We, Powering Real Riders S.L., adress Cerros de Navalcón 142, Collado Villalba, Madrid (Spain), are committed to protecting privacy of users of the Powering Offroad website, Powering Offroad application(s), and other related services (hereinafter collectively the “Powering Performance Services” or the “Services”).
Last revised: June 2019
1. What types and categories of data we collect, process and use?
We collect, process and use personal and non-personal data.
1.1 Personal and non-personal data
The term “personal data” is defined by the Federal Data Protection Act (BDSG) and the European General Data Protection Regulation (GDPR). You can think of your personal data as any data that allow you to be identified or that can be correlated to you.
On the other hand, “non-personal” data cannot be correlated to any specific person. By removing identifiable parts from and anonymizing personal data, personal data may be converted into “non-personal data.”
1.2 Data we collect, process and use
We collect, process and use three (3) types of data:
- data you provide to us voluntarily,
- data we receive when you use our Products or Services, and
- data we receive from third parties.
We collect, process and use the following categories of data:
- your name and address;
- your personal contact information (telephone, e-mail, etc.);
- your username and password;
- your user profile data (e.g., workout schedule, racing events, motorsport category, etc.);
- your user preferences (e.g., preferred language settings);
- your IP address, operating system, browser type, browser version, browser configuration, name of Internet provider, and any other relevant information regarding your computer and Internet connection in order to identify the type of your device, to connect you to the website, to exchange data with your (mobile) terminal device, or to ensure proper use of the website and an Powering Offroad application;
- the URL and IP address of the website from which you access our website or from which you are transferred to our website, including date and time;
- any pages of our website on which you click during your visit, and any links on our website on which you click, including date and time;
- the entire Uniform Resource Locator (URL) clickstream regarding, through, and from the website, including date and time;
- your service inquiries and your orders;
- your transaction history, including open and completed transactions;
- search terms you input in relation to or within our Products and/or Services;
- information regarding your orders and payments;
- information collected by cookies or similar technologies (as explained below);
- your survey answers, critiques, evaluations, or other responses;
- the content of all messages sent through the website or an Powering Offroad application, including information uploaded to social networks through the website or an Powering Offroad application or otherwise shared with us and/or other users, as well as chat messages and chat logs;
- information about workouts you upload or download using an Powering Offroad application;
- your newsletter subscriptions;
- any consents you have given us;
- any other information input or uploaded by you through the website or an Powering Offroad application (e.g., information you provide when completing an online form, photos you upload to the app, photos you share to the riders community, etc.); or
- data we receive when you log in through social media (e.g., if you log in with Facebook).
2. How is data collected?
Personal data is collected by us only if you provide such data to us on your own initiative by choosing to use our Products and/or Services. To be able to use our Products and/or Services, you must register your account with us.
You may create an Powering Offroad user account through our login system. Following registration, you will be able to use your user account to subscribe to all Powering Offroad Services. To register, you must provide us with at least the following information:
- first and last name,
- e-mail address, and
2.2 Adding information to your user profile
Powering Offroad application(s) also enable you to provide us with additional information, such as your fitness level, and workout goals. After registering, you can add more information to your profile (e.g., a profile photo) (not available in this version). If you do so, you will once again provide us with personal data. We will also receive data (including personal data) from you when you communicate with us or other users through an Powering Offroad application. If you practice a workout schedule, we will receive information about which and how many workouts you have completed. We will also receive information about how you use Powering Offroad application(s), your progression through the levels and your feedback registration after every workout session. In that case, too, you will provide us with personal data.
2.3 Enabling access rights to your device
For you to be able to use an Powering Offroad application to the full extent, we will also need certain access rights to your smart phone. For example, we need access to your camera or your photos if you upload or want to change a profile photo (not available in this version). We use push messages to send you workout reminders or to notify you of new followers or comments. When you want to use such a function for the first time, we will ask you whether you grant us such access rights or we will ask you to grant us access by selecting the appropriate settings. Generally, you may revoke such access rights at any time by changing the appropriate settings according to your preferences.
You can register for our Newsletter. That way, you will receive regular updates about the Powering Offroad Products and/or Services. All you need to receive our Newsletter is to provide us with a valid e-mail address. If you are no longer interested in receiving the newsletter, you may unsubscribe at any time, for any reason and without any cost, using the link that is included in each Newsletter.
2.5 Linking your account to Facebook
You can also link your Powering Offroad user account to your Facebook profile. To do so, simply choose “Login with Facebook” during the registration process; you will then be transferred to Facebook. There, you will be shown to which Facebook data we will receive access. We will store your Facebook e-mail address. This is the e-mail address we will use to contact you, if necessary. We will also record the fact that you have registered through Facebook.
You will also transfer certain information to us when you access our website or Powering Offroad application(s), e.g., your IP address. We will also receive data about which terminal device (computer, smartphone, tablet, etc.) you are using, which browser (Internet Explorer, Safari, Firefox, etc.) you are using, the time at which you access the website, the so-called referrer, and the data volume transferred. Such data cannot be used by us to identify the user. This data is processed for statistical purposes only. Such analyses help us make our Services more attractive and, if necessary, to improve our Services.
2.7 Log files
Every time you access our website the aforementioned data will be automatically stored in log files. A log file automatically logs all or defined actions on a computer system. Such log files are important, for example, for process control and automation. In the case of databases a log file tracks changes to the database of correctly executed transactions. In the event of an error (e.g., a system crash), this allows the current dataset to be restored. Log files are also created by web servers. Inter alia, the following data are logged: the address of the accessing computer, authentication fields, date and time of access, access method, content of HTML access, status code of the web server, and information about the browser and operating system used by the client.
2.8 Other possible instances of data collection
Collection of data also happens, for example, when you contact us or other users, i.e., when you open your Powering Offroad user account, sign up for a subscription, upload a profile photo, or use our Services to send messages.
3. What are our legal bases for processing of your data?
We will collect, process, and use your personal data and other data to support the delivery of Powering Offroad Products and/or Services in accordance with our General Terms and Conditions. In this section we provide information on the legal basis for our processing of your Personal Data as required by Art. 13 and 14 of the GDPR, as well as provide detailed information about the purposes of collection, processing and use of your data.
We process your data based on the Article 6 of the GDPR relying on the following legal bases:
- performance of our Services, Art. 6(1)b
- legitimate interest relating to our Services, Art. 6(1)f
- if you have given us your consent to process your data, Art. 6(1)a
- if it is necessary for us to comply with a legal obligation Art. 6(1)c.
We may also process the data if it is necessary to protect vital interests of our users and/or other people, or for the performance of an obligation to carry out in the public interest pursuant to Art. 6(1) (d) and (e).
4. What do we use your data for (purposes of processing)?
We process and use data (including personal data) you make available to us voluntarily on the website or through the Powering Offroad application in various situations (e.g., when you send us an e-mail). We also use data that are collected automatically on our website or through the Powering Offroad application. Finally, we may also receive data about you from third parties, for example when another user provides us with information about you through the website, subscription form application or by send us an e-mail.
We collect, process and use data for the following purposes:
- to administer, operate, maintain, and improve the website and Powering Offroad application(s);
- to allow and process orders for services placed by you through the website or Powering Offroad application(s);
- to customize your experience in relation to our website or Powering Offroad application(s) (e.g., by tailoring content and offers to your personal preferences, motorsport practice, training level, racing events, etc.);
- to assess your right to receive certain types of promotions, offers or services;
- to support the improvement and customization of the Powering Offroad Products and/or Services;
- to analyze and research customer behavior;
- to respond the questions and inquiries you voluntarily send us;
- to provide you with information about new products and/or services that may be of interest to you;
- to communicate with you about certain concerns;
- to manage awards, surveys, winning games, lotteries, or other promotional activities or events;
- to comply with our legal obligations to prevent any unlawful use of the website or Powering Offroad application(s), to protect the security of our Services, to detect and prevent fraud or abuse, to settle disputes, and to enforce our contracts;
- for any other purposes to which you have consented in a particular case, or
- otherwise as permitted by applicable law.
If required by law, we will ask for your consent before collecting, processing, or using your personal data for any of the aforementioned purposes.
We will also notify you if we want to use your personal data for a new or different purpose. We will use your personal data for such other purposes only if and to the extent necessary or permitted by applicable law or with your consent.
5. How long and where are data stored?
Your personal data will be stored for as long as this is necessary for achieving the defined purposes of processing. If you cancel your user account, we will also erase within reasonable time or archive your personal data, i.e. restrict processing. An exception applies only if we have a legal obligation to archive data for a certain time period.
6. Cookies and tracking pixels
We collect information about visitors to our website and about users of our Powering Offroad application(s) in order to improve our Services. For this purpose we use different kinds of so-called cookies and tracking pixels (a.k.a. web beacons).
Websites that include flash media write user-specific data to your computer and later read such data. Such files are called flash cookies or local shared objects (LSO). Such files are not managed by your browser, but rather by the flash player plug-in. Flash cookies are subject to the same rules as conventional cookies. Flash cookies, too, can only be read by the website that caused those flash cookies to be placed. However, flash cookies can store a substantially greater volume of data.
Your browser offers extensive setting options to manage cookies. For example, you can deactivate cookies in your browser or limit cookies to certain websites. You can also program your browser to first notify you before a cookie is placed. You can also choose these settings on your mobile terminal devices. You can at any time manage cookies by changing the settings of your devices, delete cookies, or block cookies altogether.
You can also visit our website even if you block cookies on your terminal device. If you block cookies, the display of our website may however be impaired and not all functions may be available to you. You can also use Powering Offroad application(s) without cookies. In that case, you may however no longer be able to use all functions of such application as conveniently.
Tracking pixels are small graphics in HTML e-mails or on websites. When you access such a website, your access to the tracking pixel will be recorded in a log file. This allows statistical analysis, which, in turn, can be used to improve our Services. You can set your e-mail program or your browser so that HTML e-mails will be displayed as text only, thereby preventing the use of some tracking pixels.
7. Transfer of data to third parties
Your personal data will be transferred to third parties only if we have a legal obligation to do so, if the data transfer is necessary for performance of the contract, or if you have consented to the transfer of your data. Third-party service providers and partner companies will receive your data only if and to the extent necessary for performance of the contract or with your consent. In such cases, the extent to which data are transferred will however be kept to the absolute minimum. To the extent that our service providers come into contact with your personal data, we will make sure that they too will comply with all applicable data protection laws. Please also read the data privacy policies of such third-party providers.
We use cloud services. This means we will transfer your data to a third party – the cloud services provider – and store data on the servers of that provider. In some cases, your data may also be stored on servers outside the European Union (EU) or European Economic Area (EEA). In some cases, your data may also be processed there. We either ensure through appropriate contracts that such service providers guarantee the same level of data privacy to which you are also entitled in the European Union or we use only providers that are EU-US Privacy Shield certified (https://www.privacyshield.gov/welcome). Either alternative ensures an appropriate level data privacy.
8. Data processing – third-party services and partners
To be able to offer you all functions and services of Powering Offroad application(s) in the most convenient way possible and to be able to continuously improve our Products and Services, we use third-party services and partners. We also use the assistance of third parties to improve our website. Finally, we use certain tools and resources for our marketing campaigns.
Below is the description of the third-party services we use and for what purposes:
We use a number of different Google services (Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043, U.S.A. – hereinafter “Google”) for analysis and marketing purposes. These tools collect and statistically analyze data about your use of our Services in different ways. We also use your data to show you personalized ads with the help of Google services. By using our website or our Powering Offroad Services, you consent that we may use your data for these purposes.
Below (in 8.1.1-8.1.6) we will explain the different services and the ways in which you can to conveniently revoke your consent, and we provide you with additional important information.
Additional information about how Google handles data transmitted by us is available here: https://www.google.com/intl/de/policies/privacy/partners/.
Information generated by Google tools is generally transferred to a server of Google in the United States and stored there. Google and its subsidiaries are EU-US Privacy-Shield certified.
8.1.1 Google Analytics
You can prevent the collection and processing of information generated by the Google cookie by placing an opt-out cookie or deactivating Google Analytics in the menu of your terminal device. In the alternative, you can also install a browser plug-in, which you will find here: https://tools.google.com/dlpage/gaoptout/.
8.1.2 DoubleClick by Google
If you do not wish to receive personalized ads, you can place an opt-out cookie: https://www.google.de/settings/ads/onweb#display_optout
You can also install the DoubleClick deactivation browser add-on. You will find this browser plug-in here: https://www.google.com/settings/ads/onweb/
8.1.3 Google AdWords
We use Google AdWords to advertise our offers. Following a search on Google, our ads will be shown in the areas designated for this purpose. Our website registers with the help of cookies how many users have found our Services through such ads. We use such data to optimize our ads. A cookie is stored by Google when an ad is clicked. You can block the cookie by selecting the appropriate settings in your browser. In that case, your visit to our website will not be included in anonymous user statistics.
If you do not wish to receive personalized ads, you can place an opt-out cookie: https://www.google.de/settings/ads/onweb#display_optout
You can also block cookies, for example, by installing an appropriate browser plug-in, which is available here: https://support.google.com/ads/answer/7395996?hl=de
8.1.4 Google Dynamic Remarketing
If you do not wish to receive personalized ads, you can place an opt out cookie: https://www.google.de/settings/ads/onweb#display_optout
You can block personalized ads by installing the appropriate browser plug-in, which is available here: https://support.google.com/ads/answer/7395996?hl=de
You can also block personalized ads from Google and other advertising networks by opting out on the following page: https://www.youronlinechoices.com/de/praferenzmanagement/
Firebase is a Google subsidiary with its registered office in San Francisco, CA, U.S.A. We use Firebase SDK and Google Analytics for Firebase for our Powering Offroad application(s). This tool allows us to use the same Google Analytics functions for an application that can also be used for websites. Firebase uses technologies that work similar to cookies, in particular advertising IDs. This way, we collect information about how you use the Powering Offroad application(s). We use such data for statistical analysis purposes, to test our offers (e.g., A/B testing), and to improve our offers. In addition, we use such information for personalized advertising. By using our Services you consent to our collection of such data. In addition, we use Firebase Remote Config to make changes to our Powering Offroad application(s).
If you do not wish that such data is collected, you may opt out at any time. You can conveniently do so, for example, by selecting the appropriate settings in your mobile terminal device. How you can prevent such data from being collected on your Android device is explained, for example, here: https://www.google.com/policies/technologies/ads/
On your iOS device you will find the appropriate setting under Settings > Data Privacy > Advertising.
We use Crashlytics to analyze the application stability of our Powering Offroad application(s). Crashlytics is a subsidiary of Google. Crashlytics delivers analyses of errors and system crashes in real time, thereby facilitating maintenance of the application. In the process none of your personal data will be transmitted, but only crash reports with information about register codes and your device, e.g., type of device and version of operating system.
The diagnostic data collected are processed in the United States. Like Google and other subsidiaries of Google, Crashlytics is EU-US Privacy Shield certified.
8.2 Social plug-ins
We use the following social plug-ins for our website:
- Facebook(operator: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, U.S.A.)
- Instagram(operator: )
- Google+ (operator: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S.A.)
These plug-ins routinely collect data from you and transfer such data to servers of the provider.
- Facebook: https://www.facebook.com/policy.php
- Google+: https://www.google.com/intl/de/privacy/
8.2.1 Facebook Connect
We use the “Facebook Connect” function, so that you can register and log in with us using your Facebook account.
If you use Facebook Connect, Facebook profile data and public data from your Facebook profile will be transferred to us. Conversely, data may be transferred from us to your Facebook profile. Such data are used by us to register you on our website or for Powering Offroad application(s) or to allow you to log in. For this purpose we also store and process such data.
By registering on our website or for an Powering Offroad application with the help of Facebook Connect you consent that your profile data from your Facebook profile may be transferred to us and, conversely, that we may transfer data to Facebook.
Please also note that Facebook receives information through Facebook Connect about how you use our Powering Offroad application(s) and our website.
Powering Offroad application(s) and our website use the Adjust service of adjust GmbH (Saarbrücker Str. 37A, 10405 Berlin). The Adjust service has been audited and certified in accordance with the ePrivacyseal (European Seal for Your Privacy) (see https://www.eprivacy.eu/vergebene-siegel/).
This service allows us to monitor our marketing performance, to adjust our advertising campaigns, and to better understand, overall, how you use our application. To achieve this goal, we can, inter alia, monitor in real time how you interact with our application. For this purpose Adjust, for example, collects your IP address in anonymous form (as a hash value), and tracks when you install and open Asana Rebel application(s) for the first time, how you interact with the application, or on which ads you click.
Once collected, such data are not merged with any other data for personal identification purposes.
You may choose at any time that such data shall no longer be collected in the future. If so, please simply use the opt-out option of adjust at https://www.adjust.com/opt-out/.
Amplitude is an analysis service of Amplitude Inc (631 Howard Street, Suite 300, San Francisco, CA 94105, U.S.A.). This tool collects technical information, such as the type of your device (e.g., iPhone 6), the operating system used (e.g., iOS 10.3), or the name of your provider (e.g., Vodafone). In addition, Amplitude tracks events that occur in our Powering Offroad application(s). Such events may, for example, be completed workouts. In other words, Amplitude helps us understand how you use our Services.
Data collected by Amplitude Inc. in the United States is transferred to servers of Amplitude Inc. in the United States, where they are stored. Amplitude is EU-US Privacy Shield certified.
You will find additional information about the manner in which Amplitude processes data at: https://amplitude.com/privacy.
8.6 Facebook Custom Audiences
We use the remarketing function “Custom Audiences” of Facebook Inc. (1601 Willow Road, Menlo Park, California 94025, U.S.A.). This function allows us to show visitors of our website and users of Powering Offroad application(s) interest-based ads when they visit Facebook (“Facebook ads”), and to analyze such Facebook ads for statistical and market research purposes, which helps us optimize future advertising. For this purpose we use the so-called Facebook pixel (website) and Facebook SDK (Powering Offroad application).
Such data may allow Facebook and its partners to show ads on or off Facebook.
Facebook generally also stores such data on servers in the United States. Facebook is EU-US Privacy Shield certified.
You can generally block the placement of cookies on your computer by selecting the appropriate settings in your browser, so that cookies will no longer be placed on your computer in the future and/or so that cookies that have already been placed will be deleted. If you do so, you may no longer be able to correctly use some functions on our website.
With the help of an appropriate opt-out cookie from Digital Advertising Alliance you can also completely deactivate advertising by third-party providers such as Facebook: https://www.aboutads.info/choices/
In the alternative, you can deactivate the remarketing function “Custom Audiences” in your Facebook settings: https://www.facebook.com/settings/?tab=ads#_=_
To do so, you must be registered with Facebook.
We use Greenhouse Software, Inc. (18 West 18th St, 9th Floor
New York, NY 10011, U.S.A.), an applicant tracking system and recruiting software.
If you are a candidate interested to work at Powering Offroad, you will be redirected to the Greenhouse suit either through our website’s career section, or if you are applying through a recruiter or by ways other than through our website, your data may be shared with Greenhouse Software, Inc.
When you apply to a job through an online application form or by sending us your CV, the personal data contained in your application will be collected and processed for the purposes of managing our recruitment related activities, which includes setting up and conducting interviews and evaluating and assessing the results. The legal basis for the processing of your personal data in this application process is permissible under Art. 6(1) (b) of Regulation (EU) 2016/679 (General Data Protection Regulation).
Greenhouse Software Inc. is our software provider for the application process and in the context of system maintenance and support, may also become aware of your personal data. For the purpose of application management, your data is being stored and processed on servers of Greenhouse, located in the USA.
In the event of a rejection, your personal data will be deleted after 12 months. Under the GDPR, you have the right to request access to your personal data, to request that your personal data be rectified or erased, and to request that processing of your personal data be restricted.
You will find additional information about the manner in which Greenhouse processes data at: https://www.greenhouse.io/privacy-policy.
9. Data security
Data transfers are generally subject to security gaps. It is technically impossible to protect your data 100% from access by third parties. However, we strive to minimize this risk as much as possible. We therefore maintain state-of-the-art measures to guarantee data security and to protect your data from access by third parties. In addition, we use strong SSL or TLS encryption for all data transfers. However, please make sure not to provide your login data to any third parties.
10. Websites of third parties
12. Your rights: information, revocation, erasure and data controller
You may at any time and at no cost request us to provide you information about your personal data that are processed by us, correction of any errors in your personal data, termination of processing of your personal data, or erasure of your personal data – subject to mandatory legal provisions or obligations to the contrary. In particular, if you qualify as the “data subject” under the terms of (GDPR), you have the right to:
- request information on personal data processed by us about you as provided by Art. 15 GDPR.
- in accordance with Art. 16 GDPR, to immediately demand the correction of incorrect data or completion of incomplete personal data stored with us;
- pursuant to Art. 17 GDPR, to request deletion of your personal data stored by us, unless the processing of the data is required for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
- in accordance with Art. 18 GDPR, to request the restriction of the processing of your personal data as far as the accuracy of the data is disputed by you or the processing is unlawful;
- in accordance with Art. 20 GDPR, to receive your personal data provided to us in a structured, standard and machine-readable format or to request transmission to another controller;
- in accordance with Art. 7 (3) GDPR, to revoke at any time your consent previously granted to us. As a result, we will be no longer able to continue the data processing based on this consent for the future;
- in accordance with Art. 77 GDPR, users have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or work or our company headquarters for this purpose.
- also, if your personal data is processed based on legitimate interests in accordance with Art. 6 (1) (f) GDPR, you have the right to file an objection against the processing of your personal data in accordance with Art. 21 GDPR, provided that there are reasons based on your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right of objection, which shall be implemented by us without you specifying any particular situation.
13. Contact details of the Data Controller and Data Protection Officer
To exercise your rights under GDPR, simply contact us at any time by letter or e-mail at:
Powering Real Riders S.L.,
Cerros de Navalcón, 142 Collado Villalba (28400)
E-mail: Customer Support
Managing directors: Andrea Mañas.
Recorded in the Commercial Register
Legal administrator company: Pachi Guzmán.
VAT ID: _________
External Data Protection Officer ________
For all request concerning the security of your data you can contact our data protection officer at firstname.lastname@example.org.
Please note that communications by email can always be flawed by security gaps. Therefore, if you have a particularly sensitive request, please contact our data protection officer by postal mail.