Privacy Policy

A. Information You Provide to Us:

In using our Services, you may provide us with the following categories of Information, including, without limitation:

• Individual identifiers such as name, date of birth, email address, postal address, and telephone number(s);
• Payment and transaction information including credit or bank card information;
• Communications with us, preferences, and other Information you provide to us such as any messages (including via online chat feature), opinions and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information), and other Information that you share with us when you contact us directly (such as for customer support services); and
• Additional information as otherwise described to you at the point of collection or pursuant to your consent.

B. Information We May Automatically Collect About You:

Our Services may automatically collect certain Information about you. We use this Information to help us design our Services to better suit our users' needs. This Information may include:

• IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider);
• Date and time of your visit or use of our Services;
• Domain server from which you are using our Services;
• Type of computer, web browsers, search engine used, operating system, or platform you use;
• Data identifying the web pages you visited prior to and after visiting our website or use of our Services; and
• Your movement and activity within the website, which is aggregated with other information;
• Geographic data such as country or region;
• Mobile device information, including the type of device you use, operating system version, and the device identifier (or "UDID"); and
• Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.

C. Cookies & Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Information by using certain technologies, such as cookies, web beacons, pixels, software developer kits, third party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
• Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Services use retargeting pixels from Google, Facebook, and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.
• Analytics. Analytics are tools we use, such as Google Analytics and Shopify Analytics, to help provide us with information about traffic to our website and use of our Services, which Google or Shopify may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. Learn more about Google's Privacy Policy here: https://policies.google.com/privacy?hl=en-US. You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser. Learn more about Shopify's Privacy Policy here: https://www.shopify.com/legal/privacy and Cookie Notice here: https://www.shopify.com/legal/cookies.
• Mobile Application Technologies. If you access our website and Services through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location.

D. Information We May Receive from Third Parties

We may collect additional Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, YouTube, Tik-Tok ("Social Media Platforms"), and/or sources providing publicly-available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other website's or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

A. Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

• To respond to your inquiries and provide you with requested information and other communications, including by email;
• To process your product registration request;
• To send you our newsletter and other correspondence you request;
• To help you locate a dealer location near you;
• For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
• To fulfill your order;
• To manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
• To maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;
• To comply with our Terms & Conditions;
• For analytics for business purposes and business intelligence;
• To comply with any applicable laws and regulations and respond to lawful requests; and/or
• For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

B. Sharing Your Information

We may share and/or disclose your Information as set forth in the Privacy Policy and in the following circumstances:

• Third-Party Service Providers. We may share your Information with third-party service providers or data processors that perform certain functions or services on our behalf (such as to host the Services, store or manage the data, perform analyses, process payments, provide customer service, or send communications for us). These third-party service providers will process this data only for purposes specified by Haro Bikes. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.
• Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required to by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
• Business Transfers. Your Information may be transferred, sold, or otherwise conveyed ("Conveyances") to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You agree to any and all such Conveyances of your Information.
• Aggregate and Deidentified Data. We may share general Information, aggregated data or publish information based on aggregated data. However, we will only do so in a way that your personal identity is protected.
• Online Communications. Any information you submit in a public forum (e.g., a blog or social network) may be read, collected, or used by us and other participants, and could be used to personalize your experience. You are responsible for the information you choose to submit in these instances.
• With Your Consent. We may share Information consistent with this Privacy Policy with your consent.

1. Email. By using our Services, you agree that we may contact you by email as set forth herein. If you do not want to receive marketing and promotional emails from us, you may click on the "unsubscribe" link in the email to unsubscribe and opt-out of marketing email communications or How to Contact Us.
2. Cookies. If you want to delete any cookies that are already on your computer, please refer to your file management software to locate the file or directory that stores cookies. Other information on deleting or controlling cookies is available at www.allaboutcookies.org. Please note that by deleting cookies or disabling future cookies, you may not be able to access certain areas or features of our Services.
3. Opting Out of Direct Marketing. To exercise choices regarding the marketing information you receive, you may also review the following links:

A. Access to Specific Information and Data Portability Rights

California residents have the right to request that Haro Bikes disclose certain information to you about Haro Bikes' collection and use of your personal Information over the past twelve (12) months. Once Haro Bikes receives and confirms a verifiable consumer request from you, Haro Bikes will disclose to you, to the extent permitted by law:

• The categories of personal Information Haro Bikes collected about you.
• The categories of sources for your personal Information Haro Bikes collected about you.
• Haro Bikes' business or commercial purpose for collecting your personal Information.
• The categories of third parties with whom Haro Bikes shares your personal Information.
• If we disclosed your personal Information for a business purpose, the personal Information categories that each category of recipient obtained.

You shall have the right to request that the Information described above be provided to you in a portable and readily usable format, to the extent technically feasible ("data portability").

Haro Bikes does not sell your personal Information.

B. Deletion Request Rights

You have the right to request that Haro Bikes delete certain of your personal Information that Haro Bikes collected from and/or related to you and retained, subject to certain exceptions.

To the extent that Haro Bikes can delete your personal Information, once Haro Bikes receives and confirms your verifiable consumer request, Haro Bikes will delete (and direct our service providers to delete) your personal Information, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected your personal Information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. Right to Correct Inaccurate Information.

To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your personal Information.

D. Sale and Sharing of Personal Information and the Right to Opt-Out.

You have the right to opt out of the processing of your Information for the following purposes:

• Sale of your Information.
• Sharing of your Information for cross-context behavioral advertising.

The use of online tracking technologies may be considered a "sale" or "sharing" under California law. To the extent that these online tracking technologies are deemed to be a "sale" or "sharing" under California law, you may opt-out of these online tracking technologies by submitting a request via DSAR opt out or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC).

E. Right to Limit Use and Disclosure of Sensitive Personal Information.

You have the right to request that we limit the ways we use and disclose your sensitive personal Information (as defined by CCPA) to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or and as authorized by law.

F. Right to Non-Discrimination.

You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.

G. Right to Disclosure of Direct Marketers.

You have a right to the categories and names/addresses of third parties that have received personal Information for their direct marketing purposes upon simple request, and free of charge.

You may make an authenticated consumer request exercising your Right to Know and Access Specific Information including Right to Know what Personal Information is being Sold or Shared or under the CCPA twice within a twelve (12) month period. To exercise the rights described above, see the Exercising Your Data Subject Rights section below.

H. Verifying Requests

To help protect your privacy and maintain security, if you request access to or deletion of your personal Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal Information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal Information is the subject of the request. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).

1. Authorized Agents

You may use an authorized agent to submit verifiable consumer requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request from an authorized agent that does not submit proper verification proof.

2. Notice of Financial Incentive

As an incentive for providing us with your Information, you may receive a financial benefit in the form of an email coupon, discount, rebate, free sample, promotions, or other similar reward that will be sent to you. This discount may constitute a financial incentive under the California Consumer Privacy Act (“Financial Incentive”). The categories of personal Information required for us to provide the Financial Incentives include personal identifiers such as full name and contact information including email address as well as personal and demographic information you choose to provide.

To offer these discounts, we may track your personal Information, such as purchase history and other demographic data. You have the right to withdraw from the Financial Incentive at any time by submitting a request to privacy@harobikes.com. Please note that if you request deletion of part or all your personal Information, that could affect your ability to qualify for the discount.

3. Shine the Light Requests

California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal Information by Haro Bikes to third parties for the third parties' direct marketing purposes. To make an opt-out request of such disclosures, please send an email to privacy@harobikes.com.

4. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request by contacting us at privacy@harobikes.com.

A. Controller and EU Representative

Haro Bikes is the controller for the Information (as defined above in Section II) we process, unless otherwise stated.

Email: privacy@harobikes.com

Call us: 1-800-289-4276

Write us: Haro Bikes
1230 Avenida Chelsea
Vista, CA 92081

B. Your Data Protection Rights

To the extent any European Data Protection Legislation and certain Non-European Data Protection Legislation apply, and we hold such personal data in our capacity as a data controller as defined under those laws, you may request that we:

• Restrict the way that we process and share your personal data;
• Transfer your personal data to a third party;
• Revoke your consent for processing of your personal data;
• Provide you with access to your personal data;
• Remove your personal data if no longer necessary for the purposes collected;
• Update your personal data so it is correct and not out of date; and/or
• Object to our processing of your personal data.

If you wish to object to the use and processing of your personal data or withdraw consent to this Privacy Policy, you can contact us in the following ways:

Email: privacy@harobikes.com

Call us: 1-800-289-4276

Write us: Haro Bikes
1230 Avenida Chelsea
Vista, CA 92081

The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests. You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at:

Email: privacy@harobikes.com

Call us: 1-800-289-4276

Write us: Haro Bikes
1230 Avenida Chelsea
Vista, CA 92081

C. Lawful Basis for Processing Your Information

As described throughout this Privacy Policy, we believe the foregoing handling of your Information, which may include your personal data, furthers our legitimate interests in commercial activities that are not overridden by the interest or fundamental rights and freedoms of the individuals at issue. Depending on what personal data we collect from you and how we collect it, we rely on various grounds for processing your personal data, including the following reasons:

• To administer our contractual relationship, including setting up any services you may request;
• Because it is in our legitimate interest to effectively and efficiently operate our business and provide you with the services offered through the Services and other useful content and for other marketing, design, and advertising purposes;
• To process employee data, prevent against fraud, provide technology security, and other necessary operational matters;
• In order to fulfill any legal obligations, we may have to collect this Information from you; and/or
• Because you have provided your consent for us to do so.

If the processing of your Information is based on your consent, European Data Protection Legislation and certain Non-European Data Protection Legislation also allows users the right to access, revoke or modify your consent at any time. Please see the How to Contact Us section, below, to review or modify your consents.

D. Consent to Transfer

Haro Bikes is operated in the United States, and we may use service providers based in the United States and Canada to operate our business and our relationship with you. Please be aware that Information, including your Personal Data, that we collect will be transferred to, stored, and processed in the United States and Canada, either or both of which may be jurisdictions in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We collect and transfer to the U.S. and Canada only Information, including Personal Data: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Haro Bikes in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and model clauses with vendors whenever feasible and appropriate.

E. Retention

We will retain your Information for as long as needed for the purposes described in this Privacy Policy. More specifically, the time we maintain your Information depends on the following factors:

• Whether we need the Information to provide the Services. We will maintain any data needed to provide you with the Services, such as contact information and payment or transaction information, for as long as needed for us to provide you with the Services, respond to your questions and requests, and/or administer your account (if applicable).
• Whether we need the Information to comply with our legal obligations. We may have legal obligations to maintain your Information where a legal or regulatory body may ask for it in the future, for example in response to a data subject request or complaint. This information may include contact information and location information.
• Whether we need the Information for a legitimate business interest. We may store Information like contact information, cookies, and location information in order to perform analytics, troubleshoot errors, or improve our Services. In any event, we delete the Information when it is no longer needed for our legitimate interest.

Regardless of our reason for retaining your information, we delete all Information in accordance with our routine record keeping policies.

Email: privacy@harobikes.com

Call us: 1-800-289-4276

Write us: Haro Bikes
1230 Avenida Chelsea
Vista, CA 92081