UK GDPR: DATA PRIVACY NOTICE

This is privacy notice of Active Linx Ltd trading as Velotrain® Accessible Cycling.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how data protection law protects you.

This privacy notice is provided in full below. The policy applies to all visitors, customers, suppliers, and users who interact with our website, services, digital platforms, or communication channels.

Active Linx Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

1. WHO WE ARE AND IMPORTANT INFORMATION 

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you for example: sign up to our newsletter/purchase a product or service/send an enquiry through to us.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller

Active Linx Ltd is the controller and responsible for your personal data (collectively referred to as “Active Linx” or “Velotrain®”, “we”, “us” or “our” in this privacy notice). Active Linx Ltd is a company registered in England and Wales under number 03780312, whose registered office address is at Allia Future Business Centre, London Road, Peterborough PE2 8AN. For all data matters contact us through or enquiry form on our website, or call 01234 905512, and we will provide the full contact details for our data protection officer or data representative.

Third-party links outside of our control

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.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you were necessary to provide our products and services which we have grouped together as follows:

• Identity Data which includes [first name/last name/username/title/Age/gendeR/brand & product awareness/order history].
• Special Categories of Personal Data will be collected only where necessary for legal or regulatory obligations (e.g. VAT declarations) or where freely disclosed for the purposes of assessment and advice on the suitability of our products and services. [Medical condition or diagnosis & history/health & Fitness capability/physical & cognative ability & limitations].
• Contact Data which includes [billing address/delivery address/email address/ telephone numbers/additional delivery details].
• Technical & Usage data which includes [IP ADDRESS/ DEVICE TYPE/ BROWSER VERSION/ OPERATING SYSTEM/ PAGES VISITED/ TIME SPENT/ CLICK BEHAVIOUR/ ERROR REPORTS].
• Marketing & Communications Data which includes [EMAILS/ ENQUIRY FORMS/ CHAT MESSAGES/ OPT-IN CHOICES/ INTERESTS/ CAMPAIGN INTERACTIONS].

[We 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 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 notice.]

We do not collect any additional 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, genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your 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.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including:

• Though our online forms and third-party software providers [COOKIES/ SERVER LOGS/ANAYLTIC TOOLS] built into our websites operational, contact and ordering processes.
• You may give us your [Identity, Contact, PERSONAL, TECHNICAL oR MARKETING] by filling in our online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • [Order our products or services;]
  • [Create an account on our website;]
  • [Subscribe to our newsletter;]
  • [Send an enquiry though our website;]
  • [Call and speak to us directly or leave a voicemail message;]
  • [Disclose to us in person.]
• Third-Party sources. Through payment processors, advertising platforms, social media integrations.

• Contractual relationships. Through suppliers, partners & clients.

4. HOW WE USE YOUR 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:

• Performance of Contract. Thismeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract which might include the delivery of order confirmations, invoices, customer support and service updates.

• Website performance & security. To improve website performance using analytics, personalise user experience, maintain account security and prevent fraud.

• Legitimate Interest.This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by asking us for the details of our three-part ‘legitimate interests assessment’.

• Comply with a legal or regulatory obligation.This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to or to conduct internal business reporting and auditing.

[GENERALLY, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us].

Purposes for which we will use your personal data

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data which may include the following:

• Consent: for marketing, newsletter subscriptions.

• Contract: for fulfilling orders or service agreements.

• Legitimate Interest: for security, service optimisation & fraud prevention.

• Legal Obligation: for tax reporting, accounting & compliance.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on 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.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Active Linx group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages [by following the opt-out links on any marketing message sent to you] by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration or claim, product OR service experience or other transactions].

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• 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).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control, and we cannot accept any liability for the third party’s compliance with its legal obligations. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click the privacy settings icon at the bottom left of any page of our website.

Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.

• Internal Third Parties 3001web.com, 18 Thirlmere Ave, Grimsby DN33 3EA and Social Media WOW Ltd, 3a Tudor Road, Godmanchester, Cambs PE29 2EA.
• External Third Parties Service: [FOR EXAMPLE]
  • Providers [acting as processors] who provide [IT PROVIDERS and system administration services, Payment processors [g. Stripe or PayPal], cloud hosting services, Delivery and logistics partners].
  • Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers who provide [consultancy, banking, legal, insurance and accounting services].
  • HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] [who require reporting of processing activities in certain circumstances].
• 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 notice.

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. We never sell personal information to third parties.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Active Linx group and our partners. This may involve transferring your data outside the UK. Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by implementing UK GDPR-approved safeguards:

• Standard Contractual Clauses (SCCs) using International Data Transfer Agreement (IDTA) or the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers (Addendum) as a transfer tool to comply with Article 46 of the UK GDPR when making restricted transfers.
• Verified security frameworks using certifiable standards and guidelines to manage and reduce cybersecurity risks.

Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data out of the UK.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

8. 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. We store data securely using encrypted systems, restricted access, and monitored servers.

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 unauthorised 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.]

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

After retention periods expire, personal data is securely deleted. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;

• The right to request that we correct any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary to retain such data;

• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;

• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact us.

No fee required – with some exceptions

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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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.

10. Changes to this notice and your duty to inform us of changes

[This version was last updated on The 6th of February, 2026 and historic versions can be obtained by contacting us.]

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

11. Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please contact us in the first instance.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.