TwoZero – Global Privacy Policy (GDPR-Compliant)

Last updated: 25 November 2025

TwoZero (“we”, “us”, “our”) is committed to protecting your privacy and handling your personal data in a transparent and secure manner. This Privacy Policy explains how we collect, use, store, share and protect personal data when you visit our website, create an account, contact us, or use our products and services.

This Privacy Policy is intended to comply with the EU General Data Protection Regulation (GDPR) and other applicable privacy laws in the countries where our users are located.

If you have any questions, you can contact us at:
Email: support@twozero.no

  1. Data Controller

The entity responsible for processing your personal data (the “data controller”) is:

TwoZero A Phase Energy AS Company.
Askerveien 6
1384 Asker, Norway
Email: support@twozero.no

Depending on your location, additional local legal entities or representatives may be involved; if required by law, we will inform you separately.

  1. What Personal Data We Collect

We only collect personal data that you provide to us or that is generated through your use of our website and services.

2.1 Data You Provide Directly

Examples include:

  • Contact details: name, email address, phone number, postal address
  • Account information: username, password, account preferences
  • Order and purchase information: billing details, shipping address, order history
  • Support and communication data: messages you send us via email, contact forms, or customer support
  • Comments and reviews: content you post as comments on our website, including the data you enter in the comment form

2.2 Data Collected Automatically

When you visit our website, we may automatically collect:

  • IP address and approximate location (at country or region level)
  • Browser type and version
  • Device information (e.g. device type, operating system)
  • Pages viewed, time spent on pages, and clickstream data
  • Cookies and similar technologies (see Section 8)

2.3 Data from Third Parties

We may receive limited personal data from third-party tools and services, such as:

  • Analytics providers (e.g. Google Analytics, Segment, Hotjar)
  • Marketing and advertising partners (e.g. Meta/Facebook)
  • Gravatar for profile images tied to your email when you comment

These third parties act either as our processors (processing data on our behalf) or as independent controllers under their own privacy policies.

  1. Special Cases: Comments, Media, and Embedded Content

3.1 Comments

When you leave a comment, we collect:

  • The information you provide in the comment form
  • Your IP address and browser user agent string (to help with spam detection)

We may use an anonymised hash of your email address with the Gravatar service to check whether you use it. Gravatar’s privacy policy applies for that service. Once your comment is approved, your profile image (if enabled) may appear publicly in connection with your comment.

3.2 Media Uploads

If you upload images to our website, you should avoid uploading images containing EXIF GPS data (location data). Visitors may be able to download such images and extract the location data.

3.3 Embedded Content from Other Websites

Articles on our website may include embedded content (e.g. videos, images, social media posts, maps). Embedded content behaves exactly as if you visited the originating website directly.
These external websites may collect data about you, use cookies and third-party tracking, and monitor your interaction with the embedded content. We encourage you to review the privacy policies of those third-party sites.

  1. Legal Bases for Processing (GDPR)

Where GDPR or similar laws apply, we process your personal data based on one or more of the following legal grounds:

  • Contract performance: to perform a contract with you or take steps at your request before entering into a contract (e.g. processing orders, managing your account).
  • Legitimate interests: to operate, improve, and secure our website and services, and to communicate with you about relevant updates and offers, provided that these interests are not overridden by your rights and interests.
  • Consent: where required by law (e.g. for certain marketing communications or non-essential cookies). You can withdraw consent at any time.
  • Legal obligations: to comply with legal, regulatory, accounting, or tax requirements.
  1. How We Use Your Data

We use your personal data for the following purposes:

  1. Provision of services and fulfilment of contracts
    • Creating and managing user accounts
    • Processing orders and reservations
    • Delivering products and customer support
  2. Communication
    • Responding to your inquiries and support requests
    • Sending service-related messages (e.g. order confirmations, account notices)
    • Sending newsletters and marketing communications (where permitted by law or based on your consent)
  3. Improvement of our website and products
    • Analysing how visitors use our website
    • Monitoring performance and detecting errors
    • Developing and improving our products, services, and user experience
  4. Security and fraud prevention
    • Protecting our systems and users
    • Preventing misuse of our services
    • Detecting and responding to potential security incidents
  5. Marketing and personalization
    • Delivering relevant content and offers, including online advertising
    • Using aggregated and anonymised data to understand trends and preferences

We may also process anonymised or aggregated data that cannot identify you, for statistical and analytical purposes.

  1. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes described above, or as required by law.

For example:

  • Comments: We keep comments and related metadata indefinitely, so we can recognise and automatically approve follow-up comments.
  • User accounts: We store personal data associated with your account for as long as your account is active. If you request deletion of your account, we will remove or anonymise your personal data unless retention is legally required.
  • Legal and accounting purposes: Certain records may be retained for a legally required period (e.g. tax, accounting, regulatory compliance).

When data is no longer needed, we will either delete it securely or anonymise it.

  1. Sharing Your Data with Third Parties

We do not sell your personal data to third parties.

We may share your data with:

  • Service providers / processors who perform services on our behalf (hosting, analytics, payment processing, email services, customer support tools, etc.). They are bound by contracts that require them to protect your data and only use it according to our instructions.
  • Professional advisers (lawyers, accountants, auditors) where necessary.
  • Authorities and regulators if required by law, court order, or to protect our legal rights.
  • Business transfers: In connection with a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction, in accordance with applicable laws.

TwoZero remains responsible for how your personal data is processed when shared with processors.

  1. International Data Transfers

Your personal data may be processed in countries outside your country of residence, including outside the EU/EEA. Where such transfers occur, we will ensure an appropriate level of protection, for example by:

  • Transferring data to countries recognised by the European Commission as providing an adequate level of protection; or
  • Using standard contractual clauses approved by the European Commission or other equivalent safeguards; or
  • Ensuring other appropriate safeguards are in place as required by applicable law.

You can contact us for more information on international data transfers and the safeguards we use.

  1. Cookies and Similar Technologies

We use cookies and similar technologies to operate our website, analyse traffic, and personalise content and advertising.

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They can be used to:

  • Remember your preferences and settings
  • Keep you logged in
  • Understand how you navigate our site
  • Support analytics and marketing activities

9.2 Types of Cookies We Use

  • Strictly necessary cookies: Required for the basic operation of the website and cannot be switched off in our systems.
  • Performance/analytics cookies: Help us understand how visitors use the site (e.g. which pages are most popular) so we can improve it.
  • Functionality cookies: Remember your preferences and settings to provide a more personalised experience.
  • Advertising/marketing cookies: Used to deliver relevant ads and measure marketing effectiveness (e.g. Facebook/Meta cookies).

9.3 Managing Cookies

You can manage cookie preferences in your browser settings and, where available, via our cookie banner or consent tool. You may block cookies, but this may affect your ability to use some features of our website.

For more details on specific cookies (such as _ga, _gid, ajs_user_id, Hotjar, and Facebook/Meta cookies), please refer to our Cookie Notice or cookie table on our website.

  1. Your Privacy Rights

Depending on your location and applicable law (including GDPR), you may have some or all of the following rights:

  1. Right of access: To obtain confirmation whether we process your personal data and, if so, to receive a copy.
  2. Right to rectification: To have inaccurate or incomplete personal data corrected.
  3. Right to erasure (“right to be forgotten”): To request the deletion of your personal data in certain circumstances (e.g. when it is no longer needed for the purposes for which it was collected, or you withdraw consent and no other legal base applies).
  4. Right to restriction of processing: To restrict processing of your data in certain situations (e.g. when accuracy is contested or processing is unlawful).
  5. Right to data portability: To receive your data in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible and where processing is based on consent or contract and carried out by automated means.
  6. Right to object: To object to processing based on legitimate interests, including profiling, and to direct marketing at any time.
  7. Right to withdraw consent: Where processing is based on your consent, you may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

You can exercise these rights by contacting us at hello@twozero.no. We may need to verify your identity before fulfilling your request.

If you believe that our processing of your personal data violates applicable data protection laws, you also have the right to lodge a complaint with your local data protection authority.

  1. Security of Your Data

We take appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised access, or disclosure.

Measures may include:

  • Access controls and authentication
  • Encryption where appropriate
  • Secure hosting environments
  • Regular monitoring and reviews of security practices

However, no system is completely secure, and we cannot guarantee absolute security of your data. You are responsible for keeping your login credentials confidential and notifying us immediately if you suspect unauthorised use of your account.

  1. Children’s Privacy

Our website and services are not directed at children under the age of 16 (or a higher age where required by local law). We do not knowingly collect personal data from children.
If we become aware that we have collected personal data from a child without appropriate consent, we will take steps to delete that information.

  1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. The “Last updated” date at the top indicates when the latest revision was made.

We encourage you to review this Privacy Policy periodically. If we make material changes, we will provide appropriate notice (e.g. via the website or email).

  1. Contact Details

For questions, requests, or concerns regarding this Privacy Policy or our handling of your personal data, please contact:

TwoZero
Askerveien 6
1384 Asker, Norway
Email: hello@twozero.no

Plain-Language Summary for Customers

This section is a simple explanation of what’s above. It does not replace the full legal text, but it helps you understand what we do.

  1. Who we are

We are TwoZero, and we run this website and sell our products (like the Frikar E-bike). We’re responsible for what happens to your personal data.

  1. What information we collect

We collect:

  • Things you type in (name, email, address, phone, comments, messages)
  • Things your browser sends automatically (IP address, browser type, pages you visit)
  • Information from cookies and tools like Google Analytics or Facebook

We do not collect more than we need.

  1. Why we collect it

We use your data to:

  • Let you create and manage an account
  • Process your orders and reservations
  • Send you confirmations and important messages
  • Answer questions and offer support
  • Improve our website and services
  • Show you relevant information and offers

We may also use anonymised data (that can’t identify you) to understand how people use our site.

  1. Who sees your data
  • We do not sell your personal data.
  • We share it only with trusted partners who help us run the website, process payments, send emails, analyse traffic, etc.
  • They must follow strict rules and can’t use your data for their own purposes.
  1. Cookies

Cookies are small files on your device that help us:

  • Remember you and your preferences
  • Understand how people use our site
  • Improve the site and show relevant content

You can block or delete cookies in your browser, but some parts of the site may not work properly.

  1. Your rights

You can:

  • Ask what data we have about you
  • Ask us to correct wrong information
  • Ask us to delete your data (in many cases)
  • Ask us to send you your data in a portable format
  • Say no to certain types of use (like direct marketing)
  • Withdraw consent at any time (e.g. unsubscribe from newsletters)

Just email us at support@twozero.no.

  1. How long we keep it

We keep your data only as long as we need it to:

  • Run your account
  • Provide services and support
  • Follow the law (for example, for accounting and taxes)

After that, we delete or anonymise it.

  1. Security

We use technical and organisational measures to keep your data safe. No system is perfect, but we work hard to protect your information.

  1. Questions?

If you’re unsure about anything or want to use your rights, just contact us at:
📧 support@twozero.no

 

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