Privacy Policy

Privacy Policy

CicloZone Limited — last updated 4 July 2026

Please read this privacy policy carefully before using this website, our applications or our platform.

CicloZone is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy policy.

CicloZone may change this policy from time to time by updating this page; check this page from time to time to ensure that you are happy with any changes.

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, application users and platform (Studio) customers.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of those individuals; in other words, where we determine the purposes and means of the processing of that personal data. It also explains the limited circumstances in which we act as a processor on behalf of a Studio (see Section 3).

1.3 This policy covers both our marketing website and the CicloZone application, the CicloStudio platform and our trainer education portal. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, “we”, “us” and “our” refer to CicloZone Limited. For more information about us, see Section 11.

1.5 Age and children. The CicloZone service is intended for adults aged 18 and over (or the age of majority where you live). It is not directed at children, and we do not knowingly collect personal data from anyone under 18. This is consistent with our Rider Terms of Service, which require you to be at least 18 years old to use the service.

2. How we use your personal data

2.1 In this Section 2 we have set out: (a) the general categories of personal data that we may process; (b) the purposes for which we may process personal data; and (c) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is your consent, which you give via our cookie banner when you first visit our website; you may withdraw that consent at any time (see Section 9 and our Cookie Policy).

2.3 We may process your personal data that are provided in the course of the use of our services (“service data”). The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.5 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us (“transaction data”). CicloZone does not store your full payment card details. Payments are handled by third parties: in-app purchases are processed by the Apple App Store and Google Play, and any direct or web-portal purchases (for example, Education Course purchases) are processed by a third-party payment provider. CicloZone receives transaction and confirmation data (such as the amount, date, and subscription status) but not your full card number. The transaction data may also include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and our legitimate interests, namely the proper administration of our website and business.

2.7 We may process information that you provide to us for the purpose of subscribing to our newsletter (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.8 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3. Our applications and platform (Riders, trainers and Studios)

3.1 In addition to our website, we provide the CicloZone application (used by Riders and trainers), the CicloStudio platform (used by Studios) and a separate education portal for trainers. This Section 3 explains how we process personal data in connection with those applications and platform. Health and fitness data is dealt with separately in Section 6.

3.2 Account credentials. To authenticate access to the application and platform, we process the minimum account credentials needed — such as a login identifier, authentication credentials, and any email address used to create the account. We act as a controller of these credentials, process them solely to provide and secure access to the service, apply appropriate security measures, retain them only as long as necessary, and do not sell them. The legal basis is our legitimate interests in providing and securing access, and/or the performance of a contract.

3.3 IP address and location. We may process the IP address(es) and location data from which the application and platform are accessed, for the purposes of security, prevention of unauthorised use, and enforcement of our software licences (including our per-Studio, single-address licensing). The legal basis is our legitimate interests in securing our services and protecting our and our licensors’ rights.

3.4 Studio and business-contact data. We hold limited personal data relating to our business customers (Studios) and their representatives, such as business contact and billing details, as a controller, solely to provide the service, manage the account, take payment and comply with law. We process this data in accordance with the UK GDPR and the Data Protection Act 2018, keep it only as long as necessary, apply appropriate security measures, and do not sell it.

3.5 Trainer-activity data (we act as processor for Studios). Through a Studio’s control panel we make available information about trainer activity (such as the number and timing of classes a trainer delivers). We do not disclose to a Studio which individual Riders attended. In respect of trainer-activity data shown in the control panel, the Studio is the controller and we act as its processor, processing that data only on the Studio’s documented instructions to display it in the panel. The Studio is responsible for the lawful basis for that processing and for informing its trainers. Our processor obligations (consistent with UK GDPR Article 28) are set out in our Studio terms.

3.6 Aggregated and anonymous data. We may collect and use anonymous, aggregated analytics, telemetry and attendance data (which do not identify any individual) to operate, secure and improve our services and to produce statistics for Studios, including aggregated demographic statistics such as age and gender. Such statistics are provided only in aggregated form and only where the group is large enough to prevent identification of any individual. We may retain and use such anonymous data without restriction.

3.7 Education portal for trainers. We operate a separate education portal for trainers, in which we process limited trainer data — the trainer’s name and email, their test/qualification status, and the schedule of classes assigned to them — to operate the portal and make it available to the trainer’s Studio. Trainers accept the portal’s terms and the processing of this data when they first access the portal. We hold this data minimally, apply appropriate security, and do not sell it.

3.8 Hosting and security. The limited data we store (such as account credentials and Studio/representative data) is hosted in the United Kingdom on Amazon Web Services (London region), encrypted in transit and at rest, with role-based, least-privilege access. It is not routinely transferred outside the United Kingdom or the European Economic Area. See also Section 4 (International transfers).

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom (UK) and, separately, to countries outside the European Economic Area (EEA). Following the UK’s withdrawal from the European Union, the UK and the EEA are distinct destinations for the purposes of data protection law, and a transfer outside the UK is assessed under the UK GDPR while a transfer outside the EEA is assessed under the EU GDPR where applicable.

4.2 We and our other group companies have offices and facilities in the United Kingdom.

4.3 The hosting facilities for our website, and the platform data we store, are situated in the United Kingdom (our platform data is hosted on Amazon Web Services, London region).

4.4 The hosting facilities for our electronic mail are situated in the EEA.

4.5 Where any personal data is transferred outside the UK or the EEA (for example via a content-delivery or analytics provider), we apply an appropriate safeguard or transfer mechanism as required by applicable data protection law.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 Because your workout, training, performance and heart-rate data is stored on your own device and not by us (see Section 6), we do not retain or delete that data; it is controlled by you through your device and the relevant platform’s settings.

5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on our legitimate interest in communicating with you or in providing and securing the service.

5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Health and Fitness Data (Processed Locally on Your Device)

6.1 This Section 6 explains how the CicloZone app interacts with health and fitness data on your device, including data made available through Apple Health or Google Health and heart-rate or training metrics. We do not collect, receive, transmit or store this data. It remains on your own device, under your control, at all times.

6.2 With your device-level permission, the app may read health and fitness data (for example, from Apple Health or Google Health) and process heart-rate and training metrics locally on your device in order to show insights to you. This processing takes place entirely on your device.

6.3 We do not collect this health or training data, we do not transmit it to CicloZone or any third party, and we do not store it on our systems. The data stays on your device and is never sent to us. The only exception is that, in a studio class, you may take a separate, deliberate action in the app to display your live data (such as zones, cadence and heart rate) on a studio screen; that display is live only and is not retained by us.

6.4 You can grant or revoke the app’s permission to access health and fitness data at any time through your device settings (for example, in Apple Health or Google Health permission settings). Revoking permission stops the app from reading that data on your device; because we never held the data, there is nothing for us to delete from our systems.

6.5 Because we do not receive, store or otherwise process this health and training data, we do not act as a controller or processor of it under data protection law. This is consistent with our Data Processing Addendum (available to Studios on request) and the B2C Rider Terms (clause 8.1).

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of significant changes to this policy by email.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection. You can contact the ICO or find out how to make a complaint at www.ico.org.uk. This does not affect any other administrative or judicial remedy available to you.

8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.12 You may exercise any of your rights in relation to your personal data by written notice to us at the details shown in Section 11.

9. Cookies

We use cookies and similar technologies on our website. Full details of the cookies we use, their purposes and how you can manage your preferences are set out in our separate Cookie Policy, available on our website.

10. Studios and other customers’ own responsibilities

10.1 Where a Studio uses our platform to run its classes, the Studio is responsible for its own compliance with data protection law in respect of its Riders, staff and trainers, including providing any notices and obtaining any consents required. A Data Processing Addendum is available to Studios on request.

11. Our details

11.1 This website, and the CicloZone application and platform, are owned and operated by CicloZone Limited.

11.2 We are registered in England and Wales under company number 12320834, and our registered office is CicloZone Limited, Lombard House, Cross Keys, Lichfield, England, WS13 6DN.

11.3 You can contact us: (a) by post, to the postal address given above; (b) by email, at [email protected]; and (c) by telephone, on the contact number published on our website from time to time.

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