Privacy Policy Mavic INC USA

January 2024

Mavic Group Inc is committed to protecting your privacy and complying with applicable data protection and privacy laws. This Privacy Policy (“Policy”) is designed to help you to understand what kind of information we collect in connection with our products and services and how we process and use such information. Throughout this Policy the term “personal data” means information relating to an identified or identifiable individual (i.e., a natural person).

“Mavic” refers to Mavic Group Inc, including all its group companies, affiliates, and subsidiaries from time to time (also referred to as “we”, “us”, or “our”). Your personal data may be used in accordance with this Policy by and for one or more Mavic Group Inc companies, which will be regarded, individually or jointly, as data controllers in respect of such data.

This Policy applies to personal data collected in connection with products and services offered by Mavic or from other interactions with us where a link or other appropriate reference of incorporation to this Policy is made, for example, in connection with our products, websites, applications and other types of services offered by Mavic typically in electronic form, as well as other services such as customer care and warranty services, customer events, or promotions and campaigns.

We typically provide additional privacy related terms in connection with a particular Mavic product or service. Such product or service specific terms prevail over this Policy to the extent of any conflict. Our products or services may also contain links to other companies’ websites and other third-party services that have privacy policies of their own. We recommend that you carefully read the privacy policies of such services. Mavic is not responsible for the privacy practices or contents of any such third-party services.

Further information about our data practices in our services may be provided on our website and/or in our mobile application.

Where a consent from you to the processing of personal data described in this Policy is required under the applicable law, such consent will be obtained by appropriate mechanism such as ticking a box stating your consent, choosing technical settings for a service or website, or other statement or conduct clearly indicating your acceptance to the processing, depending on the product, website, service or application you are using. If you do not provide data required for the particular service or website feature you are intending to use or for transactions that you are trying to complete, such service or website feature may not be available, or transactions may not be completed without the required data.

DATA COLLECTED

We collect your personal data typically when you purchase our products or services, use or register into our services, enter into a sales promotion or a campaign, or otherwise interact with us. Below are examples of the categories of the data we collect on you.

Technical Information. For the most part, you may visit our websites or use our products or services without having to identify yourself. However, certain technical information is normally collected as a standard part of your use of our services. Such information includes, for example, your IP-address, access times, the website you linked from, pages you visit, the links you use, the ad banners and other content you viewed, information about your devices and other such technical information your browser provides us with or as may be otherwise collected in connection with certain products and services. When you use our services or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by the telecommunications operator as a standard part of that communication. Please also see the section “Use of Cookies and Web Beacons” below.

Information you provide us. When you register to our services, make a purchase, enter a sales promotion or otherwise interact with us, we may ask you to provide us with certain information such as your name, email address, street address, as well as user names, passwords and other such credentials that are used to authenticate users and to validate their actions or that may be needed to provide you with the products and services you have requested or to communicate with you, as well as information uploaded by you such as location, route information, pictures etc. We may collect training data, demographic information, for example, your age, gender, postal code, and language preferences.

THE PURPOSES OF PROCESSING

Mavic processes your personal data for the purposes described in this Policy and/or any additional service specific privacy information. Please note that one or more purposes may apply simultaneously.

Provision of products and services. We may process and use your personal data to provide you the product or service you have requested, fulfill your other requests such as customer service, process your order or as otherwise may be necessary to perform or enforce the contract between you and Mavic. We may also process and use your personal data to ensure the functionality and security of our products and services, to identify you, and to prevent and detect fraud and other misuses.

Development of products and services. We may process and use your personal data to develop our products and/or services. However, for the most part we only use aggregate and statistical information in the development of our products and services, and not data directly identifiable to you. We may also process and use your personal data to personalize our offerings and to provide you with service more relevant to you, for example, to make recommendations and to display customized content and advertising. We may combine personal data collected in connection with your use of a particular Mavic product and/or service with other personal data we may hold about you, except where such personal data was collected for a different purpose.

Communicating with you and marketing. We may process and use your personal data to communicate with you, for example, to provide information relating to our products and/or services you are using or to contact you for customer satisfaction queries. We may process and use your personal data for marketing. Marketing purposes may include using your personal data for personalized marketing or research purposes in accordance with applicable laws, for example, to conduct market research and to communicate our products, services, or promotions to you via our own or third parties’ electronic or other services.

In addition, some of our products and services may be used to promote products and services of other companies. However, Mavic does not disclose your personal data to such companies for their marketing purposes without your prior consent or other legal basis under applicable law.

Profiling/personalization. We may process and use your personal data for profiling/personalization for such purposes as targeted direct marketing and improvement of our products or services. We may also create aggregate and statistical information based on your personal data. Profiling/personalization includes automated processing of your personal data for evaluating, analyzing or predicting your personal preferences or interests in order to, for example, send you marketing messages concerning products or services best suitable for you.

TRANSFERS OF YOUR PERSONAL DATA

We may disclose and transfer your personal data to the parties below, and to other parties to the extent permitted or required by law.

Opting out from e-mail/SMS based marketing. You may opt-out from brand marketing e-mails by following the guidance in those e-mails (typically provided via “unsubscribe” link) or by contacting the respective brand/group company as set forth in the e-mail and in their web site. If you opt-out, we may still send you non-marketing e-mails, such as service notifications or other information or if you are a business customer, we may send business relation information. You may also opt-out from any SMS based direct marketing by contacting the respective group company/brand as set forth in their site or via SMS as may be applicable.

Service providers and other authorized third parties. We may transfer your personal data to authorized third parties who process personal data on behalf of Mavic for the purposes described in this Policy, such as e.g., technical, logistics, e-commerce, marketing, and other service providers. Such parties are not permitted to use your personal data for any other purposes than for what your personal data was collected, and we require them to act consistently with applicable laws and this Policy as well as to use appropriate security measures to protect your personal data.

International transfers. Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services, including to countries outside the European Economic Area (EEA), where the level of data protection may not be deemed adequate by the European Commission. In such cases we take steps to ensure that adequate protection for your personal data is provided as required by applicable laws. For international transfers of your personal data, we generally rely on agreements that are based on the Standard Contractual Clauses (“SCCs”) of the European Commission.

Other disclosures. We may disclose and otherwise process your personal data in accordance with applicable laws to defend Mavic’s legitimate interests, for example, in civil or criminal legal proceedings.

Mergers, Acquisitions, Business Transactions and Transfers. We may disclose and/or transfer your personal data to relevant parties such as prospective or actual purchasers and their advisers in connection with mergers, acquisitions, sales, reorganization, or other transactions or transfers or changes of control involving Mavic Group Inc and/or its group companies, services, applications, digital services, or businesses. We may also receive personal data from relevant parties such as sellers and their advisers, for the purposes of such transactions.

DATA QUALITY AND RETENTION

We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data.

We store your personal data only for a period necessary for the purpose in question or as long as required by applicable laws.

DATA SECURITY

Mavic implements appropriate technical and organizational security measures to prevent and minimize risks associated with providing and processing personal data.

Such security measures include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection of processors, sufficient training of Mavic‘s personnel involved in the processing, and other necessary measures to provide appropriate protection for your personal data against unauthorized use or disclosure. Where appropriate, we may also take back-up copies and use other such means to prevent accidental damage or destruction of your personal data. If a particular part of a Mavic website supports on-line transactions, we will use an industry standard security measure, such as the one available through “Secure Sockets Layer” (“SSL”), to protect the confidentiality and security of online transactions.

YOUR RIGHTS

You have the right to request information and access to the personal data we have collected from and of you. You also have the right to request that we replenish, rectify, anonymize or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with binding legal obligations or if the personal data must be retained according to applicable laws. You have the right to request and receive the personal data we have collected on you in a commonly used and machine-readable form. In case you consider your personal data collected by us to be inaccurate, you do not wish your personal data to be deleted where the processing of your personal data has been deemed unlawful or the personal data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.

You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.

In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this Policy. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you. We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it.

Please note that Mavic may need to identify you and to ask for additional information in order to be able to fulfill your above requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.

COMPLAINT TO THE SUPERVISORY AUTHORITY

In the event you consider Mavic’s processing activities of your personal data to be inconsistent with the applicable data protection laws or that Mavic has not sufficiently ensured the realization of your rights, you may lodge a complaint with the local supervisory authority responsible for data protection matters.

THE CONTROLLER OF YOUR PERSONAL DATA AND CONTACT DETAILS

The data controllers responsible for the purposes of the applicable data protection laws are, as applicable:

1) Mavic Group SAS

Parc, 44 Rue Saturne, Av. Altaïs,

74650 Chavanod, France

and/or

2) The Mavic Group Inc company, whose webpage, application, product, or service you are using (name and registered address available during the purchase or registration process)

and/or, as applicable,

3) The Mavic Group Inc company which uses your personal data for its direct marketing or similar purposes (name and registered address available in the marketing material received by you).

CHANGES TO THIS PRIVACY POLICY

Mavic may from time-to-time update and change this Privacy Policy. If the changes include new purposes of processing, Mavic will give you prior notice of such changes and, where necessary, request your consent.

CALIFORNIA RIGHTS

CALIFORNIA RESIDENTS (California-Specific description of privacy rights – under the California Consumer Privacy Act – CCPA). This section fully incorporates all the above stated Privacy Policy as if fully set forth below and your rights under the CCPA are intended to supplement the rights set forth therein.

RIGHT TO KNOW / ACCESS

California residents have the right, (upon a verifiable request) to request the following:

(1) The categories of personal information we have collected about you.

(2) The categories of sources from which personal information is collected.

(3) The business or commercial purpose for collecting or selling personal information.

(4) The categories of third parties with whom we share personal information.

(5) The specific pieces of personal information we have collected about you.

Please note that the Mavic group company may need to identify you and to ask for additional information in order to be able to fulfill your request. We will acknowledge your request within 10 days. Upon verification of your identity, we will fulfill your request. However, we will not provide any information that we reasonably believe may be subject to fraudulent action.

California residents have the right to request deletion of their personal information collected or maintained by Mavic.

DO NOT SELL MY INFO

You have the right, at any time to direct a business that sells personal information about you to third parties not to sell your personal information. This is the right to opt-out of sale. The meaning of “sell” under the CCPA is broadly defined and can include sharing your information for any economic benefit.

Mavic shares your information with service providers and other authorized third parties as set forth in the Privacy Policy above. To the extent that any such third party is not considered a service provider under the CCPA or the CCPA is interpreted in a way that any action of Mavic is a “sale”, is “selling”, or otherwise deriving an economic benefit from the sharing of your personal information as described in this Privacy Policy and to the extent that you wish us not to share such information, please submit your request using the methods listed below.

Please note that the Mavic group company may need to identify you and to ask for additional information in order to be able to fulfill your request. We will acknowledge your request within 10 days. Upon verification of your identity, we will fulfill your request. Be advised, that a request of “Do Not Sell My Info” will result in the deletion of all information that the Mavic Group Inc company has on file about you.

RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF YOUR CALIFORNIA PRIVACY RIGHTS

Discrimination – You have the right not be discriminated against because you exercised any of your rights under California law.

AUTHORIZED AGENT

You have the right to designate an authorized agent to make any CCPA request on your behalf. Mavic reserves the right to ask for proof that such agent is in fact authorized by you.