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This California Consumer Privacy Act Notice (“Notice”) is provided by Surly Bikes, a brand of Quality Bicycle Products, Inc. (“QBP,” “We,” “Us,” “Our”). This Notice explains how we collect, use, and disclose personal information about California residents. This Notice also explains certain rights that California residents have under the California Consumer Privacy Act (“CCPA”).

Under the CCPA, “personal information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. This information is referred to in this Notice as “Personal Data.”

CATEGORIES OF PERSONAL DATA

We collect and disclose Personal Data in a variety of contexts. For example, we collect and disclose Personal Data voluntarily provided to us and automatically provided to us in connection with Surly Bikes products and services.

During the part 12 months, we have collected the following categories of Personal Data:

  1. Personal information, including contact details such as telephone number and address and financial information such as payment card details including credit and debit card numbers
  2. Unique Identifiers such as full name, IP Address, or user alias
  3. Purchase information, such as products and services obtained and transaction histories
  4. Internet or online activity information such as browsing history, and information regarding interaction with our website or advertisements
  5. Geolocation data
  6. Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics.
  7. Characteristics of protected class (applicable if we collect info on race, color, national origin, religion, sex, disability, age, citizenship status, genetic information, ancestry, marital status, sexual orientation, gender identity/expression, AIDS/HIV status, political activities or affiliations, military or veteran status, or status as a victim of domestic violence).
  8. Audio or similar information (applicable if we record calls through our customer service center).

Personal information does not include:

  • Publicly available information from government records
  • De-identified or aggregated consumer information

WHY WE COLLECT PERSONAL DATA AND HOW WE USE IT

We use your information for a variety of business purposes. For each category of Personal Information collected above, has been used to:

  • Provide and manage products and services
    • We may contact you regarding customer service issues or billing matters
    • If you purchase goods/services, We will need to use your Personal Information to process your order and to enable delivery
  • Support of everyday operations, including to meet risk, legal, and compliance requirements
    • To prevent fraud
    • Collect fees
    • Resolve disputes
    • Assist with investigations
    • Process warranty claims
    • Distribute important product information (such as recall information)
    • Enforce Our agreements
    • To comply with Our legal obligations
  • Manage, improve, and develop our business, support
    • Perform system administration activities,
    • Customize your content
    • To provide you with information, products, or services that you request from us
    • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you

During the past 12 months we have also disclosed the categories of Personal Data listed above for business purposes. We have not, however, sold Personal Data. The CCPA defines a “sale” as the disclosure of Personal Data for monetary or other valuable consideration.

WE OBTAIN THE CATEGORIES OF PERSONAL INFORMATION LISTED ABOVE FROM THE FOLLOWING CATEGORIES OF SOURCES:

  • Directly from you or your agents. For example, from information that you provide us related to the services for which you engage us
  • Indirectly from you or your agents. For example, through information we collect from you in the course of providing services to you.
  • Directly and indirectly from activity on our website.
  • From third parties that interact with us in connection with the services we perform.

SHARING PERSONAL INFORMATION

We may disclose your Personal information to a third party for a business purpose.

We disclose personal information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Service providers
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide you.

YOUR RIGHTS AND CHOICES UNDER THE CCPA

A California resident has the right to request that we:

  1. Disclose the following information covering the 12-month period prior to the request (“Access Request”):
    1. Categories of Personal Data we collected about you and the categories of sources from which we collected the Personal data;
    2. The business or commercial purpose for collecting Personal Data about you;
    3. The categories of third parties to whom we disclosed Personal Data about you, and the categories of Personal Data disclosed;
    4. The specific pieces of Personal Data we collected about you; and
  2. Delete Personal Data we collected from you (“Deletion Request”).

If you are a California resident, a business may not discriminate against you for exercising your rights under the CCPA.

HOW TO MAKE REQUESTS

If you are a California resident, you can make a verifiable consumer request for an Access Request or Deletion Request by:

  1. Submitting your request to ccparequest@qbp.com (preferred)
  2. Contacting QBP at 833-928-2722 (please allow up to two business days for a response)

RESPONDING TO REQUESTS

Privacy and data protection laws, other than the CCPA, apply to much of the Personal Data that we collect, use, and disclose. When these laws apply, Personal Data may be exempt from, or outside the scope of, Access Requests and Deletion requests. As a result, in some instances, we may decline all or part of an Access Request or Deletion Request related to this Personal Data. This means that we may not provide some or all of this Personal Data when you make an Access Request. Also, we may not delete some or all of this Personal Data when you make a Deletion Request. As an example, we will not delete Personal Data when it is necessary to maintain that Personal Data to comply with a legal obligation.

In some instances, we may not be able to honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual.

We will work to process all verified requests within 45 days pursuant to the CCPA. If We need an extension for up to an additional 45 days in order to process your request, We will provide you with an explanation for the delay.

CHANGES TO THIS NOTICE

We will modify this Notice as a result of amendments to laws or regulations, or due to other reasons involving our operation. We do, we will post the revised Notice on this webpage indicating when the Notice was “Last Updated.”

Last Updated: 01/04/2021