Privacy policy
This Privacy Policy explains how ReBake Supply Co AB processes personal data when you visit rebakemotors.com, submit an enquiry or sign-up form, communicate with us, own a ReBake vehicle, or otherwise interact with us. It also explains the rights you have over your personal data and how to exercise them.
Please read it carefully. If any term of this Privacy Policy conflicts with our Terms of Service, this Privacy Policy prevails in respect of the collection, use, and disclosure of personal data.
1. Data controller
ReBake Supply Co AB is the data controller for the processing described in this Privacy Policy, unless expressly stated otherwise.
Company ReBake Supply Co AB
Reg. no. 559521-5608
VAT no. SE559521560801
Address Birger Jarlsgatan 119, 113 56 Stockholm, Sweden
Email admin@rebakemotors.com
Where you interact with an authorised ReBake distributor or retailer, that party acts as an independent data controller for its own processing. This is described in section 6.
2. How we sell, and why that matters for your data
ReBake does not sell vehicles directly to customers through this website. We work through a network of authorised distributors and retailers, with one appointed distributor per market, who handle sales, delivery, registration support, financing and insurance guidance, service, spare parts, and warranty administration in their territory.
This has a direct consequence for how your personal data is handled. When you submit an enquiry asking to buy, test ride, or otherwise obtain a ReBake vehicle, fulfilling that request necessarily involves passing your enquiry to the authorised partner responsible for your market. We explain this at the point of collection on every relevant form, and it is set out in full in section 6.
3. Categories of personal data we process
We process the following categories of personal data. The categories that apply to you depend on how you interact with us.
Contact data Name, email address, telephone number, country, and postal address where provided.
Enquiry data The content of the enquiry or form you submit, including your stated interest, your market, your driving licence category where you provide it, and any free-text information you choose to include.
Business data Where you enquire on behalf of an organisation: company name, role, website, and the description of your business and operations that you provide.
Ownership data Vehicle identification number (VIN), model, configuration, date and place of purchase, appointed retailer, service history, and warranty records.
Communication data Correspondence with us by email, form, telephone, or social channels, and records of support matters.
Marketing data Subscription status, preferences, and engagement with our communications such as opens and clicks.
Technical data IP address, device and browser information, and information about your interaction with our website collected through cookies and similar technologies, in accordance with your cookie preferences.
We do not knowingly collect special categories of personal data as defined in Article 9 of the GDPR. Please do not include such information in free-text fields.
4. Purposes, legal bases, and retention
We process personal data only where we have a lawful basis to do so under Article 6 of the GDPR. The table below sets out each purpose, the data involved, the legal basis relied upon, and how long we retain the data for that purpose.
|
Purpose |
Data categories |
Legal basis |
Retention |
|---|---|---|---|
|
Responding to your enquiry and connecting you with the authorised partner for your market |
Contact data, enquiry data, business data |
Article 6(1)(b) GDPR: steps taken at your request prior to entering into a contract. Where no contract is in prospect, Article 6(1)(f): our legitimate interest in operating a distribution-led sales model and responding to enquiries directed to us. |
24 months from your last interaction with us, unless the enquiry results in a purchase, in which case ownership retention applies. |
|
Administering the ownership relationship, including warranty, service history, spare parts, and technical support |
Ownership data, contact data, communication data |
Article 6(1)(b): performance of the warranty and support obligations attaching to the vehicle. Article 6(1)(c): compliance with product safety and vehicle traceability obligations. |
For the service life of the vehicle and a further 3 years, reflecting the warranty attaching to ReBake vehicles. |
|
Vehicle safety, recall administration, and traceability |
Ownership data, contact data |
Article 6(1)(c): compliance with our legal obligations under applicable product safety, type approval, and market surveillance rules. Article 6(1)(f): our legitimate interest, and the overriding interest of riders, in being able to contact owners about a safety matter. |
For the service life of the vehicle and a further 10 years, or longer where required by applicable law. |
|
Sending newsletters, launch information, event invitations, and owner updates |
Contact data, marketing data |
Article 6(1)(a): your consent, which you may withdraw at any time. Article 6(1)(f) for communications to existing customers about goods and services similar to those already supplied, subject to your right to object. |
Until you withdraw consent or object, and in any case no longer than 24 months from your last engagement with our communications. |
|
Operating, securing, and improving our website |
Technical data |
Article 6(1)(f): our legitimate interest in a functioning and secure website, for strictly necessary cookies. Article 6(1)(a): your consent for analytics and marketing cookies. |
As set out in our Cookie Policy. |
|
Managing distributor, retailer, supplier, and partner relationships |
Contact data, business data, communication data |
Article 6(1)(b) where you are a party to an agreement with us. Article 6(1)(f): our legitimate interest in managing our commercial relationships where you represent an organisation. |
For the duration of the relationship and 7 years thereafter, aligned with statutory accounting retention. |
|
Complying with accounting, tax, and other statutory obligations |
Contact data, ownership data, transaction records |
Article 6(1)(c): compliance with a legal obligation. |
7 years from the end of the relevant financial year, in accordance with the Swedish Bookkeeping Act. |
|
Establishing, exercising, or defending legal claims |
Any data relevant to the claim |
Article 6(1)(f): our legitimate interest in protecting our legal position. |
For the duration of the matter and any applicable limitation period. |
A note on our retention periods
ReBake vehicles are registered road vehicles supplied with a warranty and serviced through an authorised partner network. We are also subject to product safety and market surveillance obligations that require us to be able to identify and contact the owners of vehicles placed on the market, including in the event of a recall. Our retention periods for ownership data are set by reference to those obligations and to the expected service life of the vehicle, not by reference to commercial convenience. Where the underlying purpose ends, for example where a vehicle is permanently withdrawn from use and we are notified, we will delete or anonymise the associated data.
5. Where we obtain personal data
• Directly from you, when you complete a form, contact us, attend an event or test ride, or purchase a vehicle.
• From our authorised distributors and retailers, where you have purchased or serviced a vehicle through them and the data is required for warranty, safety, or support purposes.
• Automatically from your device when you use our website, in accordance with your cookie preferences.
• From service providers acting on our behalf.
• From publicly available sources, where relevant to a business enquiry.
6. Sharing your personal data
6.1 Authorised distributors and retailers
Because we do not sell directly, we share enquiry and ownership data with the authorised ReBake distributor or retailer responsible for your market, so that they can respond to your enquiry, arrange a test ride, complete a sale, register the vehicle, provide financing or insurance guidance, and deliver service, spare parts, and warranty support.
Our authorised distributors and retailers act as independent data controllers in respect of their own processing of your personal data. They are contractually required to process personal data in accordance with applicable data protection law, to use it only for the purposes set out above, and not to use it for unrelated purposes. Each partner is responsible for providing its own privacy information to you and for handling requests relating to its own processing.
We share your data only with the partner appointed for your market. We do not sell personal data, and we do not share your data with partners outside the ReBake network for their own marketing purposes.
Where no authorised partner has yet been appointed in your market, we retain your enquiry so that we can contact you once a partner is in place, and we share nothing until that point.
6.2 Service providers
We use third-party service providers who process personal data on our behalf as processors, under written data processing agreements. These include providers of website hosting and e-commerce infrastructure, email and marketing communication platforms, customer relationship management systems, cloud storage, analytics, and IT support.
6.3 Other recipients
• Professional advisers, including legal, accounting, and insurance advisers, where necessary.
• Public authorities and law enforcement, where we are legally required to disclose.
• Financing and insurance providers, where you have requested a quotation or application through a partner.
• A purchaser or prospective purchaser, in connection with a corporate transaction, restructuring, or financing.
7. International transfers
We are established in Sweden and process personal data primarily within the European Economic Area. Certain service providers and manufacturing partners are located outside the EEA, including in China and the United States.
Where personal data is transferred outside the EEA, we rely on an adequacy decision of the European Commission where one applies, and otherwise on the European Commission's Standard Contractual Clauses together with any supplementary technical, contractual, and organisational measures required following an assessment of the laws and practice of the recipient country. You may request further information on the safeguards applied by contacting us at admin@rebakemotors.com.
8. Your rights
Subject to the conditions and exceptions in applicable law, you have the following rights:
Access To obtain confirmation of whether we process your personal data and to receive a copy of it.
Rectification To have inaccurate or incomplete personal data corrected.
Erasure To have your personal data deleted, where we no longer have a lawful basis to retain it. Please note that we may be unable to delete ownership and safety records where retention is required for product safety, warranty, or statutory purposes.
Restriction To request that we limit our processing in certain circumstances.
Portability To receive personal data you have provided to us in a structured, commonly used, machine-readable format, where processing is based on consent or contract and carried out by automated means.
Objection To object to processing based on our legitimate interests, on grounds relating to your particular situation. You may object to direct marketing at any time, without needing to give a reason, and we will stop.
Withdrawal of consent To withdraw consent at any time, where processing is based on consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact us at admin@rebakemotors.com. We will respond within one month, and will tell you if we need longer because your request is complex. We may need to verify your identity before acting on a request. We will not treat you less favourably for exercising your rights.
If your request concerns processing carried out by an authorised distributor or retailer as an independent controller, we will direct you to the relevant partner.
9. Marketing communications
You may unsubscribe from marketing communications at any time by using the unsubscribe link in any message, or by contacting us. If you unsubscribe, we may still send you communications that are necessary for the ownership of your vehicle, such as safety notices, recall information, and warranty or service matters. Those communications are not marketing and cannot be opted out of while you own the vehicle.
10. Cookies
We use cookies and similar technologies on our website. Strictly necessary cookies are set on the basis of our legitimate interest in providing a secure and functional website. Analytics and marketing cookies are set only with your consent, which you provide through the cookie banner and may change at any time. Further detail is set out in our Cookie Policy.
11. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage. These include access controls, encryption in transit, and contractual security obligations on our service providers. No transmission or storage method is entirely secure, and we ask that you do not send sensitive information to us through unsecured channels.
12. Children
Our website and services are not directed at children. We do not knowingly collect personal data from persons below the age of majority in their jurisdiction. If you believe a child has provided us with personal data, contact us and we will delete it.
13. Complaints
If you have a concern about how we process your personal data, please contact us first at admin@rebakemotors.com so that we can address it. You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement. Our lead supervisory authority is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), Box 8114, 104 20 Stockholm, imy@imy.se.
14. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or for operational, legal, or regulatory reasons. We will publish the updated version on this website and update the date below. Where changes are material, we will provide notice as required by applicable law.
