Privacy Policy

Last updated: 30 October 2026

1. Who we are

“We”, “us” or “our” means IntuEdrive BV, with its registered office at Oudebaan 130, 3360 Bierbeek, Belgium, registered under company number BE 0687.717.132.

IntuEdrive BV acts as the data controller for the personal data collected through your use of our website and the Ellio app.

This Privacy Policy provides information on the processing of personal data through our website, the Ellio app and related online interactions. Section 11 describes the Ellio app specifically. For privacy practices related to our services, reference is made to the agreements that may be concluded between you and us.

Your privacy is important to us. This Privacy Policy explains how we collect, use, store, disclose and protect your personal data, and which rights you have under applicable data protection laws.

If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data, or if you wish to exercise your rights, you may contact us:

• By email: privacy@intuedrive.com
• By post: IntuEdrive BV, Privacy Officer, Oudebaan 130, 3360 Bierbeek, Belgium

IntuEdrive BV has not appointed a formal Data Protection Officer (DPO), as it is not legally required under Article 37 of the GDPR. Privacy matters are handled internally by a designated Privacy Officer.

2. What is personal data?

Personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, for example by reference to a name, contact details, an online identifier, or location data.

3. How we collect and use personal data

3.1 How personal data is collected

We collect personal data in the following ways:

• When you voluntarily provide information via our website forms, including contact forms, newsletter subscription forms, service forms, dealer forms, test ride forms and warranty forms
• When you communicate with us by email or phone
• Automatically, through your use of our website via cookies and similar technologies

We do not collect personal data from third-party data brokers and do not enrich profiles with external datasets.

3.2 Categories of personal data

Depending on how you interact with our website, we may process the following categories of personal data:

• Identity data, such as first name and last name
• Contact data, such as email address, phone number, postal code and address information
• Communication data, including information you provide in free-text fields
• Usage and technical data, such as IP address, browser type, device type, operating system, language settings, pages visited and timestamps
• Approximate location data derived from IP address

We do not process special categories of personal data, such as health data, biometric data or data relating to criminal convictions.

3.3 Purposes of processing

We process personal data only for the following purposes:

• Responding to inquiries and requests submitted via our website
• Managing sales and service communications
• Contacting individuals by email or phone where requested or appropriate
• Sending newsletters and marketing communications to subscribers
• Managing long sales cycles and keeping a record of prior interactions
• Supporting, securing and improving the functionality of our website
• Analyzing website usage and performance
• Complying with legal obligations
• Establishing, exercising or defending legal claims

Personal data is not used for purposes that are incompatible with those listed above.

3.4 Legal bases for processing

We process personal data only where a lawful basis applies under the GDPR, including:

• Consent, for newsletter subscriptions via our website, for marketing communications to people who are not our customers, and for non-essential cookies
• Legitimate interest, for responding to inquiries, managing sales and service relationships, maintaining interaction history, sending existing customers information about similar products and services unless they have objected, ensuring website security and improving website performance
• Legal obligation, where processing is required to comply with applicable laws

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Where processing is based on legitimate interest, you have the right to object as described in Section 6.

4. Retention of personal data

We retain personal data only for as long as necessary to achieve the purposes for which it was collected, or as required by applicable law.

Contact and service inquiries are retained for up to 24 months after the last interaction.

Newsletter subscription data is retained until you unsubscribe.

Sales and marketing interaction history, such as records of contact dates, communication channels, consent status and interaction outcomes, is retained for up to five (5) years after the last meaningful interaction. This allows us to manage long sales cycles, avoid repeated or inappropriate contact, and demonstrate prior communications if necessary.

Website usage and analytics data is retained for up to 12 months.

Cookie consent records are retained for 12 months.

Personal data may be retained for a longer period where required to comply with legal obligations or for the establishment, exercise or defense of legal claims.

After the applicable retention period, personal data is securely deleted or anonymized.

Where you withdraw consent or successfully object to processing, your personal data will be deleted unless retention is necessary to respect your preferences (for example, maintaining a “do not contact” suppression record) or to comply with legal obligations.

5. Sharing personal data with third parties

To operate our website and communications, we use trusted service providers acting as data processors, including website hosting, email services, newsletter distribution and analytics providers.

The service providers used for the Ellio app are listed in Section 11.3.

These processors act only on our instructions and under appropriate data processing agreements in accordance with Article 28 of the GDPR.

We may also disclose personal data where such disclosure is required by law, or where necessary to protect our legal rights or the vital interests of individuals.

We do not sell personal data to third parties.

6. Your rights

You have the following rights under applicable data protection law:

• The right to access your personal data
• The right to rectification of inaccurate or incomplete data
• The right to erasure of your personal data under certain conditions
• The right to restriction of processing
• The right to data portability
• The right to object to processing based on legitimate interest or for direct marketing
• The right to withdraw consent at any time, where processing is based on consent

To exercise your rights, you may submit a written request using the contact details provided in Section 1. We will respond without undue delay and in any event within one month.

You also have the right to lodge a complaint with the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit) at www.dataprotectionauthority.be.

7. Cookies and similar technologies

7.1 What are cookies?

Cookies are small text files placed on your device when you visit a website. Cookies allow a website to recognize your device and store information about your preferences or past actions. We also use similar technologies such as pixels and tags. For the purposes of this Privacy Policy, all such technologies are referred to as “cookies”.

7.2 Which cookies we use

Our website uses strictly necessary cookies that are required for the proper functioning of the website, such as remembering your cookie preferences and enabling form submissions.

We also use analytical cookies to understand how visitors interact with our website. These cookies are used only after you have given your consent. We use Google Analytics 4, with IP anonymization enabled, to collect information such as pages visited, time spent on pages, browser and device type, and approximate location.

In addition, we use marketing cookies to measure the effectiveness of advertising campaigns and display relevant advertisements. These cookies are used only after you have given your explicit consent. Marketing cookies include technologies provided by Google Ads and Meta (Facebook/Instagram).

7.3 Cookie consent management

We use Cookiebot as our cookie consent management platform.

When you first visit our website, you are presented with a cookie banner that allows you to accept all cookies, reject non-essential cookies, or set granular preferences by cookie category.

Analytical and marketing cookies are not placed before you have provided valid consent. You may withdraw or modify your consent at any time via the cookie settings available on our website.

7.4 Cookie storage duration

Cookies are stored for varying periods depending on their purpose. Necessary cookies may be session-based or stored for a limited duration. Analytical and marketing cookies are generally stored for up to 12 months, unless renewed with your consent. Cookie consent records are stored for 12 months.

7.5 Managing cookies

You can manage or delete cookies at any time via our cookie settings or through your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

More information about cookies can be found at https://www.allaboutcookies.org.

7.6 Third-party cookies

Some cookies are placed by third parties whose services are integrated into our website. These third parties may act as independent controllers and process personal data in accordance with their own privacy policies. We encourage you to review their privacy information for further details.

8. International data transfers

Our website does not intentionally transfer personal data outside the European Economic Area. For the Ellio app, some service providers process data in the United States, as described in Section 11.4.

Where service providers process data outside the EEA incidentally, appropriate safeguards such as Standard Contractual Clauses are in place to ensure adequate protection.

9. Security of personal data

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration or misuse. These measures include access controls, secure hosting environments, encryption in transit and regular system updates.

10. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy from time to time. The most recent version will always be available on our website. Where legally required, we will request your consent for material changes.

11. The Ellio app

This section applies when you use the Ellio app on Android or iOS. IntuEdrive BV is the data controller. Sections 1, 2, 5, 6 and 9 of this Privacy Policy also apply.

11.1 Personal data the app processes

• Account data: your email address and password, entered on the app's sign-in page, which is provided by Amazon Cognito. Your password is handled by Amazon Cognito and never reaches us.
• Profile data: your first name, last name and phone number, which are required when you set up your account, and your address (street, number, box, postal code, municipality and country).
• Additional email addresses that you confirm in the app with a six-digit code, so the app can find orders placed under those addresses.
• Your quotes, orders and bikes that are linked to your email addresses in our ERP system. The app displays them and keeps a copy in its own database.
• The location of your bike. The app does not use the location of your phone or other device.

11.2 Purposes and legal bases

• To provide the app and its features: your account, profile, orders, bikes and service. Legal basis: performance of a contract.
• To keep our customer administration up to date: your profile becomes a customer contact in our ERP system, and changes made in the ERP system are shown in the app. Legal basis: performance of a contract and compliance with legal obligations, such as invoicing and warranty.

We may also use your name and email address to send you newsletters and information about Ellio products and services similar to those you bought from us. You can object to this at any time, free of charge: when you create your account, in the Account section of the app, via the unsubscribe link in every message, or by contacting us (see Section 1). Legal basis: legitimate interest, and for existing customers the legal exception for electronic marketing of similar products and services. If you have not bought anything from us, we only send you marketing with your consent.

11.3 Service providers and recipients

• Amazon Web Services: sign-in (Amazon Cognito), the app's servers and database, and confirmation emails (Amazon SES), in the Frankfurt region (EU).
• Expo (650 Industries, Inc., United States): delivers app updates and receives the app version, the platform and a random installation ID for that purpose.
• Google, in the Android app only: the map uses the Google Maps SDK, which sends technical data to Google, such as the device model and operating system, crash data, IP address, a pseudonymous identifier and map interactions. On iPhone, the map uses Apple Maps.
• Our own ERP system, for our customer administration.

11.4 Transfers outside the EEA

Expo and Google may process the data described above in the United States. These transfers rely on the EU-U.S. Data Privacy Framework or on Standard Contractual Clauses.

11.5 What the app does not do

The app shows no advertising, does not use an advertising identifier and does not use its own analytics or tracking tools.

11.6 Retention

• App data is kept until you delete your account. It is then deleted immediately. We only keep a technical record that the account was deleted, without your name, address or email address, so that an old sign-in on another device no longer works.
• Your purchase and the related customer data in our ERP system (quote, order, invoice, delivery and warranty) are kept for as long as required by law and by your warranty, and no longer than 10 years after your purchase.

11.7 Your rights in the app

You can view and correct your profile in the app at any time. You can delete your account in the app, or without the app via rideellio.com/account-verwijderen. For your other rights, see Section 6.

11.8 Security

All traffic between the app and our servers is encrypted (HTTPS). The app asks for your password again before your account is deleted.

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