Privacy policy

 

 

Effective as of August 15, 2025

 

This is the Privacy Policy of Tenways Technovation Europe B.V., a company incorporated in the Netherlands, whose registered number is 85385115, with a registered headquarters located at Kabelweg 57, 1014 BA Amsterdam, the Netherlands ("Tenways", "we", "our", or "us").  
We are committed to protecting your privacy and handling your data responsibly. We also aim to be transparent about why and how we use your data. This Privacy Policy explains how we collect, use, share, and safeguard your data when you use our products, services, websites, and mobile applications.

 

1. About this Privacy Policy

This policy applies to the use of:

· Our website https://www.tenways.com (the "Website"),

· The services we offer (the “Services”), such as, but not limited to, placing an order and purchasing through our platforms, getting in touch with customer support (email, form, or via channels), enabling IoT aka Smart Connect features, etc.

· Tenways app (the “App”),

· Website, Services and App together are referred to as our “Platform”.

It does not apply to third-party services, websites, or platforms that may be linked from our services. Their handling of personal data is governed by their own privacy policies.

 

2. What We Collect

We collect information necessary to deliver our services and meet your expectations as a user. This may include:

a. Information You Share with Us

· Account setup: Name, email, phone number, password, country, date of birth

· Optional profile data: Avatar, nickname, gender, location

· Orders and payments: Recipient name, address, contact details, items ordered, order number, shipping/billing details

· Customer support: Order history, submitted queries, attachments (eg, photos or screenshots)

b. Information Collected Automatically

· Device details: IP address, browser type, OS, app version, location data, system language, device model, firmware version

· Bike data: Bike ID, battery level, connection logs, signal quality, activation time

· Ride activity: Distance, speed, start/end locations, elevation, routes, frequency, duration, ride logs 

· Smart feature: GPS tracking, status updates, lock/unlock activity, IoT module usage

· Usage logs: Crashes, errors, diagnostics, user behavior patterns

· Membership activity: Points earned, order-related actions, account ID

· Cookies and similar tools: Functional, analytics, and preference cookies to optimize experience

You can manage your cookie settings through your browser or device preferences.

 

3. How We Use Your Data

We process your personal data to deliver our services in line with user expectations and contractual commitments. This includes:

 

Type of Personal Data

Purpose of Processing

Description

Legal Basis

Data Recipient

Account Information

(e.g. name, email address, phone number.)

Account setup & authentication

Creating and maintaining your user profile

Necessary for the performance of a contract (GDPR Article 6(1)(b))

IT service providers (for platform hosting and authentication)

Tenways’ affiliates

Bike & Device Data

(e.g. bike status, location data)

Bike activation & operation

Activating smart features, tracking usage, and showing bike status

Necessary for the performance of a contract (GDPR Article 6(1)(b))

Consent (for location data (GDPR Article 6(1)(a), Article 9(2)(a))

Service providers supporting IoT connectivity

Tenways’ affiliates

Ride Activity Data

(e.g. distance, speed, duration of rides)

Ride analytics & personalization

Generating ride statistics and health metrics

Legitimate interest (GDPR Article 6(1)(f))  

Consent (for health-related data) (GDPR Article 6(1)(a), Article 9(2)(a))

Tenways’ affiliates

Order & Support Data

(e.g. items ordered, payment and delivery details, customer support queries)

Product delivery & support

Processing orders, payments, and offering post-sale support

Necessary for the performance of a contract (GDPR Article 6(1)(b))

Payment processors

Commerce and logistics partners

Customer support service providers

Tenways’ affiliates

Membership & Loyalty Data

(e.g. loyalty points, membership ID, rewards status)

Membership rewards

Calculating and displaying user rewards

Consent (GDPR Article 6(1)(a))

Other Tenways users

Tenways’ affiliates

Usage & Diagnostics Data

(e.g. app usage logs, crash reports, error codes, device diagnostics)

Service improvement

Analyzing aggregated data to enhance product performance

Legitimate interest (GDPR Article 6(1)(f))

Analytics and crash-reporting service providers

Social & Community Data

 (e.g. profile name, avatar, country, total ride distance, group ride stats, achievement earned)

Social & community features

Showing leaderboard rankings, shared achievements, or future community engagement

Legitimate interes (GDPR Article 6(1)(f)) / Consent (GDPR Article 6(1)(a))

Other Tenways users

Tenways’ affiliates

Security Data

 (e.g. account IDs, login history, IP address, usage patterns flagged for anomalies)

Security and misuse prevention

Monitoring system integrity and preventing unauthorized access or fraud

Legitimate interest (GDPR Article 6(1)(f))

IT security / fraud prevention service providers

Tenways’ affiliates

Legal/Compliance Data

(information needed to fulfill legal obligations)

Legal compliance

Responding to lawful requests from authorities

Compliance with legal obligations (GDPR Article 6(1)(c))

Government authorities, law enforcement agencies, or courts as mandated by law

 

Essential functions: Some data, such as bike ID, location data, ride metrics, and activation time is essential for operating your smart bike and app features. This processing is necessary for us to fulfill the agreement concluded with you. Without it, these services cannot function.

In cases where your consent is required (e.g. for precise location tracking or health data), we’ll always ask before processing.

 

4. Social Features (Current & Future)

We may use certain profile information (e.g. nickname, avatar, country, total ride distance) in features that support social interaction, such as:

· Group ride stats

· Community achievements

· Rankings or badges

· Future social integrations in the app

You will always be able to opt out of public visibility or social participation by adjusting the settings in the app.

 

5. Sharing Your Information

We may share personal data in the following situations:

· With service providers helping us with logistics, payments, hosting, analytics, or support

· With regulators or authorities when required by law or in response to valid legal requests

· Within our company group, for internal purposes or to improve our services

· In connection with a sale or transfer, including during due diligence, as part of a merger, acquisition, or business restructuring

We only disclose what is necessary and ensure all partners meet relevant data protection standards.

 

6. How We Protect Your Data

We maintain technical, administrative, and physical safeguards to protect your personal data. This includes:

· Encrypted communications

· Access controls

· Anonymization where possible

· Regular system monitoring

While we aim for high security, no online system is 100% immune to breaches. We encourage users to protect their accounts with strong passwords and secure devices.

 

7. Data Retention

We keep personal data:

· As long as needed to provide services and fulfill our contract

· For legal and compliance purposes

· Until the user deletes their account or withdraws consent (where applicable)

If we retain data in backups, it is securely isolated until deletion is possible. Anonymized data may be retained for research and analysis without further notice.

 

8. Transfers Outside the EU/EEA

Your data may be processed in countries outside of your residence, including China. When we transfer data internationally, we apply appropriate safeguards, such as Standard Contractual Clauses for the transfer of data, as according to Article 46 of the GDPR, to ensure a consistent level of protection.

 

9. Your Rights (EU/EEA Residents)

If you live in the EU or EEA, you have certain rights under the GDPR, including:

· Access – request to see what personal data we hold about you

· Correction – update or correct your information

· Deletion – ask us to erase your data in certain cases

· Restriction – limit how we use your data

· Portability – request your data in a readable format

· Objection – object to certain uses, including marketing

· Withdraw consent – revoke your consent at any time (this won’t affect previous use)

· Complain – lodge a complaint with your local data protection authority

To exercise these rights, contact us at support@tenways.com. We respond to all requests in accordance with applicable law.

 

10. Children’s Privacy

Our services are not intended for children under 16. In accordance with GDPR and Dutch law, minors under the age of 16 cannot independently consent to the processing of personal data; therefore, we do not knowingly offer our services to such individuals without verifiable parental or guardian consent. We also do not knowingly collect data from children under 13. If we learn that we have inadvertently collected personal data from a child without proper consent, we will take immediate steps to delete the information from our records.

 

11. Updates to This Policy

We may update this Privacy Policy to reflect changes in our services or legal requirements. If the changes are significant, we’ll notify you through our app, website, or by other means. The latest version is always available on our website and reflects the current data practices.

 

12. How to Contact Us

Questions or concerns? We're here to help.

 

Tenways Privacy Team
support@tenways.com