17 May

Privacy Statement

Introduction

Updated 16th May 2018
We protect your personal information and data.
We will only use the information that we collect about you lawfully in accordance with the Data Protection Acts, 1988 and 2003 and the EU General Data Protection Regulation (GDPR).

Who we are

The biketowork.ie, travelhub.ie, fithub.ie, biketowork.co.uk and hubex.ie websites and all subdomains are owned by Bike To Work Ltd, Bike to Work Ltd trading as TravelHub and Bike to Work Ltd trading as HubEx respectively. Bike To Work Ltd, Bike to Work Ltd trading as TravelHub, Bike to Work Ltd trading as FitHub and Bike to Work Ltd trading as HubEx, whom we refer to as “Bike to Work Ltd”, “we,” “us,” “our” in this Privacy Statement, is committed to protecting your privacy. Bike To Work Ltd is a company registered in Ireland (company number 464697) with its registered office at 175 Ivy Exchange, Granby Place, Parnell Square West, Dublin 1. 
You can contact us at the above address of by phone to +353 1 514 3520 or email info@hubex.ie

This Privacy Statement

Please note that use of the Website by you and any Services offered by Bike to Work Ltd (such as our customer support phone lines) is subject to this Privacy Statement (the “Privacy Statement“) and to the Website’s terms and conditions of use (“Terms and Conditions“). 
Our Privacy Statement explains what information we collect, how we use and/or share this information, and how such information is maintained. By using this Website or any other Services of Bike to Work Ltd, you signify your acceptance of this Privacy Statement. If you do not agree to the terms of this Privacy Statement, in whole or part, you should not use this Website or services of Bike to Work Ltd. Please note that this Statement applies with respect to the information collected on the Website and through any other contact we have with you.
Our IT Security Policies ensures that any information you provide us remains private and secure. To reassure you, below we provide details of the information you provide to us, and how it will and, more importantly, will not be used. We will never collect sensitive information about you without your explicit consent. The information we hold will be accurate and up to date. You can check the information that we hold about you by contacting us (and there may be an administrative fee payable for this). If you find any inaccuracies we will delete or correct it promptly.

Transactional Use of Data

LEGAL BASIS FOR COLLECTING DATA

We may provide administration services to your employer such as administering the Cycle to Work Scheme or Travel Pass scheme. In this case your employer is the data controller for your data and We are a data processor. We are processing your data on behalf of your employer on the legal basis that you are entering into a contract with your employer in order to process your order. This contract is detailed in the purchase agreement you enter into with your employer. 

DATA COLLECTED

We will collect the following data for Cycle to Work Scheme orders.
  • Name
  • Middle initial
  • Surname
  • Employer Name
  • Work email
  • Work phone
  • Work address
Depending on the settings for your employer we may also collect additional information such as your employee ID or work location. These will be detailed in the user registration or the order submittal forms.
We will collect the following data for TravelPass Scheme orders.
  • Name
  • Middle initial
  • Surname
  • Employer Name
  • Work email
  • Work phone
  • Work address
  • Photo
  • Leap Card public transport integrated ticket ID
Depending on the settings for your employer we may also collect additional information such as your employee ID or work location. These will be detailed in the user registration or the order submittal forms.

TRANSACTIONAL PROCESSING OF DATA

We will process your data as follows:

  • To process your orders and renewal or orders
  • To keep you informed about your order and the renewal of orders
  • In improving and developing this website and Bike to Work Ltd's related websites.
  • To respond to any queries you might have and generally provide customer support to you.
We also always reserve the right to disclose data in order to:
  • comply with applicable laws
  • respond to governmental enquiries; or enquiries from a legal, governmental or quasi-governmental local authority agency, or Internet protection agency
  • comply with a valid legal process or procedure
  • protect our rights or property, this website, and/or other users of this website

TRANSFER OF DATA TO THIRD PARTIES

For Cycle to Work Scheme orders, we may transfer your name and surname to the bike shop along with the details of the quote for the bicycle and accessories that you got from the bike shop.

You may wish to give the shop additional information to allow them to order your bicycle, arrange collection, or as part of any warranty for the goods. You are responsible for transferring this data to the bicycle shop and the bicycle shop will be the controller of this data which will be administered using the bicycle shop's systems.

For Travel Pass tickets we may transfer the following data to the Public Transport Operator in order to process your ticket.

  • Name
  • Middle initial
  • Surname
  • Work email
  • Work phone
  • Work address
  • Photo
  • Leap Card public transport integrated ticket ID

In these cases the Public Transport operator will become a data controller for this data and will administer the data using their systems. You should make contact directly with the operator regarding your individual data rights.

AGREEING TO THIS USE OF DATA

You must agree to this use of your data in order to submit an order by checking the checkbox to agree to this Privacy Statement. If you do not agree we will not be able to accept your order as we require this data in order to process the order.


Marketing Use of Data

We may ask you to consent to allow us to use your data for marketing purposes. You have a choice whether you opt in or now and you do not have to opt in in order to place an order with us. 

If you consent to allow us to use your marketing data we may use the following data:

  • Name
  • Surname
  • Work email
  • Work phone
  • Work address
  • Employer Name
  • Details of the orders you place.

We may use and process the data for the following:

  • To send you news on our services and other related services and services related to the Cycle to Work Scheme and TravelPass scheme.
  • To send you special offers and discounts on bikes, accessories and cycling related products.
  • To let you know about new public transport services or other information on public transport.
  • To analyse trends and carry out research on our orders and in cycling and the use of public transport generally.

We will never sell your data. We will not transfer your data to third parties other than third parties we use to process the data for our use as set out below in the section on third parties.

Third Party Processors

In the section above we have described how we may transfer your data to Bike Shops for Cycle to Work Scheme Orders and Public Transport Operators for Travel Pass Orders as part of fulfilling those orders. These Bike Shops and Public Transport Operators become Data Controllers for that data.

Beyond this, we use may third party Sub-Processors to deliver our services and may securely transfer your data to them. These may include

  • Our software developer
  • Our server hosting company
  • Third party services for delivery of emails such as SendinBlue, Amazon or Google.
  • Outsourced service providers
  • Professional advisers and auditors.

This third party processing is on behalf of us. We will not transfer your data to third parties for their purposes without your explicit consent. We will inform your Employer of our current Sub-Processors and of any proposed additions or changes to them.

Personally Identifiable Information collected while browsing our websites

When using the Website, we may also collect your IP (Internet Protocol). An IP address is a number that is assigned to your computer when you use the Internet. Your IP address is also used to help identify you during a particular session and to gather broad demographic data. 
We use your IP address to:
  • help our website function to process your orders
  • address to help diagnose problems with our server
  • to administer the Website.

Security and retention

The data which we hold, will be held securely within our systems in accordance with our internal security policies and the law. We will hold your data for seven years after you place your last order after which it will be anonymised. 

Cookies and Google Analytics

We use “cookies”, technology to store data in your computer using the functionality of your browser. The information stored in the cookie is used to identify you.
When you first view our website you will get a popup about cookies. At any other time you can click in a Cookies Declaration link in the footer of the website to get information and options for cookies. We will list the different types of cookies we use. Certain cookies are necessary for the proper functioning of the website and cannot be opted out of. Other cookies are optional and you can change your preferences.
Necessary Cookies
We use cookies which enables us to operate an efficient service and to track the patterns of behaviour of visitors to the website. These are necessary and are not optional.
Optional Statistics and Marketing Cookies
We may ask you to accept other cookies to help us understand how visitors use our website, for analytics, to provide instant messaging chat, to help our marketing and to display ads. These cookies are optional.
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) may be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. 
Note that the use of cookies by third party advertisers or ad servers such as Google is not subject to this Privacy Statement, but is subject to their own respective Privacy Statements.

Your Rights

You have the followings rights which can be exercised as follows:

RIGHT TO BE INFORMED
This Privacy Statement informs you about your data.

RIGHT OF ACCESS
In the footer of our websites you can access information on cookies used.

If you login at www.travelhub.ie/login and click My Account you can access the data that we hold on you.

RIGHT OF RECTIFICATION
When you login at www.travelhub.ie/login and click My Account you can immediately edit certain data fields that we hold on you. For other fields we cannot allow you to edit the data immediately as it may be in use for active orders. You can raise a ticket to request a data amendment.

You can also opt-in or opt-out of the use of your data for marketing purposes.

RIGHT OF ERASURE
See the section above on our general data retention policy.

You can request that we erase the data we hold on you by logging in at www.travelhub.ie, clicking My Account and creating a ticket. We are processing the data on behalf of your employer is the data controller. We will discuss your erasure request with them. We will erase or anonymise as much data as possible. We or your employer may need to retain certain amounts of data. For example if an order is processed for a Cycle to Work Scheme bike or Travel Pass ticket you will get tax relief on that order and your employer may need to retain the data for audit purposes. We will communicate the response to your data request to you.

RIGHT TO RESTRICT PROCESSING
We have outlined above what data we require in order to process orders. 

You can login at www.travelhub.ie/login and go to My Account and request that we restrict processing by opting out of consenting to the use of your data for marketing purposes (if you had previously consented).

RIGHT TO DATA PORTABILITY

Orders can only be processed through your employer who is the data controller. Your employer can request copies of the data if required to ensure data portability.

RIGHT TO OBJECT
When we reply to any data rectification request we will inform you about your right to object and include details on how to object.
RIGHTs relating to automated decision making including profiling
We don't have automated decision making processes.

Changes to this Statement

Please note that this Statement forms part of the Terms and Conditions for use of the websites and all associated subdomains and Bike to Work Ltd and associated brands services and forms part of the Agreement between you and Bike to Work Ltd. You can determine with this Statemetn was last revised by referring to the last updated date at the top. We may, from time to time, amend this Statement, in whole or part, in our sole discretion. If we make major changes we will ask you to accept the revised Privacy Statement before you place any new orders.

Revisions


Revised: 16th May 2018: Full update to reflect the GDPR
Revised: 6th October 2016: Reference to Data Protection Act 1998 updated to Data Protection Acts, 1988 and 2003
Published: 4th March 2015