Effective date: August 12, 2025

This privacy policy describes how SPIA Cycling Inc. ("SPIA", "we", "us" or "our") collects, uses, and discloses personal data when you use our Stages Cycling App ("App”). This privacy policy also describes how we use and disclose personal data about you and the rights that you can exercise in relation to your personal data.

It is important that you read this privacy policy together with any other privacy policy or fair processing 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 policy supplements other notices and privacy policies and is not intended to override them. In some cases, we may provide different or additional policies or notices about our information practices.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data or information where the identity or identifiers have been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, date of birth, weight, and gender.
• Contact Data includes email address.
• Technical Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device make and model, and other technology on the devices you use to access this App.
• Location Data includes GPS technology used to determine your current location. This is collected when you activate location-enabled services such as Google Maps or other embedded mapping features.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our App, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect and use Aggregated Data such as statistical data or any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific application 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 policy.

We do not collect any Special Categories of Personal Data, Sensitive Personal Information or Sensitive Personal Data, as defined under the applicable laws, about you (this includes details 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 or information about criminal convictions and offences).

However, we may collect limited data about you that could arguably be used to infer further data regarding your health (e.g., functional threshold power, cadence, balance, heart rate and calorie consumption), in order to support certain features of the App (“Physiological Data”). Notwithstanding that such personal data may not constitute Special Category Personal Data, this data will only be used with your explicit consent for the purposes described at the point of collection and will be processed in accordance with applicable data protection laws.

This App is not intended for, or designed to be attractive to, children under the age of 16 and we do not knowingly collect data relating to such children.

If you fail to provide personal data

Where we need to collect 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.

2. How is your personal data collected?

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

• Information you provide to us. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • provide and maintain our service;
  • create and manage an account;
  • download or register one of our applications;
  • subscribe to our service or publications;
  • request marketing (such as news, special offers, and general information about our goods, services and events) to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Information collected by your use of our services. For example, Usage Data will be collected when you use our App. Some of our location-enabled applications require your Location Data (but not precise geolocation) for certain features to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in the settings.
• Automated technologies or interactions. Technical Data about your equipment and use of the App may be collected where you have given your consent for us to collect such data for analytics purposes. Where such consent has been provided, we use such data to analyse the performance of the App and to report any bugs that you may experience.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers, such as Google (which provides anonymized and aggregated data only) and Firebase (which provides analytics and bug reports if you have consented for this information to be processed).
  • Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.
  • Location Data from embedded maps providers, such as Google in order to plot your starting point and route.
  • Identity and Contact Data from publicly available sources.

3. How will 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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we have your consent to do so.

Purposes for which we will use your personal data

We have set out below the ways in which we may use your personal data, along with the relevant legal bases we may rely on to do so.

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 where more than one ground has been set out in the table below.

Please note that we may process your personal data without your knowledge or consent, in compliance with applicable law.

We will use your personal data to provide you with products and services, to enhance your experience using our sites, applications, or in our stores, and for other business purposes. Examples of how we may use your personal data, include:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest (where required under applicable law)
To register you as a new customer or create an account on the App and provide you with the App on an ongoing basis.	(a) Identity (b) Contact (c) Profile Data	(a) Necessary for our legitimate interests (to manage our customers)
To provide you with certain services or features at your request.	(a) Identity Data (b) Physiological Data (c) Location Data	(a)  Necessary for our legitimate interests (to provide requested services) (b) Consent (for Physiological or Location Data)
To manage our relationship with you which may include: (a) Notifying you about changes to our terms or privacy policy (b) Enabling you to partake in a prize draw, competition, or lottery	(a) Identity (b) Contact (c) Profile Data (d) Usage Data (e) Marketing and Communications Data	(a) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (b) Necessary to comply with a legal obligation
To administer and protect our business, this App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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
To use data analytics to improve our App, applications, products/services, marketing, customer relationships and experiences	(a) Identity (b) Contact (c) Technical Data (d) Profile Data (e) Usage Data	(a) Necessary for our legitimate interests (to improve our products and service, to keep our App updated and relevant) (b) Consent

If based in the EEA or UK

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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  You can update your marketing preferences at any time by following the opt-out links on any marketing message sent to you, or by adjusting your preferences in the profile page of the App, or by emailing [email protected]. This will not stop us from sending emails about your account with us.

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

If you are based in the EEA or UK, or if otherwise required by applicable law, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4. Disclosures of your personal data

We may share your personal data with the third parties, such as:

• Other companies in the Giant Group that are involved in the provision of products or services to you;
• Service providers, vendors, and contractors who perform services on our behalf and who may act as processors (e.g., who provide IT and system administration services, payment processing services, customer service, or marketing).
• Professional advisers, such as lawyers, accountants, bankers, auditors and insurers (e.g., where they are providing us with advice or when we need to make a claim on any insurance policies).
• Regulators and authorities who require reporting of processing activities in certain circumstances (e.g., tax authorities or authorities responsible for preventing fraud).
• Law enforcement authorities that submit binding legal requests for information that includes your personal data. We may also share personal data on receipt of non-binding requests where we consider that it is in our legitimate interests to do so and this is not outweighed by your fundamental rights and freedoms.
• Where your personal data is relevant to any litigation or alternative dispute resolution in which we are involved, we may share your personal data with the other parties to that dispute or the courts (e.g., in disclosure or discovery).
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets (or other third parties for example when connected with due diligence or planning exercises undertaken in relation to such a transaction). 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 policy.

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.

5. Third party links and integrations

This App may contain links to other websites whose data practices may be different than ours. The App also enables you to connect your Stages Cycling account with accounts on third party apps (e.g., connected fitness, performance, and activity tracking apps). If you choose to link your account or activities with such third-party platforms then we will receive and share relevant personal data with these platforms based on your consent and relevant configurations. These integrations are optional and managed by you via the App settings. Please consult all third-party sites’ and apps’ privacy policies. We have no control over, and disclaim any and all responsibility and liability in connection with, information that is submitted to, shared with, or collected by, third parties.

If you choose to log in to the App using your social media account, we only collect your email address and profile photo. We do not collect any other information or share any data with your social media platform.

6. International transfers of EEA and UK personal data

Personal data that we process about you may in some cases be further transferred to third parties that are based outside the UK and the European Economic Area (“EEA”). Where necessary, we ensure appropriate safeguards are in place for transfers to such third parties to protect your personal data (such as model clauses approved for this purpose by the EU Commission and the UK Information Commissioner).

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when it is transferred outside the UK or EEA. To obtain such information, please use the contact details contained in this policy.

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. How long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. If you remain inactive, we will only retain your personal data for up to two years from the date of your last activity. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.
 

9. Your legal rights

If you reside in the U.S.:

• Accessing or Correcting Your Information. You can access, correct, or delete certain information by emailing [email protected].
• Location Information. If our App collect precise location information, you will be asked to consent to the collection of this information.  If you initially consent to the collection of such information, you can subsequently stop the collection of this information at a later time by modifying the preferences on your mobile device.
• Push Notifications. With your consent, we may send push notifications or alerts to your mobile device.  You can stop these notifications/alerts at any time by changing the preferences on your mobile device.
• Promotional Emails. You can choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from us.  This will not stop us from sending emails about your account with us.

If you reside in the EEA or UK

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. In certain circumstances, this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by emailing [email protected].

You also have the right to make a complaint at any time to the relevant supervisory authority in the jurisdiction in which you are based, such as the Information Commissioner’s Office (the UK regulator for data protection issues). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so please contact us in the first instance.

No fee usually required

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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.

If you reside in another jurisdiction:

You may have certain rights in relation to your personal data if you reside in a jurisdiction other than the EEA, UK, or U.S.  If you reside in such jurisdiction, please contact us using the details in this privacy policy if you wish to understand your personal data rights.

10. How to contact us

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your rights, please contact us using the details set out below.

Email address: [email protected]

Address: 5335 Sterling Drive, Boulder CO 80301

11. Changes to the privacy policy and your duty to inform us of changes

This version was last updated on the date indicated at the top of this policy. We will review our privacy policy periodically and update the content as necessary.

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

U.S. State Privacy Notice

Effective date: August 11, 2025

Consistent with the applicable U.S. laws, you may exercise the rights described in this section. Please note that some of the rights may vary depending on your U.S. state of residence.

California Notice at Collection – This Privacy Notice services as our notice at collection for California residents.

Notice for Nevada Residents – Section 5 of this Notice further contains a Notice for Nevada Residents.

This U.S. State Privacy Notice is layered to help you navigate it. By clicking on the different options below, you can expand the relevant sections and read the information that you are interested in. You can also expand all of the sections and print this notice out, using the functionality in your web browser.

1. Collection, Use, and Disclosure of Personal Information
2. Sharing and Selling of Personal Information and Targeted Advertising
3. Your Privacy Rights
4. Notice for Nevada Residents
5. Note of "Do Not Track" Policy

1. Collection, Use and Disclosure of Personal Information

Our Privacy Policy explains how we collect, use, and disclose personal information. The table below lists the categories of personal information we have collected during the past 12 months, the sources of the information, our business purpose for the use of this information, and the third-party recipients, if any, of the information.

Category of Information collected	Source	Business purposes* for use	Categories of third parties receiving information
Identifiers (e.g., name, alias, email address, account name, unique personal identifier)	Individuals submitting information to us;	Security detection, protection and enforcement; functionality debugging/error repair; performing services for you; internal research and development.	Service providers (such as mail houses, marketing partners); affiliated companies; government regulators; law enforcement;
Protected Information (user name and password)	Individuals submitting information.	Security detection, protection and enforcement; performing services for you; internal research and development.	Service providers (such as vendors who provide cyber security service); government regulators; law enforcement.
Protected anti-discrimination classification information (gender)	Individuals submitting information.	Performing services for you; internal research and development; compliance with law.	Government regulators; law enforcement;
Commercial information	Not Collected	Not Collected	Not Disclose
Electronic network activity (App interactions)	Information automatically collected from App users.	Functionality debugging/error repair; internal research and development.	Government regulators; law enforcement; strategically aligned businesses.
Audio, video or similar information	Not Collected	Not Collected	Not Disclose
Biometrics and Consumer Health Data (such as functional threshold power, cadence, balance, heart rate and calorie consumption)	Information we collect from App users with your consent.	Performing services for you.	Not Disclose
Geolocation (such as Google maps acquired location information)	Information we collect from App user.	Performing services for you; internal research and development.	Service providers (such as Google, displaying embedded maps)
Professional, educational or employment related information	Not Collected	Not Collected	Not Disclose
Sensory Data (such as functional threshold power, cadence, balance. heart rate and calorie consumption)	Information we collect from App users’ devices such as heart rate monitors, power meter and indoor trainers.	Performing services for you; internal research and development.	Government regulators; law enforcement.
Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)	Internal analytics	Internal research and development.	Not Disclose

*More specifically, the business purposes include:

1. Performing services for you:
   • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
   • To respond to queries or requests and to provide services and support;
   • To provide customer relationship management;
   • To create and manage our customer accounts;
   • To notify you about changes to our services and products;
   • To administer any promotion, contest, survey, or competition;
   • To provide you information regarding our products and services,
   • To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.
2. Advertising customization:
   • For marketing and promotions, we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.
3. Auditing relating to internal research and development:
   • To provide for internal business administration and operations, including troubleshooting, services customization, enhancement or development, testing, research, administration and operation of our App and data analytics;
   • To create products or services that may meet your needs;
   • To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.
4. Security detection, protection and enforcement; functionality debugging, error repair:
   • As part of our efforts to keep our App safe and secure;
   • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our App, for example, by requesting verification information in order to reset your account password (if applicable);
   • To ensure the physical security of our premises through the monitoring of surveillance images;
   • To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.
5. Quality control:
   • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,
   • To develop and improve our products and services, for example, by reviewing visits to our App and various features and subpages, demand for specific products and services and user comments.

2. Sharing and Selling of Personal Information and Targeted Advertising

We do not “sell” or “share” your personal information or use your personal information for “targeted advertisement”, as these terms are defined by applicable law.

3. Your Privacy Rights

You have the following rights. If you wish to exercise any of these rights, please contact us by emailing [email protected].

Opting Out of Sales, Sharing, and Targeted Advertising. You have the right to opt-out of having your personal information shared, sold, or used for targeted advertising or profiling. As stated above, we do not “sell” or “share” your personal information or use your personal information for “targeted advertising” so we do not offer this right.

Access, Correction, and Deletion. Subject to certain exceptions and limitations found in the relevant laws, you have access, correction, and deletion rights.

You have a right to request details about the information we have collected about you and how such information is used and disclosed.  You also have a right to obtain your personal information in a format that is portable.

Depending on your state of residence in the U.S. you may also have a right to ask us to correct inaccurate information, subject to the nature of the personal information collected and how it is used.

You further can request that we delete personal information that we have collected about you. We will honour your request to the extent required by applicable law and subject to certain legal exceptions, like if we need to retain information for legitimate business purposes.

Appeals. There may be times when we deny your privacy requests. Depending on your state of residence in the U.S. you may have a right to appeal these decisions.  If you have concerns about your appeal, you may contact the attorney general of your state.

Non-Discrimination. We will not discriminate against you for exercising your privacy rights.

Authorized Agents. Depending on your state of residence in the U.S. you may designate an authorized agent to submit privacy right requests on your behalf. We may ask for proof of a designated agent’s authority and confirm that they are registered with the appropriate state authorities.  In some circumstances, we may contact you to verify your identity and confirm that the agent has your permission to submit a request.

4. Notice to Nevada Residents/Your Nevada Privacy Rights

As noted above, we will not sell your information. However, if you are a Nevada resident, you may submit a request to opt out of future sales by emailing [email protected]. We will maintain your request in the event our practices change in the future. Should your email address change, please submit a new request.  We reserve the right to take reasonable steps to verify your identity and the authenticity of the request.

5. "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our App does not respond to Do Not Track (DNT) signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.