We (‘Zero Motorcycles’, ‘Zero’, ‘we’ or ‘our’) respect your privacy and value your trust in us. Our website at www.zeromotorcycles.com and our mobile application are operated by Zero Motorcycles, Inc (United States). Our registered office is at 380 El Pueblo Road, Scotts Valley, CA 95066, United States of America (“USA”).
For the purpose of the relevant data protection legislation, we are the data controller. This means that we are responsible for deciding how we hold and use personal information about you.
Zero Motorcycles, Inc. (USA) has appointed Zero Motorcycles B.V. (the Netherlands, Europe) as its European (privacy) representative. The European representative of Zero Motorcycles can be contacted using the contact details outlined below.
- What information does Zero collect?
- How does Zero use your personal data?
- How long does Zero keep my information?
- Reviewing or removing personal information
- Zero’s security measures to protect personal information
- Transferring information outside of the EU
- Links to other websites
- What about cookies?
- Does Zero share my information?
- Children’s privacy
- How do I contact Zero Motorcycles?
What information does Zero collect?
Website usage statistics
When you visit our website, we collect information sent to us by your computer. This data includes language and locale preferences and standard web log information, including your IP address, browser information, operating system, geographical information, the duration of your visit, web pages you accessed with the corresponding time and date, navigation paths you follow and referral sources. Your personal data may be shared with our data processors, such as, but not limited to, Salesforce, Google, Facebook and Amazon.
We use this information to understand how people are interacting with our website in order to improve our products and services. Web server log information is retained for six months. Website usage data shared with our data processors will be retained for the period necessary to fulfill processing purposes as described below. We have a legitimate interest in processing this information to provide our services to you, and to continuously improve our website and related services.
Website form submissions
When you signup for our newsletter, request a demo ride, a quotation or contact us with a question or concern, we collect personal information you provide us with. This may include your first name, last name, email address, (mobile) phone number, street, city, state, country, postal code, product interest, questions and whether or not you want to subscribe to our newsletter. The Zero Motorcycles Dealer Application form also includes details about your business, such as your company name, DBA information, fax number, offered motorcycle brands, financial information, facility information, and other data.
When you submit a form, we record how you got to our site (e.g. email link, search terms, ad campaign, referral site, etc.). Previous and subsequent website visits may be connected to your form submission information. Your personal data may be shared with dealers, distributors and Zero Motorcycles personnel.
We use this information to respond to your inquiries and process requests, to understand how people are introduced to Zero Motorcycles and how the customer experience evolves over time. We will retain your personal data for the period necessary to fulfill processing purposes as described below. We have a legitimate interest in processing this information to provide our (marketing) services to you, and to continuously improve our customer service.
When you apply for employment at Zero Motorcycles, we collect personal data (that you provide). We will retain your employment application and related data for the period necessary to fulfill processing purposes as described below.
Processing this information is necessary for the performance of a (possible employment) contract, compliance with a legal obligation (if entered into an employment agreement) and for our legitimate interest to invite applicants with the intended purpose of employing them.
Motorcycle Ownership Information
When you purchase a new Zero Motorcycles motorcycle from a dealer or a distributor, we require them to submit your contact information so we can confirm the start of the warranty period and so that we can send you pertinent service updates should the need arise. In addition, as Zero Motorcycles announces new accessories or other products that might be used with your motorcycle, we will use this information to keep you updated. This information is stored at our data processor Salesforce.
Ownership history of our motorcycles is kept for the period necessary to fulfill processing purposes as described below. We may contact prior owners should the need arise. For example, while the current owner is supposed to contact us to transfer ownership via our website, we regularly are contacted by the new owner. Should we discover a motorcycle was stolen, we have the ability to contact the previously registered owner. Processing this information is necessary for the performance of our (service) contract, compliance with legal obligation (i.e. to warrant driving safety) and for our legitimate interest to provide our services to you, and to continuously improve our products.
Service Request Information
When you contact our customer service team via email, phone or through the owners resources customer service form on our website, we will initiate a Technical Case associated with the motorcycle to track and gather associated information needed to respond to the request. Notes from the phone conversations, the text of the emails and any attachments provided are saved with this case. We retain this information through data processor Salesforce for the period necessary to fulfill processing purposes as described below. Processing this information is necessary for the performance of our (service) contract, compliance with legal obligations (i.e. to warrant driving safety) and for our legitimate interest to provide our services to you, and to continuously improve our products.
Zero Motorcycles App Data
The Zero Motorcycles App gives you the ability to email diagnostic information to the Zero Motorcycles Customer Service Team. This will include information identifying the motorcycle such as VIN, the motorcycle’s settings (such as model, sprocket sizes) and information from your motorcycle’s event and error logs, which includes times and dates of rides along with the motorcycle performance data during these rides: speeds, temperatures and charging events. Statistical data about your ride and usage of the app, including but not limited to distance travelled, average speed and energy consumption may also be submitted. If you choose to email the bike log information to Zero Motorcycles, it will be associated with your motorcycle and its ownership information. This information is immediately shared with the dealer that originally sold the motorcycle and Zero Motorcycles personnel.
We use this information to resolve issues with your motorcycle and to improve product quality. We retain this information through data processor Salesforce for the period necessary to fulfill processing purposes as described below. Processing this information is necessary for the performance of our (service) contract, compliance with legal obligations (i.e. to warrant driving safety) and for our legitimate interest to provide our services to you, and to continuously improve our products.
The Zero Motorcycles App includes technology from Flurry Analytics which provides us with information about usage patterns and helps us determine the best areas for improvement. Flurry also records the types of devices and operating systems used, general geographic information, as well as events that occur within the Zero App, such as how often it is used and other anonymous data.
Zero Motorcycles Cellular Connectivity Module Data
The Zero Motorcycles Cellular Connectivity Module gives you the ability to record rides, locate your motorcycle, receive an alert when bike charging is complete, receive an alert if your bike has tipped over or is moved, update your motorcycle firmware, and record bike health information. We use this information to provide you with aforementioned functionalities, resolve issues with your motorcycle, warrant your driving safety and improve product quality.
When in use, the Cellular Connectivity Module collects motorcycle identification information (such as the VIN), motorcycle settings (such as model and sprocket sizes) and motorcycle event and error logs, which includes information concerning rides along with motorcycle performance data during these rides, such as: speeds, temperatures and charging events. GPS locations are collected during recorded rides, if the movement alarm has been triggered, and for the purpose of the Find My Bike feature. Information about your ride, including but not limited to distance travelled, average speed, and energy consumption may also be collected.
When in use, Cellular Connectivity Module data is automatically and continuously transmitted to Zero Motorcycles over the cellular network with its own encryption and authentication. Additionally, a second layer of encryption is implemented on the Cellular Connectivity Module using XXTEA with a 128-bit key. We retain this information through data processor Starcom Online for the period necessary to fulfill processing purposes as described below.
The Cellular Connectivity Module and associated data transmission is initially deactivated on new motorcycles and must be enabled for access to features such as Relive and Share Ride, Find My Bike, and alert notifications. For activation, first download and install the Zero App, available from Google Play or the App Store, then review and agree to the consent terms. If you do not agree, you will not be able to continue with app installation and will only lose functionality associated with the Cellular Connectivity Module. All other Zero App functionality is alternately available either on the bike itself, through the Zero Motorcycles website or through a dealer.
You may withdraw consent and disconnect the Cellular Connectivity Module at any time by selecting “Deregister” from the Zero App interface. After the deregister action is communicated to the Cellular Connectivity Module, data transmission will cease. Existing data associated with your motorcycle will be kept for the remainder of the retention period.
When You Don’t Provide Information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. We will notify you (of the possible consequences) when you do not provide us with the requested information necessary to perform the contracts we have entered into with you.
How does Zero use your personal data?
We process your personal data based on the following legal grounds:
- for the performance of a contract (for example by subscribing to our newsletter);
- for the purpose of our legitimate interests. These legitimate interests include:
- marketing purposes;
- creating reports and analyzing data to improve our services;
- sending invoices and taking actions to recover a debt;
- securing and administration of our digital systems (including hardware and software);
- for compliance with legal obligations (if necessary);
- your active consent.
We process your personal data for the following purposes, based on the noted legal grounds:
|For cont(r)act purposes:|
|A||the execution of the service agreement.|
|A, B1||to connect you with a nearby Zero Motorcycles dealer if you are interested in signing up for a demo ride or making a purchase.|
|B1||to approach you to promote our services and activities.|
|A, B1, B3, C||to contact you via email, message or phone.|
|A, B1, B3, C||responding to questions, comments, and the processing of complaints.|
|A, B1, C||to send promotional or communication materials which may include making limited personal information available to third parties.|
|For operating and optimization website purposes:|
|B1, B2, B4||to understand how people are using our websites and related services and to improve our website.|
|B1||matching our services, content, and advertisements with the interests of website users.|
|A, B1||to answer any questions or concerns you may have about our products, services, and website.|
|For (product) quality and experience improvement purposes:|
|A, B2||to resolve issues with your motorcycle and to help us improve product quality.|
|D||to give you the possibility to record your rides and locate your motorcycle.|
|B2||to improve our products, services and customer communications.|
|For employment and partnership purposes:|
|A, C||to process your application in becoming a Zero Motorcycles Dealer.|
|A, C||to process your job application.|
|C||to send invoices and process (corresponding) payments.|
|B3||to take action to recover a debt.|
|For compliance with legal requirements:|
|B2, B3, B4||to facilitate legal proceedings and to prevent those, specifically those directed against Zero Motorcycles, its clients or staff, as well as taking part in warning systems which are used to prevent fraud and to control credit risk.|
|A, C||to send you important updates about products that you have purchased. These updates are for your benefit only and are not marketing related.|
We may process your personal data for other purposes that are not considered to be incompatible with the initial purpose for which your personal data has been gathered.
How long does Zero keep my information?
Reviewing or removing personal information
Under certain circumstances, you have the legal right to: (i) request access to your personal data; (ii) request the rectification of your personal data; (iii) request the erasure of your personal data; (iv) request the restriction of processing of your personal data; (v) object to the processing of your personal data where Zero Motorcycles relies on a legitimate interest; (vi) withdraw your consent to specific processing for which consent has previously been provided, without affecting the lawfulness of processing based on consent before its withdrawal; and (vii) request the transfer of your personal data to a third party.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if any request made by you is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. All requests will be executed in accordance with the law, subject to legally available exceptions, within four weeks. If you want to exercise any of the above rights, please contact us by using the contact details below.
380 El Pueblo Road
Scotts Valley, CA 95066
1723 HW Noord-Scharwoude
+31 (0) 72 5112014
If you have a complaint or question, you may contact us through the following email address: email@example.com. Please make sure you include as much information as reasonably possible. We will review complaints and questions within four weeks. We make every effort to resolve disputes. You may contact the applicable Supervisory Privacy Authority to file a complaint, should you be unsatisfied with our outcome.
Zero’s security measures to protect personal information
We take reasonable organizational and technical measures to help secure your personal data, ensure availability and to help prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction. Your personal information is not stored on our public web server. In a very few cases an error log entry may be made when your personal information is submitted. Log information is retained for six months.
Transferring information outside of the EU
Your personal information may be stored and processed in any country where we have operations. Zero Motorcycles is based outside the European Economic Area (“EEA”) in the USA and your personal data will be transferred to and processed in the USA. The USA is not deemed to provide an adequate level of protection for personal data. However, your personal data will be processed in compliance with EU data protection legislation under specific contracts approved by the European Commission which ensures the same level of protection of your personal data it has in the EEA.
Many of our data processors are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the USA, we may either use the above contracts approved by the European Commission or we may transfer data to them if they are part of the EU–U.S. Privacy Shield which, as outlined above, requires them to provide similar protection to personal data shared between the Europe and the USA. For further details, see European Commission: EU-U.S. Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Zero’s website and app are not designed for or directed to children under the age of 16. We never knowingly collect personal information from anyone under the age of 16 without parental consent. If we learn that we have collected personal information from a child under 16 without parental consent, we will delete the information as soon as possible.
How do I contact Zero Motorcycles?
380 El Pueblo Road
Scotts Valley, CA 95066
1723 HW Noord-Scharwoude
+31 (0) 72 5112014
Last revised: April, 2019