Preamble

At Paddle Wheel Adventures Ltd (PWA), the last thing we want you to be worried about is how your personal data is handled. Rest assured, we take your privacy seriously. We utilize best practices from privacy authorities worldwide, only collect the information we need, and never unnecessarily share anything with anyone else. We wrote this policy with the intent that it would be accessible and informative to everyone, but if you still have any questions about it (or see something we might have missed!), please do not hesitate to contact us and let us know so we can rectify it as soon as possible.

Scope

The privacy notice explains how PWA collects, uses, discloses, retains, and secures your personal data as part of our business practices. The notice outlines the legal justifications for the processing of your personal data and lists your privacy rights under the Cayman Islands’ Data Protection Act (2021 Revision) (“DPA”).

Overview

You can trust that your personal data will be processed in accordance with the DPA. Below are the privacy principles PWA applies when processing your personal data:

  1. Lawfulness: PWA will only collect your personal data in a fair, lawful, and transparent manner.
  2. Purpose limitation: PWA will only collect your personal data for specified, explicit, and legitimate purposes.
  3. Data minimisation: PWA will limit the collection of your personal data to what is directly relevant and necessary for the services provided.
  4. Accuracy: PWA will keep your personal data accurate and up to date while there continues to be a customer relationship and in certain circumstances after that relationship has ended.
  5. Retention limitation: PWA will retain your personal data in a manner consistent with the DPA and no longer than is necessary for the purposes for which it has been collected.
  6. Access and rectification: PWA will process your personal data in line with your legal rights under the DPA.
  7. Data security: PWA has implemented technical and organisational measures to ensure an appropriate level of data security considering the sensitivity of the personal data we process. Such measures provide for the prevention of any unauthorized or unlawful processing of your personal data and against accidental loss or destruction of or damage to that data.
  8. Protection for international transfers: PWA will ensure that if your personal data is transferred outside the Cayman Islands, it is adequately protected.

What personal data does PWA collect?

PWA collects various personal data about you, which may include the following (this list is not exhaustive):

  • name and address
  • telephone number
  • email address
  • payment information such as credit card numbers or certain banking information
  • details of past purchases and the products we have serviced for you
  • data voluntarily provided to PWA by you on social media or messaging platforms such as Facebook, Instagram, or WhatsApp

How does PWA use the personal data it collects?

PWA may use your personal data to (this list is not exhaustive):

  • respond to your inquiries
  • manage our business relationship with you
  • send invoices and collect payment for goods or services rendered
  • provide warranty services
  • conduct promotional activities
  • conduct surveys
  • market goods and services
  • engage with you on social media platforms
  • handle your complaints
  • prevent fraud or other criminal activity

When does PWA disclose your personal data?

PWA may disclose your personal data in the following circumstances (this list is not exhaustive):

  • on social media where you may have already made the personal data public
  • if PWA uses a third-party service provider for marketing, marketing research, or client relationship management
  • if PWA uses a third-party service provider for retail, service, warranty, or other business transactions
  • if you request that your personal data be disclosed to a third party
  • to a third party that PWA partners with for special events so that the third party might contact attendees for marketing purposes
  • if there is a valid legal request or criminal investigation
  • if it is required to seek legal advice from PWA legal counsel
  • any other circumstance where it may be required by law

International transfer of personal data

PWA uses the following international business platforms to ensure our business runs smoothly and that you as the customer have the best consumer experience possible:

  • Lightspeed POS USA Inc. (this is where we keep track of inventory, your past purchases, bicycle servicing requests etc.)
  • Automattic Inc. (WooCommerce is a subsidiary of Automattic, and we use their technology for online sales transactions. WordPress is also a subsidiary of Automattic, and we use their technology to run our website.)

If you do business with us by other means than just paying for an item in cash then it is likely that some limited amounts of your personal data will be held, for directly related business purposes, in the databases of these companies.

These companies are signatories to the United States Privacy Shield Framework. Privacy Shield was designed to provide privacy protections for personal data reasonably similar to those found in the European Union, which we have evaluated as reasonable considering the sensitivity of the information we collect.

More details on these companies and Privacy Shield can be found using these links:

  • https://www.privacyshield.gov/participant?id=a2zt0000000TSiLAAW&status=Active
  • https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active

Their own privacy policies and data processing policies can be found at these links:

  • https://pdf.lightspeedhq.com/privacy/PrivacyPolicy_EN.pdf
  • https://pdf.lightspeedhq.com/privacy/DPA_EN.pdf
  • https://automattic.com/privacy/

For purchasing and warranty purposes, limited amounts of your personal data may be transferred outside of the Cayman Islands to Specialized Bicycle Components (USA/Uruguay), Shimano (USA), SRAM (USA), Tern (USA/EU), Unagi (USA), Quality Bike Parts (USA), Bicycle Technologies International (USA), iGo (Canada) and Bosch (EU).

PWA has minimal control of personal data you might send outside the Cayman Islands on various media platforms related to PWA, such as our Facebook or Instagram sites, so we would encourage you to familiarize yourself with the privacy policies of those companies before sharing your personal data on those platforms.

The legal basis for processing your personal data

The DPA sets out some different reasons for which a company may process personal data, and PWA does so under the following legal conditions:

  • Consent
    In specific situations, PWA may collect and process your personal data with your consent. For example, if you provide us with your email address or phone number so we can contact you about the availability of a bicycle you wish to purchase.
  • Contractual obligations
    In certain circumstances, PWA may need to process specific personal data to comply with contractual obligations. For example, PWA will process your personal information to process a warranty claim for an item you purchased from us.
  • Legal obligations
    If the law requires, PWA may need to process your personal data. For example, PWA may be required to disclose your personal information if there is a legal request or law enforcement investigation. As well, certain amounts of personal data are also legally required to be processed for purchases made online or via debit or credit card.
  • Legitimate interest
    In specific situations, PWA may process your personal data to pursue its legitimate interests in a way that might reasonably be expected as part of running its businesses and which does not materially impact your rights, freedom, or interests. For example, PWA may send you information on discounts or special events using the contact
    information you provided to us as part of a previous business transaction.

How long does PWA retain your personal data?

PWA retains your personal data for as long as a customer relationship exists, and the personal data is necessary to manage that relationship. When there is no longer a customer relationship, PWA will retain certain types of personal data for varying periods depending on legal requirements and business needs. Personal data that is no longer needed will be securely destroyed.

How does PWA secure your personal data?

No computer system or database can be made 100% secure, but we do our best to make sure your information is safe. We have analyzed the risks to your data based on the sensitivity of the personal data we collect and the likelihood of intrusion, unlawful processing, or loss. Based on that analysis, we have taken reasonably necessary steps to mitigate those risks adequately.

PWA employs appropriate technical and organizational measures to protect against unauthorized processing, accidental loss, or destruction of, or damage to, your personal data. As examples, we use individual passwords for our customer database, a secure WiFi signal, and Hypertext Transfer Protocol Secure on our website.

We also ensure that all of our international business partners have policies and procedures in place to protect your personal data to the same or higher standard than what you are legally afforded here in the Cayman Islands.

We have a privacy expert on our business team and can assure you that you are receiving services from us that meet or exceed the privacy standards required in the DPA.

What rights do you have with respect to your personal data?

You have a right to be informed of how your personal data is processed, and this privacy notice fulfills PWA’s obligation in that respect. If you have further questions or concerns not addressed in the notice, you may contact us at hello@paddlewheel.ky.

You have a right to request access to your personal data, the right to request rectification/correction of your personal data, the right to request that processing of your personal data be stopped or restricted, and the right to require PWA to cease processing your personal data for direct marketing purposes. If you wish to exercise any of these rights, you should contact us at hello@paddlewheel.ky.

If you feel that your personal data has not been handled correctly, or you are not satisfied with PWA’s responses to any requests you have made to PWA regarding the use of your personal data, you have the right to complain to the Cayman Islands’ Ombudsman. The Ombudsman can be contacted by calling: 1-345-946-6283 or by email at info@ombudsman.ky.