Web-Based Tracking Technology, which may include information about your preferences to make your use of the Sites more productive, via the use of Cookies. (For more information on Cookies, please see Section 2.)
• Geo-Location Data, which may include the precise location of your device or other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”), to customize our Services based on your location, and to provide you with other services such as notifying you of a nearby Aventon store location, or sending you push notifications or to engage in research, product development, analysis, and targeted marketing by email, push notification, online or in-app advertising. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. You can prevent your device from sharing precise location information, including without limitation some or all of the Geo-Location Data, at any time through your device’s operating system settings. We use this information to provide, maintain, monitor, secure, debug, personalize and optimize our online services to and for you; provide you with customer service and technical assistance; and to generally develop and improve our products and services. We also use some of the data that is automatically collected by cookies and related technologies to understand the effectiveness of our ads and social media campaigns.

Please note, you may be able to control the collection of such data through the control settings on your device or browser; but removing the collection of such data may impact the convenience to use or the functionality of the Sites or Services. 

We allow you to create an account and log in to use the Service through the following third-party social media services: Google, Facebook, and X (formally Twitter). If you decide to register through or otherwise grant us access to a third-party social media service, we may collect Personal Information that is already associated with your third-party social media service's account, such as your name, email address, activities, or contact list associated with that account.

When you interact with any of our pages or our account on third-party social media services, we may collect the Personal Information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such Personal Information that we are permitted to collect by those social media platforms. When you access our Sites through social media channels or when you connect the Services to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Policy.

We may use cameras in stores to keep employees and customers safe and to look for ways to improve our customer experience. We do not process the digital image files for biometric information (i.e., identification) purposes, however, we may use the image files recorded when necessary for security reasons or as requested by governmental authorities with a lawful right to review such information.

We use cookies and other similar tracking technologies to collect additional Personal Information automatically as you interact with the Sites and to personalize your experience. Tracking technologies we may use include web beacons, tags, and scripts. Cookies are small web files that a website or its provider transfers to your device’s hard drive through your web browser that enables the website’s or provider’s system to recognize your browser and remember certain information. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted. Certain sections of our Sites, Services and emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

 The cookies used on our Sites and Services may be categorized as:

• Strictly Necessary Cookies, which are needed for the Sites or Services to operate as reasonably expected by you. They enable basic functions like page navigation and access to secure areas of the Sites. The Sites cannot function properly without these cookies. Necessary cookies cannot be disabled.
• Preference Cookies, which remember your name or choices.
• Statistics Cookies, which collect passive information about your use of the Sites or Services. 
• Marketing Cookies, which are used to make advertising messages more relevant and personalized to you based on your inferred interests. We do not sell our marketing data or use cookies to permit third party advertisers to market to users on the Sites. 

We use first-party and third-party cookies for the following purposes to: make our Sites function properly, or to improve our Services; make login to our Sites easier (such as by remembering your user ID); recognize you when you return to our Sites; track your interaction with the Sites or Services; enhance your experience with the Sites and Services; remember information you have already provided; collect information about your activities over time and across third-party websites or other online services in order to deliver content and advertising tailored to your interests; and provide a secure browsing experience during your use of our Sites or Services.

Your Cookie Choices. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. Please remember that cookies are often used to enable and improve certain functions on our Sites. If you choose to switch certain cookies off, it may affect your user experience. 

• Except for Necessary Cookies, you have the right to accept or reject cookies via our cookie pop-up on our Sites and to provide your preferences for what cookies we collect. In addition, you have the ability to control use of cookies through your web browser’s settings for each of your devices with which you access our Sites. Browsers allow you to control cookies through their settings and enable you to review and erase cookies. 

• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third- party advertising networks and similar entities that use these technologies, please see YourAdChoices.
• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage. Flash cookies are not managed by the same browser settings as are used for browser cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (optout.aboutads.info) or the Network Advertising Initiative (optout.networkadvertising.org). In addition, on your iPhone, iPad or Android mobile device, you can change your device settings to control whether you see online interest-based ads.

We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences.

Do Not Track Signals. Currently, we do not monitor or take any action with respect to Do Not Track signals or other mechanisms, which means that we collect information about your online activity both while you are using the Sites and Services and after you leave our Sites and Services.

Analytics. We may use third-party providers like Google Analytics to monitor and analyze the use of our Sites. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Sites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout .  For more information on the privacy practices of Google, please visit the

Google Privacy & Terms web page: https://policies.google.com/privacy.

Behavioral Remarketing. We use remarketing services to advertise to you after you have accessed or viewed our Sites or Services. We and our third-party vendors use cookies and non-cookie technologies to help us recognize your device and understand how you use our Sites and Services so that we can improve our Sites and Services to reflect your interests and serve you advertisements that are likely to be of more interest to you. These third-party vendors collect, store, use, process and transfer information about your activity on our Sites and Services in accordance with their privacy policies and to enable us to:

• Measure and analyze traffic and browsing activity on our Sites and Services;
• Show advertisements for our products and services to you on third-party websites or apps; and
• Measure and analyze the performance of our advertising campaigns.

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use third- party tools to decline the collection and use of information for the purpose of serving You interest-based advertising, for example:

• The NAI's opt-out platform: see http://www.networkadvertising.org/choices/ 
• The EDAA's opt-out platform: see http://www.youronlinechoices.com/
• The DAA's opt-out platform: see http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on our Sites and Services with these third-party vendors. This allows our third-party vendors to recognize and deliver you ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the privacy policy of each vendor listed below. The third-party vendors we use are:

• Google Ads (AdWords). 
• Bing Ads Remarketing. 
• X (formally Twitter). 
• Facebook.  

• Pinterest. 
• Criteo. 

We may use Personal Information for the following purposes:

• To better serve you. The Personal Information we collect helps us to better understand and serve our customers.
• To fulfill your orders. The Personal Information we collect allows us to fulfill your online or in-store order.
• To enhance our Services. The Personal Information we collect allows us to provide programs and program benefits, verify your participation, track orders placed, respond to your inquiries, and to keep records of our interactions.
• To send you marketing materials and promotional offerings from us and third party partners. The Personal Information we collect may also be used to tailor your experience on our Sites or otherwise customize what you see when you visit and use the Sites.
• To provide notice of updates. The Personal Information we collect may also be used to advise you regarding the administration of any features or functions of the Sites and/or Services you have registered to use, and to provide you with notices about your account, including expiration and renewal notices.
• To record your activities. For example, our mobile application collects information about your trips, such as the distance rode, time riding, average speed, and elevation information.
• For research purposes. The Personal Information we collect may also be used to conduct research and analysis and measure the effectiveness of our Services and our offline and online marketing programs. This may be from information that we combine from other sources.
• To administer contests, sweepstakes, promotions and surveys. We may use your Personal Information if you enter into any contests or sweepstakes which we or a third-party vendor might advertise, or if you accept one of our promotional offers or discounts, or if you respond to a survey from us or a third party.
• To ensure your compliance with our Terms and other agreements. We process your Personal Information to enforce our rights arising from any contracts entered into between you and us, including for billing and collection. 
• To prevent, investigate, and provide notice of fraud and or unlawful or criminal activity. We may use your Personal Information to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
• To comply with legal process and our legal obligations. We may use your Personal Information to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We may share your Personal Information in the following ways:

• Service Providers. We may share your Personal Information with third party service providers to monitor and analyze the use of our Sites and Services, to advertise on third party websites to you after you visited our Site, or to contact you.
• Payment Processors. We may provide paid products and/or services within the Services. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their privacy policy. Our payment processors are listed below. 
• Stripe. 
• PayPal. 
• Shop Pay: 
• Google Pay: 

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• Merger, Sale, or Other Asset Transfers. We may share or disclose or otherwise transfer your Personal Information to the our professional advisors such as attorneys or accountants (“Outside Professionals”), other advisors, potential transactional partners, or other third-parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
• As Required By Law, Subpoena or Similar Government Order. We may access, preserve, share, or disclose your Personal Information if we believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any of our tax reporting requirements; (ii) comply with any other law enforcement requests or legal process, such as a court order or subpoena; (iii) respond to your requests; or (iv) protect your, our, or others’ rights, property, or safety. We may be required to disclose your information to (a) taxing authorities as part of our tax reporting requirements, or (b) law enforcement authorities or other governmental agencies or via subpoena.
• Our Outside Professional Advisors. We may share or disclose your Personal Information with any of our Outside Professionals to facilitate the professional advice from those Outside Professionals.

Depending on where you reside, you may have certain rights as to your Personal Information. For example, in the United States there are several states (e.g., California, under the California Consumer Privacy Act (“CCPA”) and other states similar data protection laws), you have right to request certain actions, including:

• Delete: The right to ask us to delete your Personal Information. We will retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. Please note that such a request may mean that we treat some of your Personal Information as necessary for us to retain as noted below. If we are able to fulfill your request, you should be aware that deletion of your Personal Information may affect your right to use our Sites and the Services. While we use reasonable efforts to fulfill your request to delete your Personal Information, we may be required to retain such Personal Information as required by our systems or our legal requirements. Until we have deleted all of your Personal Information, we will continue to honor our privacy and security obligations related to your Personal Information and we will treat such request as a limitation of use request so that any Personal Information retained is used only as we require for our lawful purposes..
• Know: The right to request what Personal Information we have from you and from which sources we have collected such information.
• Correct: The right to request that we correct Personal Information you have which may be incorrect.
• Limit: The right to request that we use Personal Information only for limited purposes. For example, you may elect to opt out of our right to use for marketing purposes. See also the Marketing Communications below.
• Transfer: The right to request that we provide you with an electronic copy of your Personal Information.

Up receipt of a request, we will confirm that the requestor is the lawful owner of the Personal Information and also that the request conforms the applicable laws for the request and we will inform you of our determination and if we are fulfilling your request or if we are unable to honor your request as why we have made such a decision. Any such request should be sent to us using the Contact Us section below.

Please note that in the event we elect to de-identify your Personal Information, such de-identified information is no longer your Personal Information, and we may use such de-identified information, alone or in an aggregated basis to analyze our Sites and Services, or as we deem appropriate.

The security of your Personal Information is important to us, which is why we maintain appropriate administrative, technical and physical safeguards designed to protect your information’s security, confidentiality and integrity.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Sites like message boards. The information you share in public areas may be viewed by any user of the Sites.

Unfortunately, the transmission of information via the Internet is not completely secure and no website, database, or system is completely secure or “hacker proof.” Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Sites or the Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites or Services.

You may choose to provide us with your email address to allow us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications. If you sign up to receive text messages from us that contains promotional information, you can opt-out of receiving future messages by replying “STOP.”

Users from the EEA, the UK, Switzerland or Canada will, if required by applicable law, receive such communications only after having consented hereto. Please note that “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to this Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to unsubscribe will not be retrieved or rescinded, unless required by applicable law.

In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C. § 6501.06 and 16 C.F.R. §§ 312.1 – 312.12, we do not knowingly collect information from children under the age of 13, nor does our Site target children under the age of 13. By using our Sites or Services, you represent that you are not younger than 13. . If you believe a child under the age of 13 has been using our Sites or Services, you may contact us at the email noted in the “Contact Us” section below and we will work promptly remove the data from our system.

Please note that our Sites may contain links to third-party websites, such as delivery services and social media pages. These links are intended for your convenience only. These third-party websites and services are not related to Aventon and may have separate privacy policies and data collection practices. We have no responsibility for the

third-party websites or their privacy practices and encourage you to read the privacy policies of all websites you visit.

14. Specific Laws.  

Depending on where you are located, we will comply will all local laws.

United States Residents

The following additional terms may apply to you depending on where you reside in the United States. In addition to the rights you have noted under “Your Rights” section, those states with data protection laws (e.g., California, Colorado, Connecticut, Virginia, and Utah) require that we identify the categories of Personal Information we have collected or disclosed about you in the last twelve (12) months, the categories of sources for such information, and the categories of third parties with whom we have shared such information. 

For more information about the Personal Information we collect, how we collect it, and the categories of sources for such information please refer to Sections 1-6 above and to review the categories of third parties with whom we may share your Personal Information, please refer to Section 8, above.

For Residents in California

If you are a California resident (as defined by the California Consumer Privacy Act), you may have certain rights.

This Notice for California Residents supplements the information in our Policy, and except as provided herein, applies solely to California residents (as defined by the California Consumer Privacy Act (CCPA) and amended by the Consumer Privacy Act Regulations (CPRA)). It may apply to Personal Information (as defined by CCPA / CPRA) we collect on or through the Sites or Services and through other means (such as information collected offline, in person, and over the telephone). Until the CCPA / CPRA has specifically regulated business information, this notice for California residents does not apply to business information that does not constitute Personal Information. See Your Rights section above.

“Shine the Light” Requests. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please contact us here https://www.aventon.com/pages/contact. Please include the words “Shine the Light” in the subject line of the request, and state the name of our specific website with respect to which you are requesting the information, as well as your name, street address, city, state, and zip code.

Metrics. California law may require us to compile the following metrics for the previous calendar year; the number of rights requests received, complied with, denied, as well as the median number of days within which we responded to those requests. To the extent this obligation applies to us, we will update this section. 

California Do-Not-Track Disclosure.  We are committed to providing you with meaningful choices about the information we collected on our Sites and Services for third-party purposes. However, we do not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations, and solutions. 

Notice of Financial Incentive.  You may have the right to receive information about the financial incentives that we offer to you, if any. In certain cases, we may offer a gift card, coupon, discount, points towards a future purchase, or other financial incentive in exchange for your participation in our loyalty program, or for other reasons, such as in response to a survey that seeks feedback, or for providing information about your shopping behaviors.

Information We Collect for the Loyalty Program. When you create your account and opt-in to the loyalty program, you will be asked to provide the following information: first and last name, email address, and will be asked to create a password. Once you have created your account, you may also save your address. You may also opt to provide your data of birth to receive an extra reward, but this is not mandatory.

Opt-In to Receive Rewards. You may opt-in to receive the benefits of the loyalty program by signing up online or through the Services. If you do not want to receive the financial incentive, you may elect to not participate. We reserve the right to change or modify the loyalty program at any time.

Opt-Out. You may opt-out of the loyalty program and delete your account by contacting us here: https://www.aventon.com/pages/contact with your request.

For Residents of Illinois 

Residents of Illinois may have certain rights under the Biometric Information Privacy Act. Please note that while we may record customer service calls and/or training videos and use in-store cameras; we do not digitally analyze any such data for any biometric identification purposes.

For Residents of Nevada

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a person to be contacted either physically or online. We do not engage in such activity.

European Union/European Economic Area

If you reside in the European Union/European Economic Area (EU/EEA), the EU/EEA’s General Data Protection Regulation (GDPR) governs our processing (as defined under GDPR) of your personal data, as well as your rights regarding the same. See the Your Rights section above. You have the right to lodge a complaint with the ICO if you consider that the processing of your personal data infringes the GDPR. If you wish to exercise this right, please contact us. You may also contact us using the contact information provided in our Policy. We have the right to refuse your request where there is a basis to do so in law, or if your request is manifestly unfounded or excessive.

Special Categories of Personal Data

Our Sites and Services do not require the collection or processing of any sensitive personal data or sensitive information, as defined in applicable data protection laws (e.g., racial, ethnic origin, political opinions, religious beliefs, etc.).  We may nevertheless collect such sensitive personal data about you, or we may collect it incidentally if you provide such data to us. By providing any sensitive personal data or by providing information by a recording, you consent to our collection of such information, however, we do not require or use such data to provide our Sites or Services. 

International Transfers of Data

Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction. If you are located outside the United States, please note that we transfer the data, including personal data, to the United States and process it there. We adhere to the GDPR where it applies to our Sites or Services. Where your personal data is processed outside of the EEA, we will put in place appropriate safeguards.  Where appropriate, we may enter into Standard Contractual Clauses with importers or processors and/or other relevant third parties for the transfer of your personal data and may carry out a risk assessment and/or take necessary security measures in order to fulfill our obligations under GDPR. If we determine we are unable to provide equivalent protection of your personal data, including by entry into the Standard Contractual Clauses, we may seek to rely on derogations authorized by the GDPR, including the derogation of consent/contract/request of data subject. If relying on your consent, we will seek your explicit consent in advance.

United Kingdom

If you reside in the United Kingdom (UK), the UK’s General Data Protection Regulation (UK GDPR) governs our processing (as defined therein) of your personal data, as well as your rights regarding the same. See the Your Rights section above. You have the right to lodge a complaint with the ICO if you consider that the processing of your personal data infringes the UK GDPR. If you wish to exercise this right, please contact us. You may also contact us using the contact information provided in our Policy. We have the right to refuse your request where there is a basis to do so in law, or if your request is manifestly unfounded or excessive.

Lawful Basis for our Processing of Your Personal Data.

Because we are a data controller, we are the ones who are responsible for establishing a lawful basis for the processing of your personal data. We rely on our legitimate interests under UK GDPR Article 6 in order to engage in the processing of your personal data. This means that we have a legitimate interest in receiving and processing your personal data in order to provide the Sites and Services. We might in some cases also rely on obtaining your consent under UK GDPR Article 6 as the lawful basis of our processing of your personal data. If so, this means that we have requested your explicit consent (or “opt-in”) to their processing of your data. If applicable, you will be provided with our Consent and/or Lawful Basis to Collection and Processing of personal data notice.

Data Protection Officer.

Aventon has appointed a Data Protection Officer (DPO). 

Special Categories of Personal Data

Our Sites and Services do not require the collection or processing of any sensitive personal data or sensitive information, as defined in applicable data protection laws (e.g., racial, ethnical origin, political opinions, religious beliefs, etc.).  We may nevertheless collect such sensitive personal data about you, or we may collect it incidentally if you provide such data to us. By providing any sensitive information or by providing information by recording, you consent to our collection of such information and our use and disclosure of it in accordance with our Policy for purposes directly related to the reason it was provided.

International Transfers of Data

Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction. If you are located outside the United States, please note that we transfer the data, including personal data, to the United States and process it there. We adhere to the UK GDPR where it applies to our Sites and Services. Where your data is processed outside of the UK, we have put in place appropriate safeguards.  Where appropriate, we may enter into the UK Addendum to the Standard Contractual Clauses with an importer or processor and/or other relevant third parties for the transfer of your personal data and may carry out a risk assessment and/or take necessary security measures in order to fulfill our obligations under the UK GDPR.

If we determine we are unable to provide equivalent protection of your personal data, including by entry into the UK Addendum to the Standard Contractual Clauses, we may seek to rely on derogations authorized by the UK GDPR, including the derogation of consent/contract/request of data subject. If relying on your consent, we will seek your explicit consent in advance.

Canada

At the Canadian federal level, the Personal Information Protection and Electronic Documents Act (PIPEDA) establishes a framework for the collection and use of your Personal Information across Canada (e.g., if you are a candidate for employment of an organization that is a federally regulated work, undertaking, or business (e.g., Canadian bank, airline, broadcaster, etc.)). PIPEDA may not apply to Personal Information about you for use of our Sites or Services.

If PIPEDA does not apply, Canadian provincial privacy laws may still apply. We will comply with any such specific provincial privacy laws that apply to our Sites and Services.  For example, Alberta, British Columbia, and Quebec may have provincial privacy laws that apply to your Personal Information.

Consent

Depending on the applicable data protection laws, we may need to obtain your consent for the collection, use, or disclosure of your Personal Information. In Canada, your consent is only valid if it is reasonable to believe that you understand the nature, purpose, and consequences of the collection, use, or disclosure of your Personal Information. You may withdraw your consent at any time.

At the time of obtaining your consent, we must provide you with the following:

• An exhaustive list of types of Personal Information being collected and processed
• A list of third parties with whom it is being shared (including the countries for such parties if outside Canada)
• A stated commitment to handling your personal information according to our Policy, and provide a link to that policy
• An explanation of the risk of harm and other potential consequences in using our Sites and Services
• A “No, I do not consent” button or similar option and explain to you the consequences of withholding your consent, and
• A statement of the possibility for you to withdraw your consent after providing it.

If applicable, you will be provided with our Consent and/or Lawful Basis to Collection and Processing of Personal Data notice.

Opting Out of Email Communications

Canada’s Anti-Spam Legislation (CASL) requires your consent on an opt-in basis in order for us to communicate with you by email. If you elect to provide us with an email address, we will treat such provision as your consent to opt-in to our use of email as a communication means. If applicable, you will be provided with our Consent and/or Lawful Basis to Collection and Processing of Personal Data notice. You may opt-out of email communication at any time.

If you have any questions about how we maintain your personal information, or any other questions regarding your privacy or this Policy, you can contact us: via our website: https://www.aventon.com/pages/contact; by phone: (866) 300-3311; or by email: legal@aventon.com.