Privacy Policy

Privacy Policy

Privacy Policy

This Privacy Policy is provided by Specialized Bicycle Components, Inc. and its affiliated companies (collectively referred to as "Specialized" or "we"), including Specialized Shanghai Co. Ltd., and is intended to outline our commitment to safeguarding your personal information in accordance with relevant laws, regulations, and the provisions of this Privacy Policy.

This Privacy Policy is prepared for the following individuals:

• Specialized stores and online customers, including prospective customers and consumers (such as individuals who subscribe to any marketing information from Specialized).

• Visitors, registered users, and/or followers to Specialized.com.cn (the “Official Website”), Specialized WeChat Official Account (SpecializedCHINA), Specialized WeChat Pop-up Store, Specialized WeChat Membership Center Mini Program, Specialized Tmall Flagship Store, and Specialized Weibo Official Account, as well as any subsequent successor websites or applications (collectively referred to as "Website" or "Online Platform").

This Security and Privacy Policy (this “Privacy Policy") outlines the categories and methods through which Specialized collects your personal information, and how it is used, stored, shared, and protected.

Before using our products or services, we kindly request you to carefully read this Privacy Policy and make the appropriate choices you deem necessary. If you have any questions regarding this Privacy Policy, you can contact us at [email protected].

1. Who Are We?

For the purposes of this Privacy Policy, the data controller is Specialized Bicycle Components, Inc., located at 15130 Concord Circle, Morgan Hill, California 95037, United States, and Specialized Shanghai Co. Ltd., located at 1888 Xingang Road, Pudong New Area, Shanghai, China.

2. What Data Does This Privacy Policy Cover?

This Privacy Policy covers all personal information processed by Specialized. Personal information refers to various types of information recorded electronically or by other means that can identify a specific natural person either alone or in combination with other information, or reflect the specific activities of a natural person. This includes the types of information mentioned in the following sections.

3. What Data Do We Collect from You?

We may collect your personal information from the following sources:

(1) Information You Provide to Us:

We may collect the personal information you provide during the following interactions (such as your name, gender, mailing address, email address, phone number, nationality, date and month of birth), geographic location, third-party platform (such as WeChat, Weibo, and other social media) account or username, photos, payment card information, or other personal characteristics or preferences:

• Purchasing our products through the Online Platform;

• Registering an account on the Online Platform;

• Following Specialized WeChat Official Account, Specialized WeChat Pop-up Store, Specialized WeChat Membership Center Mini Program, Specialized Weibo Official Account, or interacting with them;

• Completing our store cards (for receiving information about our products and events, and understanding how to participate in store activities, competitions, or promotions);

• Requesting customized product services;

• Subscribing to our marketing information or other marketing activities, such as sweepstakes and surveys;

• Contacting our customer service department (e.g., via phone, email) and subsequent communications with us; and

• Submitting product reviews on any of our Websites.

(2) Information We Collect About You:

We may collect information about you from the following sources:

• Your transaction records and purchase history;

• Your interactions with our social media (e.g., "liking" or "sharing" content on our social media platforms);

• Your usage of our Website or third-party websites where our advertisements are displayed. Specifically, we may collect:

a) Technical information, including your IP address, browser type and version, device identification number, geographic location and time zone settings, network and/or service provider, operating system and platform, page response times, and download error notifications;

b) Your browsing information, including websites visited before or after our Website, and products viewed or searched. This includes the duration of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse hovering), and methods used to exit page views.

If you want to learn more about how we use cookies or similar digital tracking technologies (used to collect the above information), please refer to the "How We Use Cookies" section below.

• Your interactions with our marketing emails to measure marketing effectiveness (e.g., we collect whether/when you opened our emails and whether you clicked on links or forwarded the email);

• Your interactions with our online advertisements to measure advertising effectiveness;

• Store cards you completed out and returned to us when visiting our stores;

• CCTV recordings collected in our stores; and

• Your information obtained from the aforementioned sources and from third parties under a legal basis (including information obtained from public channels).

We will combine all the information to better understand who you are and your preferences, among other purposes, to enhance your customer experience with us (see "How We Use Your Personal Information" for more details).

When we provide services to you through third-party vendors (including entities providing software development, data management and analysis, technical support, event coordination, or business management), we will collect personal information from such third parties with your consent.

When processing your product orders on the Website, providing additional services as per your request, or when we require your personal identity information to fulfill legal obligations, it is necessary for you to provide us with your personal identity information (especially detailed personal information, email address, address, credit/debit card numbers and bank codes, and phone numbers). Therefore, if you do not provide the relevant information, in some cases, we may not be able to process your product orders on the Website or provide additional services, and you may also be unable to participate in related activities.

4. How We Use Your Personal Information?

Your personal information will be used for the following purposes:

Based on the following reasons:

1. Processing your online payments and completing your online orders.

Based on your consent.

Necessary for the performance of our sales contract with you.

2. Creating a personal account for you on our Website and enabling you to use that account.

Based on your consent.

Necessary for the performance of our contract with you (online personal account).

3. Using your personal account on our Website (e.g., saving billing details and delivery addresses for future purchases, retaining relevant data for processing product returns).

Based on your consent.

For certain specific data usage (e.g., processing product returns), using your data is necessary to fulfill our contract with you.

4. Personalizing and optimizing your experience of online shopping with us (e.g., recording information about past purchases such as addresses for reuse in future purchases, saving your favorite store location).

Based on your consent.

5. Enabling you to use the functions of our Website online (even if you have not registered for an online personal account).

Based on your consent.

6. Providing customer support for any inquiries or requests related to products you have purchased.

Based on your consent.

Necessary for the performance of our contract with you (e.g., contractually agreed customer support for inquiries or requests). Necessary to comply with legal obligations we must adhere to (e.g., specific inquiries requiring responses or enabling you to exercise consumer rights, such as the Consumer Rights Protection Law).

7. Providing customer support for any inquiries or requests related to products you intend to purchase, or providing general inquiries or requests.

Based on your consent.

8. Using your product reviews provided on our Website or through third-party platforms.

Based on your consent.

9. Customizing products as you specifically requested.

Based on your consent.

Necessary for the performance of our contract.

10. Evaluating the effectiveness of our online advertisements and marketing activities (e.g., assessing whether/when/how you interacted with online advertisements or emails from us).

Based on your consent.

11. Targeting advertisements based on your preferences, likes, preferences, and habits.

Based on your consent.

12. Contacting you through email, postal mail, or SMS (if you provide such information through our store cards or online methods) to inform you about our product purchases, offers, and promotions.

Obtaining your consent where applicable by law.

13. Conducting research and surveys related to our products and customer experiences, product development, and testing.

Based on your consent.

14. Enabling you to voluntarily participate in contests, sweepstakes, competitions, promotions, and similar activities organized for our customers.

Based on your consent.

Necessary for the performance of our contract with you (based on your written acceptance of terms and conditions for participating in our contests, sweepstakes, competitions, and other promotions).

15. Providing better-personalized services and customer support to our customers.

Based on your consent.

16. Interacting with you through our social media platforms, assessing the effectiveness of our social media activities, and achieving certain objectives through social media (e.g., advertisements, enabling your participation in our contests, sweepstakes, surveys, etc.).

Based on your consent.

17. Enabling you to voluntarily participate in our social media activities, including using your image.

Based on your consent.

Necessary for the performance of our contract with you (based on your written acceptance of terms and conditions for participating in such activities).

18. Improving the functionality and user-friendliness of our Website.

Based on your consent.

19. Detecting fraud in online payments and preventing any illegal activities in a broader sense.

Based on your consent.

Necessary for the performance of our contract with you (including securing and keeping your payment data confidential by fulfilling our contractual obligations).

20. Supporting company transactions such as mergers or acquisitions, where data must be merged or transferred as part of the transaction.

Based on your consent.

Necessary for compliance with regulatory or legal requirements.

21. Responding to or processing inquiries or requests from law enforcement agencies, regulatory bodies, or other public authorities.

Based on your consent.

Necessary to comply with legal requirements we must adhere to.

5. How We Use Cookies?

Like many other organizations, we use Cookies or similar digital tracking technologies on the www.specialized.com.cn website for various purposes. Cookies (or similar technologies) will be placed on our Website by us or third-party partners engaged by us for our purposes.

Third-party Cookies may also be placed on third-party websites by us (e.g., for assessing advertising effectiveness). Please note that we cannot control and are not responsible for any third-party Cookies placed on our Website without our authorization or representation.

We respect applicable laws regarding Cookies. Specifically, we only use Cookies with your consent (as required by applicable laws). In any case, you can disable Cookies at any time by adjusting your browser settings accordingly. However, disabling Cookies may result in certain features, parts, or functionalities of our Website not functioning properly, and it may hinder your full enjoyment of our online services.

Categories of Cookies

Some Cookies, known as session Cookies, will be deleted when you close your browser. Others, known as persistent Cookies, will remain on your device until they expire or are deleted from the cache. Persistent Cookies allow us to remember some information about you as a returning customer. The main categories of Cookies we use include:

• Strictly Necessary Cookies: These Cookies are essential for you to browse and use website functions, ensuring the security of your online transactions and access to our Website. Without these Cookies, we will be unable to provide necessary services, such as completing transactions. These Cookies will not collect your information for marketing purposes.

• Performance Cookies: These Cookies enable us to calculate the number of visitors and gather information about how visitors use the website, such as the most frequently visited pages and whether they encounter error messages. Although these Cookies may collect the IP addresses of devices used to access the website, they will not collect information that identifies visitor identities. All information collected by these Cookies is anonymous and used only to improve website operations and user experience. By using our Website, you agree that we can place these types of Cookies on your device. However, you can also disable these Cookies through browser settings (see "Managing Cookies" section below).

• Functionality Cookies: These Cookies allow us to recognize you when you return to our Website and enable the Website to remember your choices (e.g., your username). They can also be used to provide services you request, such as watching videos. The information collected by these Cookies is anonymous (i.e., does not include your name, address, account details, etc.), and they do not track your browsing activities on other websites. By using our Website, you agree that we can place these types of Cookies on your device. However, you can also disable these Cookies through browser settings (see "Managing Cookies" section below).

• First-Party and Third-Party Cookies: Whether a Cookie is first-party or third-party depends on which website it originates from. First-party Cookies are set by the website visited or on its behalf. All other Cookies are third-party Cookies. Please note that third parties (including advertising networks, web traffic analytics services, and other external service providers) also use such Cookies, which we cannot control. These Cookies are likely to be analytics/performance Cookies or targeted Cookies.

• Personalization Cookies: Our Website may also use Cookies to personalize your shopping experience and enable specific functions.

For more information about Cookies, including how to view and manage them, please visit www.allaboutcookies.org or search for other independent information about Cookies on the internet. Except for strictly necessary Cookies, all Cookies will be stored according to the principles outlined in Article 10 of this Privacy Policy.

Purposes of Using Cookies

We utilize Cookies for the following purposes:

• To facilitate the basic functionality of the Website;

• To conduct network analysis in order to enhance our Website (including its structure, functionality, accessibility, usability, and content) and to address technical issues through the collection of relevant technical data;

• To enable fundamental online browsing and shopping functions (such as retaining the information you generate or provide on our Website, such as preferred items, items placed in the shopping cart, and checkout addresses, to save your time and effort during your next visit to our Website or during shopping);

• To review the effectiveness of our online advertisements and marketing efforts (by recording your interactions with our advertisements on third-party websites, our social media platforms, or our marketing emails); and to gain insights into your preferences and online browsing habits, among other information, to provide you with personalized advertisements (we believe you wouldn't want to see advertisements that are not of interest to you).

Managing Cookies

Browsers of most computers, smartphones, and other network devices are typically set to accept Cookies by default. If you wish to modify the Cookies settings for our Website or any other website, you can do so through browser settings. The "Help" function in your browser can also guide you on how to perform these settings. If you do not wish to use Cookies, you can manually delete them through a simple process. You can visit www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html to access this information.

Please be aware that Cookies are often used to enable and enhance the functionality of our Website. Choosing to disable certain Cookies may impact the way our Website operates.

6. Sharing of Personal Information with Third Parties:

In certain cases, we may share your personal information with third parties:

• Affiliated Companies of Specialized: We may share your personal information within our corporate group, including subsidiaries, headquarters, and branches, to establish unified accounts, manage our services and products, provide customer support, process payments, understand your preferences, deliver targeted advertising, send information about products and services that may interest you, and perform other activities as described in this Privacy Policy.

• Our Service Providers: Other companies, agents, or providers may offer services to us or assist us in providing Specialized services and products to you. We may share your personal information with the following categories of service providers:

• Infrastructure and IT service providers, including cloud service providers;

• Vendors that maintain and manage customer databases;

• Marketing, advertising, and communication agencies;

• Online payment and anti-fraud service providers;

• Delivery/logistics service providers (for door-to-door delivery of products purchased online);

• External auditors and consultants (e.g., social media consultants);

• Suppliers of services related to online optimization features such as customer reviews;

• Cookies analysis software providers;

• Online advertisers; and

• Website testing/analysis service providers.

During the provision of such services, these service providers may access your personal information. Whenever possible, we will strive to anonymize or de-identify personal information and only provide service providers with the personal information they need to fulfill their services. We will require them not to use your personal information for any other purpose. We will make our best efforts to ensure that all our service providers maintain the security of your personal information.

• Third Parties Permitted by Law: In certain situations, we may be required to disclose or share your personal information to comply with legal or regulatory obligations (e.g., we may be required to disclose your personal information to public security authorities, regulatory agencies, government agencies, judicial or administrative bodies).

We may also disclose your personal information to third parties if permitted by law and necessary to protect or defend our rights, national security, law enforcement, enforce our contracts, or protect your rights or the rights of the public.

• Third Parties Related to Business Transfers: In the event of asset restructuring, company restructuring, merger, acquisition, or asset transfer, we may transfer your personal information to third parties, subject to the receiving party agreeing to process your personal information in a manner consistent with this Privacy Policy.

Please note that our Website may occasionally contain links to the websites of our partners or affiliated companies. If you visit any of these linked websites, please be aware that these websites have their own privacy policies, and we cannot control how they use your personal information. Before submitting any personal information to third-party websites, you should review the privacy policies of those third-party websites.

7. Cross-border Transfer of Your Personal Information:

In general, the personal information we collect and generate in the People's Republic of China ("China") will be stored within China and will not be transferred abroad. However, as a global multinational corporation, we have necessary collaborative arrangements with our overseas parent company. Therefore, to the fullest extent permitted by law and in compliance with applicable laws and the provisions of this Privacy Policy, your personal information collected and processed through the Official Website may, under certain circumstances, be transferred to locations outside the territory of the People's Republic of China for processing and may be accessed by countries and regions outside of China. The information related to the transfer of personal information abroad is as follows:

Recipient Abroad: Specialized Bicycle Components, Inc.

Registered Address: 15130 Concord Circle, Morgan Hill, CA 95037, USA

Contact Information: [email protected]

Personal Information: Name, Mailing Address, Email Address, Phone Number

Purpose of Transfer Abroad: "Enabling you to use the functions of our Website online" and "Improving the functionality and user-friendliness of our Website" (same as the purposes 5 and 18 under Article 4 of this Privacy Policy).

We will take all reasonable and necessary measures to ensure the secure and proper processing of your personal information, in compliance with this Privacy Policy and applicable data protection laws.

8. Your Rights:

With regard to your personal information, you have the following rights:

• Right of Access: You may access or update most of your personal information online. If you cannot access certain personal information, you may send relevant requests to us. You also have the right to request a copy of your personal information that we are processing. For your privacy and security, we may request verification of your identity before providing the required information.

• Right of Rectification: You have the right to request us to correct your incomplete or inaccurate personal information.

• Right to Erasure: You have the right to request us to delete your personal information in the following circumstances:

a) Our collection, use, or processing of your personal information violates relevant laws and regulations;

b) Our collection, use, or processing of your personal information violates our agreements.

However, if we need to retain such data to fulfill legal obligations or exercise or defend legal claims, we are not obligated to delete your personal information.

• Right to Account Closure: You have the right to request the closure of your account. For your privacy and security, we may request verification of your identity before performing the closure.

• Right to Withdraw Consent: If you have given your consent for us to process your personal information, you have the right to withdraw your consent. This includes opting out of receiving marketing information from us.

Regarding the exercise of the right to delete information or close an account, please note that after you submit relevant requests, we will verify whether there are any outstanding orders. If there are orders within the return and exchange period or in the post-purchase service process, we may temporarily be unable to delete or close your account for the sake of your legitimate rights and interests. If we need to retain your information in order to comply with applicable laws, regulations, or regulatory requirements, we will retain the relevant information until the minimum retention period required by law or regulations expires. Additionally, once your information is deleted, your membership points and other rights and benefits will be cleared, and you will no longer be able to view or operate historical orders.

You can contact us as instructed in "Contact Us" below to request the exercise of any rights related to your personal information.

If you believe we are not complying with applicable data protection laws, you also have the right to lodge a complaint with supervisory authorities.

9. How We Protect Your Personal Information:

To safeguard the personal information we collect, we have implemented technical and organizational security measures. These measures include limiting access to personal information to employees and authorized service providers who need to know such information for the purposes described in this Privacy Policy, as well as other administrative, technical, and physical safeguards.

While we strive to protect our systems, websites, operations, and information from unauthorized access, use, modification, and disclosure, the internet is an open global communication tool and there are potential risk factors. As a result, we cannot guarantee the absolute security of any information during transmission or storage in our systems. We recommend that you also take measures to protect your personal information within feasible limits (including but not limited to protecting your account and password).

10. How Long Do We Retain Your Personal Information:

We will retain your personal information only for the period required for the purpose of data collection and as permitted by applicable laws. When we no longer need to use your personal information, we will delete the information and/or take anonymization measures in our systems and records, making your identity unidentifiable (unless we are required to retain your information to fulfill legal obligations or regulatory requirements).

11. How We Handle Children's Personal Information:

For children aged fourteen (14) and below, parental consent must be obtained before providing personal information or registering as a member. We will not knowingly allow children who have not obtained prior parental consent to register or otherwise collect personal identity information. If the child or their guardian subsequently requests that we stop providing services to the member account, we will immediately cancel the membership, cease to provide member services, and delete the membership account and related personal information in accordance with relevant national laws and regulations.

12. How to Contact Us:

If you have any questions or concerns about this Privacy Policy or the data collection outlined herein, or if you wish to exercise any of your rights, please contact us through the following means:

Email: [email protected]

Address: Specialized Bicycles (Shanghai) Co., Ltd., 1st Floor, No. 1888, Building 40, Xingang Road, Pudong New District, Shanghai, China

When contacting us, please provide your accurate contact information to ensure proper handling of your requests. Unless otherwise required by applicable laws and regulations, we will generally respond within thirty (30) days after receiving your request.

13. Applicable Version of this Privacy Policy:

This Privacy Policy is written in Chinese and may be translated into any other language. In case of any inconsistency between the Chinese version of this Privacy Policy and translations in other languages, the Chinese text shall prevail.

We reserve the right to change this Privacy Policy from time to time, including changes necessitated by changes in our data processing behavior or activities. By continuing to use our Online Platform or related services after the updated version of this Privacy Policy is released, you agree to the changes we have made. For significant changes to this Privacy Policy, we may provide more prominent notices and, where required by applicable laws and regulations, seek your consent to the updated policy.