PRIVACY POLICY
Effective date: 9-Sep-24
INEX Club is a community of people passionate about cycling.
The organizer of the INEX Club is the company ZAK INEX CLUB LTD, with office in 58, Leoforos Ellados,
Paphos 8020, Cyprus.
ZAK INEX CLUB LTD is committed to protecting and respecting your privacy. This Privacy Policy explains
how we use any personal data we collect from you, or that you provide to us, when you use this
websites: https://inex.club/, https://store.inex.club/ (when referred to collectively, referred to as «Оur
sites», «Websites», «Sites», and when referred to separately, referred to as «Оur site», «Website»,
«Site») or services linked to this websites or our services («Services»).
ZAK INEX CLUB LTD complies with the principles of GDPR.
The six overall guiding principles are:
 Lawfulness, transparency and fairness;
 Purpose Limitation;
 Data Minimisation;
 Accuracy;
 Storage limitation;
 Confidentiality and integrity.
By visiting Websites or using Services you are accepting and consenting to the practices described in
this policy.
We ask that you carefully review this Privacy Policy and any other privacy notices we may send you
from time to time.
We will update this Privacy Policy when necessary to reflect feedback, changes in our Websites and
services or legal changes. When we post changes to this Policy, we will revise the «Effective Date» at
the top of the privacy policy.
If there are material changes to the Privacy Policy we will notify you either by prominently posting a
notice of such changes before they take effect or by directly sending you a notification. We encourage
you to periodically review this privacy policy to learn how ZAK INEX CLUB LTD is processing your
information.
CONTROLLER
For the purposes of the General Data Protection Regulation (EU) the data controller is ZAK INEX CLUB
LTD, 58 Leoforos Ellados, Paphos 8020, Cyprus.
Email address: store@inex.club.
Postal address: 58, Leoforos Ellados, Paphos 8020, Cyprus.
1You have the right to make a complaint at any time to the Commissioner for Personal Data Protection
in Cyprus (https://www.dataprotection.gov.cy/).
However, we would like to deal with your concerns before you approach the Regulator so please
contact us in the first instance.
PURPOSES OF USE AND TYPES OF YOUR PERSONAL DATA WHICH WE WILL USE
We may collect, use, store and transfer different kinds of your personal data. For convenience we have
combined them with the following terms:
(a) Identity Data First name, last name, username or similar identifier, date of birth,
gender, height, weight
(b) Passport Data Passport number and date of issue, issuing authority, citizenship,
passport expiration date
(c) Contact Data Billing address, delivery address, email address and telephone numbers
(d) Financial Data Bank account and payment card details
(e) Transaction Data Details about payments to and from you and other details of products
and services you have purchased from us
(f) Technical Data Internet protocol (IP) address, your login data, browser type and
version, cookies, time zone setting and location, browser plug-in types
and versions, operating system and platform and other technology on
the devices you use to access this website
(g) Profile Data Username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses
(h) Usage Data Information about how you use our website, products and services
(i) Marketing and
Communications
Data
Your preferences in receiving marketing from us and our carefully
selected third parties and your communication preferences
(g) Biometric data Photo, video, voice
(k) Social networks
User name in social networks, such as instagram, facebook, twitter,
data
Strava, Komoot, etc.
The purposes and uses of your personal data are described below.
№ PURPOSES FOR USING TYPE OF YOUR PERSONAL DATA LAWFUL BASIS FOR
PROCESSING
1 To register you as a new customer Identity, Contact Performance of a contract
with you / Consent
2 To process and deliver your order
including: Manage payments, fees and
charges, Collect and recover money
owed to us
Identity, Contact, Financial, Transaction,
Marketing and Communications
Performance of a contract
with you. Necessary for our
legitimate interests to
recover debts owed to us /
Consent
3 To organize your ride with INEX Club, for
equipment rent
Identity, Contact Necessary for setting up
equipment for you,
communicating in case of a
ride postponement,
2№ PURPOSES FOR USING 4 To organize your trip with INEX Club,
including, but not limited to, booking
hotels, tickets for all types of transport,
etc. including: Manage payments, fees
and charges, Collect and recover money
owed to us
5 To manage our relationship with you
which will include: Notifying you about
changes to our terms or privacy policy,
Asking you to leave a review or take a
survey
6 To enable you to partake in a prize draw,
competition or complete a survey
7 To administer and protect our business
and this website (including
troubleshooting, data analysis, testing,
system maintenance, support, reporting
and hosting of data)
8 To deliver relevant website and app
content and advertisements to you and
measure or understand the effectiveness
of the advertising we serve to you
9 To use data analytics to improve our
website, products/services, marketing,
customer relationships and experiences
10 To make suggestions and
recommendations to you about goods or
services that may be of interest to you
11 To assess whether you are suitable for a
job at the company
12 For running the Club's social networks,
for use in announcements of Club events,
for advertising the Club
TYPE OF YOUR PERSONAL DATA Identity, Contact, Passport, Financial Identity, Contact, Profile, Marketing and
Communications
Identity, Contact, Profile, Usage, Marketing and
Communications
Identity, Contact, Technical Identity, Contact, Profile, Usage, Marketing and
Communications, Technical
Technical, Usage Identity, Contact, Technical, Usage, Profile Identity, Contact, Profile Biometric data, social networks data 3
LAWFUL BASIS FOR
PROCESSING
changes in the schedule,
communicating during the
ride/ Consent
Necessary to perform or
prepare for a contract with
the data subject / Consent
Performance of a contract
with you. Necessary to comply
with a legal obligation.
Necessary for our legitimate
interests to keep our records
updated and to study how
customers use our
products/services / Consent
Performance of a contract
with you. Necessary for our
legitimate interests to study
how customers use our
products/services, to develop
them and grow our business /
Consent
Necessary for our legitimate
interests for running our
business, provision of
administration and IT
services, network security, to
prevent fraud and in the
context of a business
reorganisation or group
restructuring exercise (b)
Necessary to comply with a
legal obligation / Consent
Necessary for our legitimate
interests to study how
customers use our
products/services, to develop
them, to grow our business
and to inform our marketing
strategy / Consent
Necessary for our legitimate
interests to define types of
customers for our products
and services, to keep our site
updated and relevant, to
develop our business and to
inform our marketing strategy
/ Consent
Necessary for our legitimate
interests to develop our
products/services and grow
our business / Consent
Necessary for our legitimate
interest (b) Performance of a
contract with you / Consent
Processing is necessary for the
purposes of the legitimate
interests pursued by the№ PURPOSES FOR USING TYPE OF YOUR PERSONAL DATA LAWFUL BASIS FOR
PROCESSING
Controller or by a third party /
Consent
Where you have provided personal data voluntarily, or otherwise consented to its use, the right to
withdraw your consent.
We may also collect, use and share aggregated data. Such data is derived from personal data, but
cannot be directly or indirectly identified by you.
However, if the aggregated data is combined with your personal data, which leads directly or indirectly
to the possibility of identifying with you, then such data will be treated by us as personal data and
protected in accordance with the terms of this provision.
We do not collect any special categories of personal data about you (including information about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health, and genetic and biometric data).
Our site is not intended for children and we do not knowingly collect data relating to children.
PERIOD OF STORAGE OF YOUR PERSONAL DATA
We keep your personal data for the entire period while you are a member of INEX Club, as well as for
one year after you have ceased to be a member of INEX Club.
If you were not a member of INEX Club, we store your personal data for one year after it was
provided (collected) or the last time you used the online store or Services.
YOUR RIGHTS IN RELATION TO THE PERSONAL DATA
You have the right to request access to the personal data ZAK INEX CLUB LTD holds about you. In order
for us to comply with such a request, you will have to submit a Subject Access Request (SAR). We may
require you to prove your identity with two pieces of approved identification. We will respond to a SAR
within 30 days.
Information about requested personal data provided free of charge.
Where requests from a data subject are manifestly unfounded or excessive, in particular because of
their repetitive character, ZAK INEX CLUB LTD may either:
 charge a reasonable fee taking into account the administrative costs of providing the
information or communication or taking the action requested;
 refuse to act on the request.
As well as the right to access the personal data ZAK INEX CLUB LTD holds about you, you have a number
of other rights in respect of your personal data under the data protection laws. These may include (as
relevant):
 The right to rectification, including to require us to correct inaccurate personal data;
4 The right to request restriction of processing concerning you or to object to processing of your
personal data;
 The right to request the erasure of your personal data where it is no longer necessary for us to
retain it;
 The right to data portability including to obtain personal data in a commonly used machine
readable format in certain circumstances such as where our processing of it is based on a
consent;
 The right to object to automated decision making including profiling (if any) that has a legal or
significant effect on you as an individual;
 where you have an option to provide us with your personal data or not in connection with your
use of our Website or in connection with any of our products or services, you have the right to
be informed about the possible consequences of not giving it to us; and
 The right to withdraw your consent to any processing for which you have previously given that
consent.
TRANSFER OF PERSONAL DATA
Advertisers and advertising networks sometimes require data to select and serve relevant
advertisements to you and others. We may provide them with aggregate cookie information about our
users with certain attributes (for example, we may inform them that 100 men aged under 25 have
clicked on their advertisement on any given day). We may also use such aggregate information to help
advertisers reach the kind of audience they want to target (for example, women who are interested in
cycling).
We share cookie data with other publishers via a secure data management platform when advertising
campaigns are served across multiple news websites. These publisher partners are not able to access
this data themselves, only serve the advertisements across their own websites to readers whose cookie
data form part of the selected advertising segments.
We reserve the right to disclose your personal information to comply with applicable laws and
government or regulatory bodies' lawful requests for information.
Your personal details may be shared with third party organisations we have contracted to provide
services to us which include processing data. For example, to send you the emails you have signed up
for. Only companies who can provide adequate safeguards will be used to ensure your data is stored
and handled securely.
We may also have to release information because of a legal requirement on us or pursuant to a court
order.
We may transfer, sell or assign any of the information described in this Privacy Policy to third parties
as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of
our business.
We may transfer your personal data in order to fulfill our obligations to you, such as, for example,
purchasing tickets for all types of transport, hotel reservations, visa support before sports camps,
ordering and purchasing equipment, clothing, gear, sports nutrition, etc.
5The data that we collect from you may be transferred to, and stored at, a destination outside the
European Economic Area (EEA). It may also be processed by staff operating outside the EEA working
for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of
your order, the processing of your payment details and the provision of support services.
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 the
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 transfer to US group companies or use providers who are based in the US, we may transfer
data to them if they are part of the Privacy Shield which requires them to provide similar protection to
personal data shared between the Europe and the US. For further details, see European Commission:
EU-US Privacy Shield.
Please contact us if you would like further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
Google Analytics
Our website uses Google Analytics to collect information about the use of our website.
Google Analytics collects information from users such as age, gender, interests, demographics, how
often they visit our website, what pages they visit, and what other websites they have used before
coming to our website.
We use the information we get from Google Analytics to analyse traffic, remarket our products and
services to users, improve our marketing, advertising, and to improve our website.
We have enabled Google Analytics advertising features such as remarketing with Google Analytics,
Google Display Network Impression Reporting, and Google Analytics Demographics and Interest
Reporting.
Google Analytics collects only the IP address assigned to you on the date you visit our website, not your
name or other identifying information.
We do not combine the information collected using Google Analytics with Personal Data.
Google Analytics plants a cookie in your web browser to identify you as a unique user the next time
you visit our website, the cookie cannot be used by anyone but Google. Google also uses specific
identifiers to help collect information about the use of our website.
All data handled by Google is retained for 14 months from your last visit, the minimum term they allow.
For more information on how Google collects and processes your data, visit
https://www.google.com/policies/privacy/partners/.
0
6You can prevent Google Analytics from using your information by opting out via this link:
https://tools.google.com/dlpage/gaoptout.
CONTACT US
If you have any questions about how we process your personal data, please contact us:
store@inex.club.
7

Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent.

We may also collect, use and share aggregated data. Such data is derived from personal data, but cannot be directly or indirectly identified by you.

However, if the aggregated data is combined with your personal data, which leads directly or indirectly to the possibility of identifying with you, then such data will be treated by us as personal data and protected in accordance with the terms of this provision.

We do not collect any special categories of personal data about you (including information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
Our site is not intended for children and we do not knowingly collect data relating to children.


PERIOD OF STORAGE OF YOUR PERSONAL DATA
We keep your personal data for the entire period while you are a member of INEX Club, as well as for ten years after you have ceased to be a member of INEX Club.
If you were not a member of INEX Club, we store your personal data for ten years after it was provided or collected.


YOUR RIGHTS IN RELATION TO THE PERSONAL DATA
You have the right to request access to the personal data ZAK INEX CLUB LTD holds about you. In order for us to comply with such a request, you will have to submit a Subject Access Request (SAR). We may require you to prove your identity with two pieces of approved identification. We will respond to a SAR within 30 days.
Information about requested personal data provided free of charge.


Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, ZAK INEX CLUB LTD may either:

• charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested;
• refuse to act on the request.
• As well as the right to access the personal data ZAK INEX CLUB LTD holds about you, you have a number of other rights in respect of your personal data under the data protection laws. These may include (as relevant):
• The right to rectification, including to require us to correct inaccurate personal data;
• The right to request restriction of processing concerning you or to object to processing of
• your personal data;
• The right to request the erasure of your personal data where it is no longer necessary for
• us to retain it;
• The right to data portability including to obtain personal data in a commonly used
• machine readable format in certain circumstances such as where our processing of it is
• based on a consent;
• The right to object to automated decision making including profiling (if any) that has a
• legal or significant effect on you as an individual;
• where you have an option to provide us with your personal data or not in connection with
• your use of our Website or in connection with any of our products or services, you have the right to be informed about the possible consequences of not giving it to us; and
• The right to withdraw your consent to any processing for which you have previously given that consent.

TRANSFER OF PERSONAL DATA
Advertisers and advertising networks sometimes require data to select and serve relevant advertisements to you and others. We may provide them with aggregate cookie information about our users with certain attributes (for example, we may inform them that 100 men aged under 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women who are interested in cycling).

We share cookie data with other publishers via a secure data management platform when advertising campaigns are served across multiple news websites. These publisher partners are not able to access this data themselves, only serve the advertisements across their own websites to readers whose cookie data form part of the selected advertising segments.

We reserve the right to disclose your personal information to comply with applicable laws and government or regulatory bodies' lawful requests for information.

Your personal details may be shared with third party organisations we have contracted to provide services to us which include processing data. For example, to send you the emails you have signed up for. Only companies who can provide adequate safeguards will be used to ensure your data is stored and handled securely.

We may also have to release information because of a legal requirement on us or pursuant to a court order.

We may transfer, sell or assign any of the information described in this Privacy Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.

We may transfer your personal data in order to fulfill our obligations to you, such as, for example, purchasing tickets for all types of transport, hotel reservations, visa support before sports camps, ordering and purchasing equipment, clothing, gear, sports nutrition, etc.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA working for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

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 the 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 transfer to US group companies or use providers who are based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Google Analytics
Our website uses Google Analytics to collect information about the use of our website.
Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website.

We use the information we get from Google Analytics to analyse traffic, remarket our products and services to users, improve our marketing, advertising, and to improve our website.

We have enabled Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting.
Google Analytics collects only the IP address assigned to you on the date you visit our website, not your name or other identifying information.

We do not combine the information collected using Google Analytics with Personal Data. Google Analytics plants a cookie in your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our website.
All data handled by Google is retained for 14 months from your last visit, the minimum term they allow.
For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/.

You can prevent Google Analytics from using your information by opting out via this link: https://tools.google.com/dlpage/gaoptout.


CONTACT US
If you have any questions about how we process your personal data, please contact us:
privacy@inex.club.