VERGE MOTORCYCLES PRIVACY POLICY

Last updated and effective date: July 17 2023

Verge Motorcycles OÜ and its affiliate companies (“Verge”, “we”, “us”, “our”) are committed to protecting your privacy and personal data.

This Privacy Policy provides you information on how we collect, process and store your personal data. This Policy applies when you make inquiries about or use our products and services, such as ride a Verge motorcycle, place orders for test drives or rentals, visit our website, interact with the Verge Club or the Verge App, communicate with our customer support, sign up for our newsletter, make reservations with us or purchases from us or otherwise interact with us via our website or in the Verge Club, the Verge App, in-store or social media, or by phone or any messaging app.

This Privacy Policy applies also to you as a pedestrian, driver, passenger, or vehicle owner if you are present and identified in the records of our test drives with video recording.

This policy applies as well to our business contacts, shareholders and other stakeholders as well as job applicants and partners engaging in cooperation with us concerning our products and services.

We process your personal data under this Privacy Policy so please read it carefully. For certain products and services, we may give additional notices about privacy information. Please read those additional privacy notices to understand, how your personal data is collected and processed in such cases.

1. WHAT PERSONAL DATA IS COLLECTED, STORED AND PROCESSED?

We collect and process various types of personal data. Such personal data may include:

  • Contact information. Such as your name, title, position, address, phone number, email address and, if you are a vendor, distributor or other stakeholder, company information.
  • Personal details. Your username, password, social security number, gender, age, and ID card, such as your passport or driver’s license details, when required for verifying your identity or right to drive.
  • Your Verge motorcycle data. Such as the vehicle type, identification number (VIN), registration number, insurance information, location data, data concerning the performance, usage and operation of your motorcycle, and service history. This might include diagnostic data relating to your vehicle, such as odometer, battery status, tire pressure, charging status, over-the-air updates, and maintenance schedule.
  • Agreement and transaction related data. Personal data necessary for maintaining our contractual relationship, such as information about your agreements, orders, purchases, given authorizations, payment status and details, credit card information, bank account number and other payment information, invoices, marketing preferences, personal interests, as well as your communications with us through different channels, such as online via our website or in the Verge Club, the Verge App, in-store or social media, or by phone or any messaging app.
  • Shareholder information. Such as your name, address, date of birth, nationality, and amount of shares held by you.
  • Recruitment information. Such as your application and resume, education and work experience, and other information necessary for the recruitment that you provide to Verge during the recruitment process, including interview information, video interviews and references.
  • Online and electronic identification data. Such as your IP address, cookie ID, mobile device ID, time of visit and spent on the website or app, details about browser and device, page interaction information, navigation paths, scrolling, clicks, and location.
  • Test ride recording data. Personal data collected from time to time in connection with our test drives with the means of camera and video recordings, including photos, video footage and audio track, for the purpose of ensuring our interests and the protection of our property.

Your personal data may be collected and processed in the following situations as applicable and in accordance with the legal basis provided below in section 2 of this Privacy Policy:

  • Product orders, rendering services. We process your personal data to facilitate your orders, deliver the products and to render the services requested by you. This data includes your personal details, your Verge motorcycle data, agreement and transaction related data as well as online and electronic identification data.
  • Contacts. We need to process your personal data when you contact us e.g. for questions and inquiries concerning our products or services, including customer support or warranty service. We also need to process your personal data if we need to contact you regarding product safety or regulatory notices. Additionally, if you are a stakeholder of ours, we process your personal data in connection with our communications and contacts with you relating to our stakeholder relationship. We may process your personal details as well as other information you provide to us in connection with these communications.
  • Accounts. When you create an account in the Verge Club, we collect your personal data in connection with creating and managing the account. In connection with signing up to the Verge Club and using your account and the Verge app, we may process your contact details and other personal data you provide us through your use of the account, such as your Verge motorcycle data.
  • Physical stores. If you visit our physical stores, we may collect your personal data in order to send you electronic receipts or for registering you to Verge Club. Such personal data includes your contact details.
  • Interest and adherence in our offerings. We collect data regarding your interest in our products and services based on, for example, your orders, visits on our website, signing up for in test drives, feedback, email communications to you, or participation in – or in connection with – any events, surveys, contests, campaigns, perks or incentives we may have. The data collected includes your personal details and agreement and transaction related data, such as information of your orders, online and electronic identification data as well as test ride recording data.
  • Cookies and other similar technologies. We use cookies and similar technologies on our website and the information collected includes online and electronic identification data. For more information about cookies, please read our Cookie Policy.

We primarily obtain your personal data directly from you when you order or use our services, create an account, browse our website, or otherwise interact with us.

In addition to the information you provide, we collect information about you automatically when you use our products and services and visit our website. Your personal data may be also obtained from or shared with certain third parties, such as our finance partners, dealers and distributors, in accordance with applicable laws and regulations. These third parties have their own privacy policies that you should also carefully review.

Collection and Use of Non-Personal Data

We may also collect, use, and share information that does not, on its own, personally identify you. Such information may be used for any purpose, including for example, for operational or research purposes, for industry analysis, to improve or modify our products and services, to better tailor our products and services to your needs, and where legally required.

2. WHAT ARE THE PURPOSES AND LEGAL BASES FOR PROCESSING PERSONAL DATA?

The table below sets out our purposes for processing your personal data as well as the legal basis for the processing.

Purpose of processingLegal basis for the processingCategories of personal data
Service delivery & customer service. Processing orders, delivering our products and services, providing customer service relating to your orders, warranty, refunds, returns and cancellations as well as managing payments, contracts and transactions.Necessary for the performance of the contract between us and you.

Necessary for compliance with our legal obligations.

Based on your consent (for example, in order to insure your Verge Motorcycle for you).

Where you have made an order or a purchase through our sites with a local Verge company, such company may act as an independent data controller of your personal data for this purpose.		Contact information

Personal details

Your Verge motorcycle data

Agreement and transaction related data
Maintaining and developing our customer relationship with you. Including responding to your inquiries and comments, sending important notices to you, sending you notices requested by you (such as regarding your motorcycle health) and providing you with other customer support.Necessary for the performance of the contract between us and you.

Based on your consent

Necessary for our legitimate interests to provide customer service and process orders.

Necessary for our legitimate interest to provide customers with important notices or notices requested by them.		Contact information

Your Verge Motorcycle data

Agreement and transaction related data
Administering and managing your account. Administering your registration as a user of our services and providing you different functionalities in them.Necessary for the performance of the contract between us and you.

Necessary for our legitimate interests to provide customer service and process orders. 		Contact information

Personal details

Online and electronic identification data
Developing our products and services. Improving and developing the quality, safety and functionality of our products, services and business as well as considering customer satisfaction. This may include making anonymized, de-identified or aggregated compilations, statistics and analyses of such data.Based on your consent

Necessary for our legitimate interests to improve and develop the quality, safety and functionality of our products, services and business as well as consider customer satisfaction.

Necessary for compliance with our legal obligations.		Your Verge motorcycle data

Agreement and transaction related data

Online and electronic identification data
Marketing purposes. Providing information related to our products, services, events and campaigns, recommending our products and services that you might find interesting, performing analytics and sending you promotional messages via email, phone, and/or other similar means of communication.Based on your consent

Necessary for our legitimate interests to market our products and services.

When required by applicable law, we will collect your consent before contacting you for direct marketing purposes via email, phone and/or similar means of communication.		Contact information

Personal details

Your Verge motorcycle data

Agreement and transaction related data
Providing the option to opt-out. Complying with your request not to send you direct marketing, where applicable.Necessary for compliance with our legal obligations. Contact information
Compliance with applicable legislation. Complying and fulfilling our legal duties and obligations relating to e.g. tax law, accounting, regulatory compliance, safety issues, litigation, recalls and product liability.Necessary for compliance with our legal obligations.

Based on your consent		Contact information

Personal details

Your Verge motorcycle data

Agreement and transaction related data

Shareholder information

Recruitment information

Online and electronic identification data

Test ride recording data
Legal defense & security assurance. Defending and securing our and our customers’ rights, ensuring the security and safety of our products and services and preventing misconduct and fraud.Necessary for our legitimate interests to defend and secure our and our customers’ rights, ensure the security and safety of our products and services and prevent misconduct and fraud.

Based on your consent		Contact information

Personal details

Your Verge motorcycle data

Agreement and transaction related data

Shareholder information

Recruitment information

Online and electronic identification data

Test ride recording data
Managing our contractual relationships. Preparing and implementing of our contractual relationship with our business partners, including distributors’, suppliers’ and other stakeholders’ contact persons as well as investors, contacting you and communicating otherwise with you as one of our stakeholders.Necessary for the performance of the contract between us and you.

Necessary for our legitimate interests to contact you and communicate with you as one of our stakeholders.		Contact information

Agreement and transaction related data

Shareholder information

Recruitment information
Recruitment and resourcing. Contacting you to inform you about the status of your application or to obtain additional information as well as to carry out interviews and evaluations in connection with the recruitment process.Necessary for compliance with our legal obligations.

Necessary for our legitimate interests to contact you, obtain information from you and evaluate you in connection with the recruitment process.		Contact Information

Personal details

Recruitment information
Administrating shareholder relationships. Maintaining our shareholder register, organizing shareholder meetings and sending investor information to our shareholders.Necessary for compliance with our legal obligations. Shareholder information

3. HOW DO WE SHARE YOUR PERSONAL DATA?

For the purposes described in this Privacy Policy, personal data may be disclosed to:

  • Other Verge group companies. We may share your personal data within the Verge Group of companies, including our subsidiaries, affiliates, joint venture and other associated companies for any of the legitimate purposes described in this Privacy Policy. A list of the Verge Group companies to which your data may be transferred can be found at the end of this Privacy Policy. If you make an order or a purchase through our website from a local group company, your data will be shared with such group company for handling it.
  • Authorized third parties. Your personal data may be shared with and processed by third party service providers (such as dealers, distributors, payment processors, banks and vehicle finance providers, debt collectors, professional advisers, and email providers) to help carry out the services they are performing for us to support our business operations.
  • Business partners.Your personal data may be shared with third parties with whom we co- sponsor events or promotions or jointly offer products or services, such as our business partners.
  • Third parties for compliance with laws and other legal business purposes. We may share your personal data i) when necessary or required to comply with applicable laws, regulations or a court decision; ii) to detect, prevent, or otherwise address fraud, money laundering, terrorism financing, or technical or data security problems; or iii) to defend and exercise our or our customers’ rights. In addition, if you accept a government-offered purchase incentive or otherwise participate in government incentive programs, such as rebates or tax incentives for electric vehicles, we may be required to provide information to the government, or its designated administrators, pertaining to your purchase, participation and eligibility.
  • Third parties in connection with a business sale. If we are involved in a merger, business/stock/asset transfer or similar M&A activity or financing in or reorganization of our business, we may transfer your personal data to one or more third parties (including their advisors) as part of that transaction.
  • Bankruptcy or insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.

4. WHERE IS PERSONAL DATA PROCESSED?

We primarily process personal data on servers within the EU/EEA.

However, the processing of personal data may also involve possible disclosures, transfers, storage, and processing of data to other countries outside the EU/EEA, where the data protection laws may differ from those in the EU/EEA. In such an event, Verge engages appropriate safeguards under applicable data protection legislation to ensure an adequate level of data protection for your personal data. These measures include, for example, the European Commission’s standard contractual clauses on transferring personal data to third countries.

For more information on data transfers, please contact us using the information provided at the end of this Privacy Policy.

5. HOW DOES VERGE PROTECT PERSONAL DATA?

We have taken reasonable technical and organizational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access and any other unlawful forms of processing.

However, no data transmission or storage over the Internet can be guaranteed to be completely secure. As a result, while we strive to protect your personal data, we cannot guarantee or warrant the security of any information we have collected.

You should also be mindful of the security of your own computer or mobile device – and their internet connection – when you place an order online or log on to the Verge Club or the Verge App. We recommend you protect your computer and mobile device with a passcode and change your log-in passwords periodically.

6. HOW LONG DOES VERGE STORE PERSONAL DATA?

We will retain personal data only for as long as is necessary to fulfill the purpose for which it was collected. When no longer required, personal data will be destroyed or erased. For more information on our data retention policies and storage times, please contact us using the information provided at the end of this Privacy Policy.

If you use our mobile application, you can delete your account by submitting a request to legal@vergemotorcycles.com or by deleting your account through the application itself. If you delete your account from within the application, we will delete the application related personal data. Please note that we may be obligated to store your other kind of personal data in order to comply with our legal obligations.

7. YOUR RIGHTS

If you are an EU/EEA, Monaco, or UK resident or if required by your local law, you may at any time exercise the following rights in relation to your personal data that we process:

  • Right to access personal data. You have the right to be informed about our processing of your personal data and to request a copy thereof.
  • Right to correct personal data. You have the right to ask us for rectification of any inaccurate personal data we hold about you.
  • Right to erasure.We will delete the data at your request if it is no longer legitimately needed.
  • Right to object to the processing. You have the right to object to the processing of your personal data when the processing is based on our legitimate interest.
  • Right to restrict processing. Under certain circumstances, you may have the right to restrict our processing of your personal data.
  • Right to data portability. Where the legal basis for processing your personal data is your consent or an agreement directly entered between you and Verge, and we process your data by automated means, you may have the right to be provided with the personal data we hold about you in structured, commonly used and machine-readable format and to transmit the data to another controller.
  • Right to withdraw your consent. If the processing is based on your consent, you have the right to withdraw your consent to such processing at any time. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
  • Right to opt-out from marketing. If you no longer wish to receive marketing messages from Verge, you can choose to opt-out at any time by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.

You may exercise these rights by contacting us by using the information provided at the end of this Privacy Policy.

If you consider that our processing of your personal data infringes the applicable data protection laws, you may have the right to lodge a complaint with a competent data protection supervisory authority. If you are an EU resident and believe your rights under the GDPR have been violated, you have the right to file a complaint with the supervisory authority. Contact details for all EU supervisory authorities can be found at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Please note that residents of certain jurisdictions may have additional privacy rights compared to the ones described above. Depending on your jurisdiction, you may have, for example, the following right in respect of our data processing:

  • Right to communicate after-death instructions. You have the right to communicate your instructions to us relating to the processing of your personal data in case of death.

8. CHILDREN’S PRIVACY

Our website and motorcycles are intended for persons who are of the legal age to drive a motorcycle in their jurisdictions. Typically, the minimum age to get a motorcycle license varies from 16-18 years. We do not target our products, services or website to children under the age of 16 years and do not knowingly collect personal data from children. In the event that we learn that we have gathered personal data from anyone under the age of 16, we will delete such information as soon as possible.

Our website and services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “Contact details” section below.

9. COOKIES

We use cookies and other similar technologies on our website. A “Cookie” is a small text file that is placed on a web browser or internet-enabled device to record information related to how a website is used. In most cases, your personal data collected through cookies and other technologies is collected automatically for our legitimate business interests. In some jurisdictions, we ask for your consent before collecting your personal data.

We do not use any cookies, pixels, or other tracking that discloses to any third party information that identifies a person as having viewed specific video materials.

For more information about cookies, please read our Cookie Policy.

10. CHANGES TO THIS PRIVACY POLICY

We may update and change this Privacy Policy from time to time. You can see the date of the latest change or update at the top of this Policy. Any changes and updates will become effective upon our posting of the revised Privacy Policy.

We may provide notice to you of any changes. This notice may be provided by email, by posting the revised Privacy Policy on our website or by other means prior to the change becoming effective, consistent with applicable laws.

11. “DO NOT TRACK” SIGNALS

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites and online services, our websites are not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you may wish to visit http://www.allaboutdnt.com/.

12. CONTACT DETAILS AND CONTROLLER OF YOUR PERSONAL DATA

If you have further questions or comments regarding your privacy or wish to exercise your rights, please contact us by using the following contact information:

Verge Motorcycles OÜ (Business ID: 16535648)

Address: Ilunurme tee 10/1, Liivamäe küla, 74207 Harju maakond, Estonia

Email address: privacy@vergemotorcycles.com

For individuals in the EEA, UK, Monaco or Switzerland, the main data controller for the processing of your personal data as described in this policy is Verge Motorcycles OÜ.

Additionally, when you order products and services through our website or do business with us in our flagship stores, the independent data controller responsible for processing of your personal data may be the local Verge Company you have contracted.

VERGE GROUP COMPANIES

Verge Group companies may use your personal data for the purposes defined in this Privacy Policy.

For a list of the Verge Group companies, please click here for Company Information