PRIVACY POLICY

Effective date: February 8, 2024

INTRODUCTION

Alta Cycling Group, LLC and its affiliates and subsidiaries (Alta Cycling Group, “Company”, “us”, “our” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy (“Privacy Policy”).

This Privacy Policy describes the personal information Alta Cycling Group collects about you, and how we use and share that information. This policy applies to personal information we collect when you sign up for Alta Cycling Group; access or use our website, products, or services (collectively, the “Services”); when you otherwise interact with us, including through email, text and other electronic messages, including if you contact us by telephone, email or otherwise. This Privacy Policy does not apply to products and services that reference and link to separate privacy policies..

This Privacy Policy refers to personal information which is information that can be used to identify you as a natural person, directly or indirectly, in particular in combination with other information available to us such as an identification number, online identifier or one or more factors specific to your identity as a natural person. Personal information does not include information that has been anonymized so that it does not identify a specific user, which may be used for any legal purpose.

This Privacy Policy covers the following topics:

• Updates to the Privacy Policy
• Categories of Personal Information Collected
• Sources of Information About You
• Our Use of Information
• Sharing of Information
• Your Rights
• Links to Other Websites
• Children’s Privacy
• Security
• Contact Information
• Supplemental Notices

Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy.

UPDATES TO THE PRIVACY POLICY

We may update, amend, revise or otherwise change this Privacy Policy from time to time. If we make changes, we will notify you by posting the updated policy and revising the “Effective Date” above. Your continued use of the Services constitutes your acceptance of the then-effective Privacy Policy.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Updated date of this Privacy Policy) the categories of personal information listed below. Not all categories will be collected or received for every individual.

• Identifiers: Personal identifiers, such as name, telephone number, physical address, email address, national identification numbers, driver’s license numbers, and signatures
• Device Information and Online Activity: Device and online identifiers, keystroke patterns indicative of human or bot website/app usage, mobile and web network activity and related information (such as Mac address, IP address, cookie IDs, browser activity, and other information associated with your browsing history), and social media information
• Commercial Information: Purchase and transaction history information (such as products or services you have purchased, rented, or returned), health and safety-related information, product testimonials, travel and vacation information, and competition entries
• Communications: Communication details (such as the content of emails, text messages, or other communications), call logs, and calendar information where Walmart is a party to the exchange
• Demographic Information: Demographic information, such as age, gender, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information, family health, number of children, number of cars owned, and software or virtual assets owned
• Financial Information: Financial information, such as credit or debit card numbers, financial account numbers, and claims information
• Biometric Information: Biometric information, such as voice prints, imagery of the iris or retina, face geometry, and palm prints or fingerprints
• Geolocation: Location information, such as geolocation information
• Sensory Information: Audio, visual information, and other sensory information such as photographs and audio and video recordings
• Background Information: Background and criminal information, such as background checks and criminal convictions
• Inferences: Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors, intelligence, and aptitudes
• Sensitive Personal Information: Government-issued identifiers (such as social security, driver’s license, state identification card, or passport number), account log-in and financial information (such as payment card details), and precise geolocation

SOURCES OF INFORMATION ABOUT YOU

We obtain information about you from a variety of sources, including you, your interaction with Alta Cycling Group, and third parties.

Information you provide to us: If you use certain Services, you may be required to provide us certain information, including, without limitation:

• contact information (e.g. name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
• biographical and demographic information (not related in any case to racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership);
• purchase and customer service history;
• financial information (e.g. payment information, including name, billing address and payment card details (e.g. card number, expiration date and security code); bank account information; financial statements; income; and credit score);
• location data (e.g. data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
• contact information you provide about friends or other people you would like us to contact;
• clickstream data and other information about your online activities (e.g. information about your devices, browsing actions and usage patterns), including across the Services and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies (see further below); and
• other personal information contained in content you submit to us (e.g. through our “Contact Us” feature).

Information we collect from Other Sources:

We and third parties may collect your usage information about how you use the Services and may combine information we collect from you over time and across the Services with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you, including, without limitation, your access times, location, browser types and language, and Internet Protocol addresses. We may collect device-specific information when you access our Services, including, without limitation, your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device's interaction with our Services.

The technologies we use for this automatic data collection may include cookies, web beacons, and other tracking technologies. Brief descriptions of common tracking technologies are provided below:

• Cookies: A cookie is a small text file that is stored on your computer’s hard drive or stored temporarily in your computer’s memory. There are two kinds of cookies: those that are “session” oriented and those that are “persistent.” Session cookies make it easier for you to navigate the Services and expire when you close your browser. Persistent cookies remain longer and help in understanding how you use the Services and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. Most web browsers accept cookies automatically. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result, some features and functionalities of the Services may not work. Please see “Your Rights” below for information on your choices related to tracking technologies.
• Web Beacons: Our web pages may contain a small graphic image called a web beacon, which is sometimes also called a “clear gif,” that allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small or invisible to the user, but, in general, any electronic image viewed as part of a web page can act as a web beacon. We may use web beacons to count visitors to our web pages or to monitor how our users navigate the Services. We may use web beacons to compile aggregate statistics about the Services.

OUR USE OF INFORMATION

We use information about you to provide, maintain, personalize and improve our Services and to deliver the information and support your requests, including receipts, technical notices, security alerts, and support and administrative messages.

We may use information we collect to send you news and information about our Services and to communicate with you about products, services, contests, promotions, incentives, and rewards offered by us and select partners. You may opt out of receiving promotional emails or text messages from Alta Cycling Group by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

We may also use information about you to:

• communicate about and administer our products, services, events, programs and promotions (e.g. by sending alerts, promotional materials, newsletters and other marketing communications);
• perform data analytics (e.g. market research, trend analysis, financial analysis and customer segmentation);
• engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
• process, evaluate and respond to requests, inquiries and applications;
• create, administer and communicate with you about your account (including any purchases and payments);
• conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• operate, evaluate and improve our business (e.g. by administering, enhancing and improving our products and services; developing new products, services and the Services; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
• verify your identity and endeavor to protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
• conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Services terms of use); and maintain and enhance the safety and security of our products, services, the Services, network services, information resources and employees;
• for other reasons that (a) we disclose when asking you to provide your information, (b) with your consent, or (c) as described in this Privacy Policy.

We may combine personal information we obtain through the Services with information we obtain through other channels only for the purposes described above, or as described upon collection through such other channels. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes than those identified at the time of collection, provided that such other purposes remain compatible with the initial purposes. In any case, we will inform you of such additional purposes and, to the extent required by law, will seek your prior consent.

We may use third-party service providers to process and store personal information in the United States and other countries.

SHARING OF INFORMATION

We may share personal information about you as follows:

• To our subsidiaries and affiliates;
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal; information confidential and use it only for the purposes for which we disclose it to them;
• To comply with any court order, law or legal process, including to respond to any government or regulatory request;
• To enforce or apply our terms of service, available at Terms & Conditions, and other agreements, including for billing and collection purpose;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Alta Cycling Group, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• To fulfill the purpose for which you provide it;
• With third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services;
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by another company
• For any lawful purpose, including, without limitation, selling your data to third parties; and
• With your consent or direction.

We may also share non-personally identifiable information (aggregated or otherwise) with third parties for any reason.

Your rights

Subject to applicable legal requirements, you may have the right to access, obtain a copy, review, correct and update all your personal information stored by us, notably to confirm its accuracy. Subject to any relevant legal requirements and exemptions, you may also request to oppose to or limit the processing or your personal information or request that certain of your personal information be deleted from our files and/or also exercise your right to portability of your personal information. Please note that such a request could be limited to the sole personal information you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.

We will make reasonable efforts to comply with the aforementioned requests, unless such requests are prohibited by law, or there is a legitimate purpose to retain your personal information, in which case we will inform you without undue delay. We reserve the right to verify your identity before any request relating to your personal information processed by us.

To stop receiving marketing email communications from us, click on the "unsubscribe" link in the footer of the email or email info@altacycling.com. We may send you service communications relating to the products or services we provide you via email (e.g. to inform you about changes to the product or service you requested from us, revisions of our terms and conditions or this Privacy Policy). As such service communications are necessary for the purposes of providing you with our products or services or complying with our legal obligations, you will not be able to opt out from receiving them.

Ability to Opt-Out of Tracking Technologies

Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options,” “tools” or “preferences” menu. You may also consult the browser’s “help” menu. You can learn more about cookies and how to block cookies on different types of browsers by visiting http://www.allaboutcookies.org. If you access the Services on your mobile device, you may not be able to control tracking technologies through the settings. You should check your mobile device's settings to determine whether you can control cookies through your mobile device.

“Do Not Track”

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Services is not designed to recognize “Do Not Track” signals. For more information on Do Not Track, please visit allaboutdnt.com.

Ability to Opt-Out of Analytics

You may exercise choices regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

Rakuten

Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links. Privacy policy: https://rakutenadvertising.com/legal-notices/services-privacy-policy/ Your rights: https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/

You may update or correct information about yourself by emailing us at info@altacycling.com or by accessing your “My Account” page.

LINKS TO OTHER WEB SITES; THIRD PARTY APPLICATIONS

Alta Cycling Group is not responsible for any practices employed by websites linked to or from our website, nor their information or content. Please remember that when you use a link to go from our website to another website, this Privacy Policy is no longer in effect. Your browsing and interaction on any other website is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding. Additionally, some content or applications, including advertisements, on or through the Services are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

CHILDREN'S PRIVACY

Our Services are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 13, please contact us so that we can delete the child's information. The Services will never knowingly accept, collect, maintain or use any information from a child under the age of 13. If a child whom we know to be under the age of 13 sends personal information to us online, we will only use that information to respond directly to that child or notify parents.

SECURITY

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect Personal Data from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

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 Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our 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 or within the Services.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences and/or for other privacy related requests, please contact us by emailing or writing to us at:

Attn: Alta Cycling Group – E-commerce Manager

PO Box 98430

Seattle, WA 98198-0430

Email: info@altacycling.com

Supplemental privacy noties

Notice to Residents of California and Certain Other U.S. States

The following is a list of categories of personal information which may have been collected from consumers or users of our Services within the last twelve (12) months, along with the categories of third parties to whom each category of personal information was disclosed. The categories and examples provided in the chart below are those defined in the California Consumer Privacy Act of 2018 (“CCPA”). This does not mean that all examples of that category of Personal Information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about consumers. We will update this disclosure from time to time as appropriate.

Category	Examples	Categories of Third Parties to Whom Personal Information Is Disclosed
A. Identifiers.	A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.	Service providers, affiliates, third-party advertising, marketing, and analytics companies, government regulators, our legal advisors and parties involved in a legal process, to an entity involved in the sale of our business, and third parties when you agree to or request that we share your information with them
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information, medical information. Some personal information included in this category may overlap with other categories.	Service providers, affiliates, third-party advertising, marketing, and analytics companies, government regulators, our legal advisors and parties involved in a legal process, to an entity involved in the sale of our business, and third parties when you agree to or request that we share your information with them
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Service providers, affiliates, third-party advertising, marketing, and analytics companies, government regulators, our legal advisors and parties involved in a legal process, to an entity involved in the sale of our business, and third parties when you agree to or request that we share your information with them
F. Internet or other similar network activity.	Browsing history, information on a consumer’s interaction with a website, application, or advertisement.	Service providers, affiliates, third-party advertising, marketing, and analytics companies, government regulators, our legal advisors and parties involved in a legal process, to an entity involved in the sale of our business, and third parties when you agree to or request that we share your information with them
G. Geolocation data.	Physical location or movements.	Service providers, affiliates, third-party advertising, marketing, and analytics companies, government regulators, our legal advisors and parties involved in a legal process, to an entity involved in the sale of our business, and third parties when you agree to or request that we share your information with them
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Service providers, affiliates, third-party advertising, marketing, and analytics companies, government regulators, our legal advisors and parties involved in a legal process, to an entity involved in the sale of our business, and third parties when you agree to or request that we share your information with them
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Service providers, affiliates, third-party advertising, marketing, and analytics companies, government regulators, our legal advisors and parties involved in a legal process, to an entity involved in the sale of our business, and third parties when you agree to or request that we share your information with them

 

California and certain other U.S. states provide their state residents with rights to (as applicable):

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Data portability.
• Opt-out of personal data processing for targeted advertising, sales; or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state.

You may also have the right (for example, under California Civil Code § 1798.83) to periodically request and obtain from us the details of any personal information we shared with a third party for the third party’s direct marketing purposes during the prior calendar year. The details would include the categories of personal information and the names and addresses of the third party with which it was shared.

To exercise any of these rights or appeal a decision regarding the same, you may contact us as indicated under the “Contact Us” section above. To change your consent settings for our use of cookies and other technologies, please see the Your Rights section above.

We do not sell your covered information as defined under applicable Nevada law.

Notice to Residents of the EEA and UK

The Services are not intended for use by individuals or businesses in the European Economic Area ("EEA") or the United Kingdom (“UK”). If you are in the EEA or UK and nonetheless access the Site or use our services, the following privacy-related information applies:

Subject to applicable law, you may be able to exercise any of the following rights in relation to your personal information:

• Right to know what information we have about you: This is known as the "right of access" and gives you the right to find out what, if any, personal information we have about you, how we process it, and to request a copy of the personal information.
• Right to correct your information: This is known as the "right of rectification" and gives you the right to ask that we correct or complete any personal information we have about you.
• Right to delete your information: This is known as the "right to erasure" or "right to be forgotten" and gives you the right to ask us to delete your personal information.
• Right to change how we use your information: This is known as the "right to restrict processing" and gives you the right to ask us to change how we use your personal information in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.
• Right to move your information: This is known as the "right to data portability" and gives you the right to ask to receive your personal information from us in a structured, commonly used and machine-readable format or to have it transmitted to another controller.
• Right to stop us from using your information: This is known as the "right to object" and gives you the right to ask us to stop using your personal information when applicable.
• Rights relating to how we use your information to categorize you or make decisions about you: This is known as the "right in relation to automated decision-making and profiling": You have the right to be free from decisions we may make that are based solely on automated processing of your personal information, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.
• Right to withdraw consent: If we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This will not affect our use of your data before we received notice that you wished to withdraw your consent.
• Right to file a complaint with the supervisory authority: If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the supervisory authority that is authorized to hear those concerns in your jurisdiction, although we invite you to Contact Us with any concern as we would be happy to try and resolve it directly.

You may exercise your rights by contacting us as indicated under the “Contact Us” section above. To change your consent settings for our use of cookies and other technologies, please see the Your Rights section above.

The requests above will be considered and responded to in the time period stated by applicable law. Certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.