Privacy policy

Welcome to the REKKIE INC ("REKKIE") privacy policy. REKKIE respects your privacy and is committed to protecting your personal data. We do collect many forms of data. We use this data to continually improve the experience for everyone using our products and services. We do not sell your data to other companies.

1. Introduction

This privacy policy tells you how REKKIE INC (referenced in this document as “REKKIE” or “The Company”, “we”, “us” or “our” in this privacy policy) uses your personal data when you visit our website, download our apps or interact with us, including when you sign up to our newsletter, use our products and services or take part in a competition.

It also tells you your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy notices we may show you from time to time, so that you are fully aware of how and why we are using your personal data.

This website is not intended for children and we do not knowingly collect data relating to children. The REKKIE website and app are not intended for individuals under the age of 16. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

This privacy policy was last updated on 8th Jan 2021. We reserve the right to update our privacy policy from time to time to ensure that we can deliver a great experience.

If you have any questions about our privacy and data policies, including any requests to exercise your legal rights, please email us at info@rekkie.com.

 2. Who we are

Our mission here at REKKIE is to bring augmented reality and other technologies to improve performance and help people have more fun while skiing or participating in other demanding sports or activities.

We take privacy very seriously and strive to only collect the data we need to deliver an outstanding experience. We have appointed a data privacy manager who is responsible for looking after questions about this privacy policy.

3. How we collect data

There are lots of different ways in which we may collect data, or receive data, and you can see an explanation of the main ways below.

You may give us data when you interact with us on our app, website, and other platforms.

You may give us data by filling in forms or by corresponding with us by post, phone, email or through chat or social media. This includes data you provide when you:

• sign up to receive our email newsletter;
• make enquiries or request information be sent to you;
• create an account on our website;
• order our products;
• ask for direct marketing to be sent to you;
• use ‘refer a friend’;
• participate in our social pages, forums and networks;
• engage with us on social media;
• enter a competition, promotion or survey;
• contact customer services using the chatbot, email, or letter; or
• leave comments or reviews on our products or services.

We may get some data automatically.

As you interact with us, including via the REKKIE website, we may automatically collect data about your equipment, browsing actions and patterns. We may also collect data when you click on one of our adverts (including those shown on third party websites or via social media).

• We may obtain some data from third parties.
• We may receive data about you from various categories of third parties, including:
• from providers of services which facilitate our ecommerce operations, including ecommerce platforms and payment and fraud prevention services;
• from web and app analytics providers, advertising networks and search information providers; from data partners;
• from your friends who referred you using ‘refer a friend’;
• from publicly available sources; and from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.

4. How we collect consent

When you install our app and agree to our terms of service/privacy policy, this confirms your consent.  Also, when you provide us with personal information to complete a transaction, verify your credit card, place a pre-order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will ask you directly for your expressed consent.

How do I withdraw my consent? If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at info@rekkie.com.

5. Types of personal data we collect

How we collect data above described all the different ways in which it’s possible to be given or obtain data. Some of that data may be personal data and we explain below the types of personal data we may collect about you. Of course, the types of personal data we collect about you will depend on how you are interacting with us. 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We collect a variety of personal information about our customers and visitors to the Rekkie website and users of the Rekkie app.

This personal data falls into these categories:

• Identity Data includes title, gender, first name, maiden name, last name, date of birth, username or similar identifier and your login/password. If you interact with us through social media, this may include your social media username.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card and direct debit/bank account details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, app products and services, and any of the content you contribute to the REKKIE social media communities.
• GPS data, linked to your profile if you ski with the REKKIE app.
• Movement/Pressure/Motion sensing data, linked to your profile if you are a user of the REKKIE app.
• Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
• Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.
• We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

6. The legal bases for using personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract between you and us for us to supply the products to you.
• Where we need to use your data to create and maintain a user profile to provide you with the services in the REKKIE app.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, fraud screening as part of the check-out process or keeping our website secure.
• Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Where our legal basis is consent, you have the right to withdraw consent any time.

See How and why we use your personal data below for more detailed information.

7. How and why we use your personal data

The breakdown below gives you a breakdown of the details of how we are using your personal data, the types of personal data that applies to and why it is we can do this. When we explain why, we will identify the relevant category from explaining the legal bases for using personal data above, and, where it’s based on being able to do so for our legitimate interests, we will highlight what that legitimate interest is.

We may process your personal data for more than one legal basis depending on how we are using it.

How we are using your personal data:

• To register you as a new customer and manage a potential sale with you, including letting you know you have left products in your basket without checking out. To process and deliver your order including manage payments.
  • What types of personal data do we use to do that: Identity, Contact, Financial, Transaction, Marketing and Communications
  • Why it is that we can do that: Performance of a contract with you. Necessary for our legitimate interests (including being able to process purchases of products by our customers) 

• To manage our relationship with you, including notifying you about changes to our terms or privacy policy.
  • What types of personal data do we use to do that: Identity, Contact, Profile, Marketing and Communications
  • Why it is that we can do that: Performance of a contract with you, necessary to comply with a legal obligation, necessary for our legitimate interests (to keep our records updated) 

• To deliver direct marketing to you.
  • What types of personal data do we use to do that: Identity, Contact, Profile, Usage, Marketing and Communications, Technical, Tracking
  • Why it is that we can do that: Necessary for our legitimate interests (to promote our own business and our products and services). 

• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  • What types of personal data do we use to do that: Identity, Contact, Technical, Tracking
  • Why it is that we can do that: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud), Necessary to comply with a legal obligation 

• To deliver relevant website content to you and measure or understand the effectiveness of the content we have on our website.
  • What types of personal data do we use to do that: Identity, Contact, Profile, Usage, Marketing and Communications, Technical, Tracking
  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

• To deliver relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  • What types of personal data do we use to do that: Identity, Contact, Profile, Usage, Marketing and Communications, Technical, Tracking
  • Necessary for our legitimate interests (to promote our business and products/services, to develop them, to grow our business and to inform our marketing strategy).

• To prevent and detect unlawful acts.
  • What types of personal data do we use to do that: Identity, Contact, Financial, Transaction, Technical, Tracking
  • Why it is that we can do that: Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring). Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement. 

• To administer our business and keep proper records.
  • What types of personal data do we use to do that: All relevant data categories
  • Why it is that we can do that: Necessary to comply with a legal obligation. Necessary for our legitimate interests (to administer our business and keep proper records).

• In order to manage your REKKIE user in-app profile and in order to improve the REKKIE app in the future.
  • What types of personal data do we use to do that: Identity, Contact, Technical, Tracking,
  • Why it is that we can do that: Necessary to manage your profile and settings in our app. Necessary to help us improve the REKKIE experience with details about how you use our app (including the mobile network and operating system you use, so we can analyze how our app works and fix any issues, including mesh network connectivity and reliability). 

• In order to improve your REKKIE app user experience.
  • What types of personal data do we use to do that: Identity, Contact, Technical, Tracking,
  • Why it is that we can do that: We use your location and motion data to provide you and others with map-related and geo-location features (such as showing your location to others in your ski group or providing analytical and leaderboard data related to specific ski runs). This is necessary to process your motion and geolocation data to provide you with data to improve your experience.

8. Advertising, marketing, and your communication preferences

On our website, we make your direct marketing preferences clear. You may choose to opt in to receive our email newsletter, or as part of creating an account or buying a product. We may also send you a nudge as part of the purchase if you have left products in the basket without checking out. 

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. We may carry out direct marketing by email, phone, text and post. 

At all times you have a right to opt out of direct marketing. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication or just email us at info@rekkie.com.

We will get your express opt-in consent before we share your personal data with any outside company for direct marketing purposes. 

There are lots of different ways you’ll see adverts for REKKIE, and these may not be using your personal data. If you see REKKIE’s adverts on websites and in social media, these may not be directed specifically at you, we may just have bid for the space.

 We may also be using a search engine or social media platforms’ ‘retargeting’ products based on your browsing cookies or ‘lookalike’ products, which are not directed at you and which you can control using each search engine or social media platform’s privacy settings.

 We may use your details in a ‘hashed’ format as part of Facebook’s Custom Audience feature which enables us to pass your contact data in an anonymized (hashed) format to Facebook to create remarketing and ‘lookalike’ products to help us build similar audiences on their platform. In order to opt out of any lists used with Facebook’s Custom Audience feature, please contact us directly at info@rekkie.com.

 We use Tracking Data to deliver relevant online advertising, including on websites and in social media. Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to other potential REKKIE customers. The cookies used for this purpose are often placed on our website by specialist organizations – and this is also why when you’ve been on REKKIE website, you might see content from our website again. This is called retargeting. Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

If you want more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the European Interactive Digital Advertising Alliance and the Digital Advertising Alliance (United States). We do not control cookies which are set by advertising networks.

 9. Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following categories of cookies:

• Strictly necessary cookies. These are cookies which are needed to make the website work properly. They include, for example, cookies that enable you to log in, use a shopping cart or make secure payments.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). These also allow us to tell if you’ve left any products in your basket without checking out.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website relevant to your interests and for advertising and retargeting purposes. We may also share this information with third parties for this purpose.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
cart	Used in connection with shopping cart.
cart_sig	Used in connection with checkout.
cart_ts	Used in connection with checkout.
checkout_token	Used in connection with checkout.
secret	Used in connection with checkout.
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

Reporting and Analytics

Name	Function
_tracking_consent	Tracking preferences.
_landing_page	Track landing pages
_orig_referrer	Track landing pages
_s	Shopify analytics.
_shopify_s	Shopify analytics.
_shopify_sa_p	Shopify analytics relating to marketing & referrals.
_shopify_sa_t	Shopify analytics relating to marketing & referrals.
_shopify_y	Shopify analytics.
_y	Shopify analytics.

 

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

10. Disclosures of your personal data

We may share your personal data with the third parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it. 

We may share personal data with the following categories of third parties:

• suppliers and service providers (such as outsourced services partners, technology service providers, manufacturers and post and courier services);
• payment services providers, via Shopify (see below) – payment processors may take your personal data directly from you as part of processing a purchase, and they will be data controllers in their own right for that processing;
• auditors and professional advisers like bankers, lawyers, accountants and insurers; and
• government, regulators and law enforcement.

We share personal data with the following specific third parties:

• Shopify, who are the ecommerce platform we use for our website. The Shopify privacy policy tells you all the details you need to know about what information Shopify collect from you when you use our website or buy a Rekkie product, and how Shopify may use and share it when we use them to support us with processing orders, risk and fraud screening, authentication and payments. You can read the full Shopify privacy here; in particular see the section about Information from buyers. Shopify also carries out some automated decision making, for example screening IP addresses or payment information to block potentially fraudulent transactions for a short period of time. If you have any questions about the Shopify privacy policy you can contact them directly.
• Klaviyo: to send our direct marketing campaigns to prospective and current customers. You can read their privacy policy here.
• OpenPhone: to help us carry out customer support. You can read their privacy policy here.
• We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.

 

 We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

11. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

13. How to contact REKKIE about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at info@rekkie.com, use this form or write to us with your letter addressed to:

If you need help with our products and services, or this website generally, please contact us at info@rekkie.com. 

14. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

15. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

16. Change of purpose

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

17. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

• Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data: This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
• Request transfer of your personal data: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please see "How to contact REKKIE" above.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

18. Additional information and other privacy policies

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

• We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

• FACEBOOK - https://www.facebook.com/settings/?tab=ads
• GOOGLE - https://www.google.com/settings/ads/anonymous
• BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/