TRACEFY PRIVACY STATEMENT
Privacy Statement, April 2026
Welcome! Thank you for reading our privacy statement, because it means that you consider privacy as important as we do. We have carefully prepared this privacy statement for you so that it is clear to you what happens to your data when you use the Tracefy app (or white-label apps), portal or website or we use your data in any other way.
Who are we? (Who is the data controller?)
Tracefy B.V.
Treubstraat 27
2288 EH Rijswijk
We are registered with the Chamber of Commerce under number 66322642
You can call us on: +31 (0)10 3073199
Or send an email to: info@tracefy.com
Tracefy is a young Dutch company that offers specialised IoT solutions for bicycles and other vehicles such as scooters, cars and kick scooters. For ease of reading, we will refer to them as “bicycles” hereafter, but we also mean other vehicles if you use our GPS system for them.
The GPS system and the Tracefy app allow you to track your bike (or have it tracked) if it is stolen provided you have a subscription for this. Moreover, in the Tracefy app, you can see where your bike is in real time and you can make use of the app's other great features such as viewing rides and distances. Likewise, you can get a reminder for maintenance via your bike shop. As you might normally get that via email, it will now be based on usage via the app.
We are the supplier of the GPS system in your bike and the owners of the Tracefy app. We provide our services to consumers but also have business customers who use our app, for example for their company bicycles. In such cases, we act as a data processor. Business customers must inform the people who use their bicycles about the processing of their personal data. This is usually set out in their privacy notice.
Who are you? (Who is the person involved)
We hope you are reading this privacy statement because you have purchased or are using a bicycle equipped with the Tracefy GPS system. In addition, you have taken out a subscription through us for the connectivity of your GPS tracker with or without tracking through G4S or Recoveryservice NL. You may also be someone who appears in videos we make about thefts involving our GPS trackers. Or you may be someone with whom we communicate, for example via online social media channels.
This privacy statement is about your personal data. For convenience, in this privacy statement we (also) use the word "data" when talking about your personal data. According to the law, you are called a "data subject" in this situation.
What are personal data?
Personal data are pieces of information that allow other people to see or understand that it is about you.
We are a supplier of the GPS system in your bicycle. GPS allows location to be determined. In order to determine the location of your bicycle and to be able to trace your bicycle in case of theft, we ask you to enter various personal data, such as your name, address and phone number, in the Tracefy app. As the recipient of these data, we know that you have entered the data in the Tracefy app and have purchased or used a bicycle with a GPS system or a GPS system for your bicycle. Therefore, by entering your data in the Tracefy app, we receive information about you. In this privacy statement, we explain to you what information this is and what we do with it.
What data do we collect?
Data via the Tracefy app
When you install our app and cycle, we collect data about you. All this data is needed to locate your bike and track it down in case of theft. This is because if the bike is stolen, we need to be able to make sure it is returned to you if you also have a tracking subscription. So we also need your data for that. We request the following data from you where the data marked * is really needed so that you can make good use of the Tracefy GPS system and your bike can be traced in case of theft.
Mr / Mrs
First name and surname *
Gender
Date of birth
Address *
Postcode*
City *
Country *
Phone number *
Email address *
Bike name *
Insurer
Policy number
* If you do not wish to enter this information, you will unfortunately not be able to use the GPS system on your bike or the accompanying app. This information is required, amongst other things, for the KIWA certificate linked to your GPS system.
Just as you have an app to see the location of your bike and routes ridden, we have developed a dashboard showing all your data, location and routes ridden of all bikes with a Tracefy GPS system. If your bike is stolen, we can track and trace it and see where it is. In addition, we can see all routes ridden and statistics such as average km per trip, stop and start locations, average trip duration, etc.
It is also important to note that Tracefy does not collect the individual location of the smartphone. If permission is given for the app to retrieve the smartphone's location, the location is displayed on the map in the app, but the location is not stored on Tracefy's dashboard. This is because the location processing of the smartphone on the map in the app is local processing on the smartphone and not processing in Tracefy's dashboard. Tracefy can therefore only see the location and ridden routes of bikes, not your personal smartphone location data.
Data in videos
If you appear in images we take of thefts, the images and other information that allow you to be recognised are personal data about you. We do not make videos that include recognisable suspects. We also try to make other people (such as police and passers-by) unrecognisable but cannot guarantee that they will never be recognisable. Therefore, personal data may appear in the videos.
Contact details
When you contact us online (via social media) or through other channels, we process your profile or contact details and any other personal data contained in the messages we exchange with one another.
What do we do with your data? (the purposes of processing)
We don't collect your data for no reason. We collect the data to do the following with it:
1. To ensure that you can use the features in the app
Several functions in the app require processing and storing data.
This allows you to see driven routes and distances in the app. There is also the function to get a reminder for servicing.
2. Being able to track your bike
If your bike is stolen, report it as stolen in the app. This will activate the tracking service. We may also activate the tracking service ourselves if your bike’s location matches certain suspicious criteria. For example, if the bike is travelling at a certain speed (in which case it may be inside a car) or if it is located in a high-risk area. The tracking service will then locate your bike and, once it has been found, return it to your bike shop (and may notify you personally). To carry out these actions, we need to process and store your data.
3. For maintenance, repair or replacement by your service technician (bicycle repairer)
As your app also includes a maintenance feature, bicycle manufacturers and bike mechanics can set it up so that you automatically receive notifications via the app based on a certain number of kilometres cycled. Such a notification might, for example, state that it is time for your first service. For example, the bike shop might set it up in advance so that anyone who has cycled 500 km automatically receives a notification that it is time for a service. Incidentally, the bike shop does not have access to your personal data in this process. You can then decide for yourself whether or not to make a separate appointment with your bike shop.
If our GPS tracker needs to be serviced, repaired or replaced by one of our authorised dealers (bike mechanics), the dealer may need temporary access to the bike’s location to check whether the service, repair or replacement has been successful. You will receive a notification from us regarding this. This access will be deactivated after 24 hours.
4. Access to anonymous user profiles and heatmaps
Based on your cycling behaviour and that of other cyclists, we carry out analyses and create anonymous user profiles. Manufacturers, dealers and/or bicycle hire companies, or mobility providers, can view these anonymous user profiles on our online dashboard. Furthermore, they can view heatmaps (popular routes) on our online dashboard. Based on this anonymous data and the heatmaps, dealers and/or bike hire companies or mobility providers can, for example, make product improvements to their bikes.
It is important to emphasise that only anonymous data is shared with manufacturers, dealers and/or bicycle hire companies, or mobility providers. They cannot view data relating to an individual bicycle, a user and/or a location. Anonymous data can only be viewed for a minimum of 10 bicycles. This also applies to heatmaps: a heatmap showing frequently used routes (i.e. involving at least 10 cyclists) can only be viewed for a minimum of 10 bicycles. The anonymous data cannot therefore be traced back to you. However, we mention this here to make it clear that we are able to anonymise (aggregate) the data.
5. To ensure that your app and your data are visible on your mobile device and remain so
Of course, if you open the app again, it's nice if you don't have to enter your details again.
5. Conduct analytics to understand app usage
We are naturally curious to know whether the app is easy and fun to use. That is why we use your data (obviously not for commercial purposes) and can see through our own dashboard how often the app is used, at what times, in what locations and for how long. We can also use the dashboard to track whether the app gives problems and how often those problems occur.
7. So that we know which insurer has insured your bike
Your insurer can request information from us about the theft and tracking of your bicycle. To know that the insurer requesting this information is really your insurer, we administer which insurance company you are insured with, including your policy number. The name of your insurer is linked to the GPS tracker on your bicycle so that the insurer can check whether you have a certified GPS tracker.
8. To find out whether you have paid for the subscription
You pay for the subscription via a payment provider (Mollie). We do not receive your payment information but we do receive whether your payment was successful or not. We also put this information in our financial records.
9. For marketing and (online) engagement
We use your (contact) details when you get in touch with us or when we contact you. For example, if you ask questions about our products or services via an online enquiry form. Or if we wish to inform you about topics of interest, such as when your bike needs servicing. Online, we also interact with people who are interested in our products, services or our company.
When you contact our customer service team, we process the relevant data. We may do this via email, telephone or chat messages. Depending on the situation, we may then ask for information such as whether you are the owner of the vehicle, your name and your postcode.
To show what a ‘pop-up’ looks like using our GPS trackers, we publish videos of some thefts on online (social media) channels.
10. For administrative purposes and to comply with legal obligations
We store your details in our records to keep track of who our customers are and, therefore, who has taken out a subscription with us. We also do this to comply with tax legislation. In addition, we may be legally obliged to disclose certain data to public authorities, such as the tax authorities during audits or to the police in connection with investigations into the whereabouts of your bicycle.
What are the bases for using your data? (the bases)
We may only process personal data if there is a valid legal basis for doing so.
We use your data on the following legal bases:
– Performance of a contract with you.
In order to provide you with our services (your subscription for the GPS tracker’s connectivity, the app, and to help you track your bike in the event of theft), we need your details.
– On the basis of your consent, such as:
We ask your explicit consent for the use of your location data. Location data is sensitive data. Since we use your location data, we specifically ask for your permission to share location data in the app. If you do not give or withdraw your consent to the use of your location data in the app, we will be able to track your bike, but you will not be able to see the routes and we will not be able to track your bike in case of theft.
We also specifically ask your permission to send you notifications to service your bicycle. If you do not consent to the sending of notifications or withdraw your consent, you will not receive any reminders to service your bicycle.
Incidentally, if you give your consent, this also means that you may withdraw your consent at any time. This does not affect the lawfulness of the processing that took place before you withdrew your consent.
- Based on a legitimate interest.
To (i) provide access to anonymous user profiles and heatmaps; (ii) carry out analyses of app usage (as described above); (iii) ensure that the maintenance, repair or replacement of the GPS tracker has been carried out correctly, (iv) to keep records, (v) for marketing purposes, (vi) to know which insurer you are insured with, and (vii) more generally, to run our business and provide the app, it is necessary to process your personal data. Otherwise, we cannot achieve these objectives. In addition, we need to process your personal data in order to communicate with you (online). And in order to publish videos of thefts to promote our products, services and business, these may contain images of people. We do, however, take the privacy interests of these people into account as much as possible, for example by blurring faces.
- Based on legal obligations
To comply with our legal obligation to keep financial records, we need to process data about your payment (whether you have paid or not). We may also be required to provide certain data on an individual basis, for example if the police or another government agency requests it from us.
Do you have any questions or comments about our use of your data?
You have a say in what we are allowed to do with your data. This is because you have the following rights:
- (i) the right to request whether data about you is being processed and, if so, to access it;
- (ii) the right to request rectification and erasure of that data. To a large extent, by the way, you can manage this yourself via your profile and settings of your browser or mobile device;
- (iii) the right to object to processing or request restriction of processing;
- (iv) the right to withdraw consent to processing, if the processing is based on your consent;
- (v) the right to receive or deliver your data, in a structured, common and machine-readable form;
- the right to lodge a complaint with a supervisory authority responsible for ensuring compliance with the rules on the protection of personal data. In the Netherlands, this is the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl).
Please do get in touch if you wish to exercise any of your rights. You can contact us using the contact details provided at the beginning of this privacy notice.
Incidentally, the rights are not absolute; they do not apply in all circumstances and applicable regulations provide for necessary exceptions. If we do not comply with your request, we will explain why.
Do we share your data with others?
Yes, we share your data.
Our suppliers
We do not manage and support the Tracefy app and the dashboard where we can view the data entirely on our own. We are assisted in this by companies which, as a result, automatically process your data – solely for that purpose. These companies are AWS (Amazon Web Services), an IT company that provides server hosting and backups, and Auth0, an IT company that provides the login functionality. These companies operate on our instructions. We have entered into a data processing agreement with these companies.
Detection
If a bicycle is reported as stolen, we will share your details with the G4S or Recoveryservice NL tracing service. This will allow them to contact you directly regarding the search. If the bicycle has indeed been stolen, we will report this to KIWA in connection with the KIWA certification. Is the bicycle insured? If so, the insurer can verify this information with KIWA.
Dealer / bicycle repairer
When servicing, repairing or replacing the GPS tracker, the dealer (bicycle repairer) carrying out the work may need temporary access to the bicycle’s location, as indicated above.
Insurance companies
As explained above, insurers may request information about the theft and tracking of the bike. This may require sharing your details with them, such as your name and tracing information traceable to you.
KIWA
If your bicycle is stolen, details of the theft will be passed on to KIWA, as described above.
Mollie
You pay for your subscription via the payment provider (Mollie); you can find their privacy policy here: https://www.mollie.com/nl/privacy. They are responsible for processing your payment details. We only receive a notification from them as to whether the payment was successful or not.
Requests from third parties
Furthermore, we may – only where we are legally obliged to do so or where there is a legitimate interest on the part of a third party – disclose your personal data to supervisory authorities, other parties, individuals or authorities.
Disputes
In the event of a dispute with you, we may be obliged to share relevant information with third parties, such as a bailiff, a solicitor or a court.
Do we receive your data from others?
Yes, we receive videos of thefts from the investigative services we work with or from people working on their behalf. We receive limited details (name, email address) from the dealer where you bought your bike so that we can send you an email about activating your account. In addition, we may receive information from your insurer regarding your policy with them so that we can verify whether you are indeed insured with them. In response to requests from third parties (such as the police), we may receive limited details about you so that we can act on the request.
Is your data safe with us?
We consider the security of your personal data important. We have therefore taken appropriate technical and organisational measures to secure your personal data against loss or any form of unlawful processing. This means that while using the app and all functionalities there is always a secure (SSL) connection, and that we have a policy stating who can access your data when and why, and that we back up files, install updates on time and use anti-virus software. Moreover, our employees are bound by confidentiality, and must comply with our instructions aimed at the adequate protection of your data.
Cookies on our websites
Our websites https:// tracefy.com and https://portal.tracefy.com https://portal.tracefy.io use cookies. This is because we use Google Analytics 4, a service that provides us with insights into how our website is used. This includes usage statistics such as the number of unique visitors, the pages most frequently visited and the average duration of a visit. We do not collect any IP addresses that can be traced back to you.
How long do we use your data?
Data in the app
We will retain your data for as long as you keep it available in the app.
Location details
Data relating to your bike’s location is stored for as long as you have a subscription and for the period specified below thereafter, whilst with a Solo Tracker, this data is deleted once a thousand location points have been recorded.
Data following cancellation of subscription
Once your subscription ends, we will retain your subscription and account details (including location data) for a further period of two years, after which they will be automatically deleted or anonymised.
Information about the insurance
We may retain information about your insurance even after you are no longer a customer of ours. We do this if it is necessary for the insurer’s investigation.
Information on reporting thefts
If the vehicle is reported as stolen, we retain the information relating to the theft for an initial period of 5 years (as this is the statutory limitation period for claims).
Data in financial administration
Data in our financial records is retained for seven years following the relevant financial year.
Online content
We keep videos and other online content online for as long as they remain relevant in the online context. We retain data from our communications with you for as long as is necessary to complete the communication and to archive it for our own records. In some cases, we may retain this data for longer, for example if there is a dispute or if we are legally obliged to do so.
Correspondence
As a general rule, we retain any correspondence with you for 5 years. We may archive this information if necessary for evidential purposes.
Disputes
We will retain information relating to a dispute with you for as long as is necessary to resolve the dispute and during any period allowed for lodging an appeal.
Amendments to this privacy statement
Everything in life is subject to change. That includes our privacy statement. We will inform you (where possible) of any significant changes. In any case, you can check the reference number and date of this privacy statement to see whether this is the same version you have read previously.
