EU data Act

PRIVACY POLICY

Introduction

Welcome to Royal Enfield UK Limited’s consumer privacy policy.

1. Important information and who we are

Purpose

This privacy policy aims to give you information on how we collect and process your personal data, including the personal data collected through your use of this website i.e. www.royalenfield.com and its associated sub domains.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

We work with a network of dealers and other partners who are independently owned businesses. You should contact our dealers and partners in the first instance if you have any concerns about how they process your personal data.

Controller

The website www.royalenfield.com and its associated subdomains is owned and run by Eicher Motors Limited which is the parent company of Royal Enfield UK Limited.

In respect of the processing set out in this privacy policy, Royal Enfield UK Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

Contact details

If you would like to exercise any of your legal rights or have any questions about this privacy policy or our privacy practices, please contact our DPO using one of the following methods:
Email address: myprivacy_uk@royalenfield.com
Postal address: Data Protection Officer, Royal Enfield UK Limited, Technology Centre, Bruntingthorpe Proving Ground, Bath Lane, Leicester, Leicestershire, United Kingdom, LE17 5QS

Changes to the privacy policy and your duty to inform us of changes in your personal data

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about a living individual from which that individual can be identified. It does not include data where the identity/identifier has been removed (anonymous data).

 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, title, date of birth and gender.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and authorized bluetooth devices or wifi enabled devices paired with user devices.
Profile Data includes your username and password, profile picture and other pictures uploaded, videos of you (shared by you or uploaded by you on our website or social media handles, or when you agree to appear on the films/videos created by REUK), purchases or orders made by you, dealer branches, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Vehicle Data includes details of your historic and current brand and model of vehicle, model description, colour, capacity, Vehicle Identification Number, registration number, key number, engine number, engine type, selected optional equipment, ownership option (purchase, rental or leasing), number of cars in your household, annual mileage, vehicle purchase spend.

We do not routinely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). It is possible for us to collect, use or store some Special Categories of Personal Data which you have volunteered in an email, during a telephone call, in a form submitted on our website or physically at our dealerships/events as part of managing and responding to your bookings, requests, queries and complaints about our products and services.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your Identity, Financial, Profile, Contact, Vehicle Data, Technical Data, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Create an account on our website and update details;
- Apply to join the Royal Enfield Riders Club;
- Apply for, order or purchase our products and services;
- Make a payment for Royal Enfield Riders Club membership and/or any orders;
- Search for your local dealer or store using our website;
- Make an enquiry on our website;
- Request a brochure or other marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us feedback or contact us by telephone, email or social media.
Automated technologies or interactions: As you interact with our website, we will automatically collect Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy here for further details.
Third parties or publicly available sources: We may receive your personal data from various third parties, our dealer network and public sources set out below:
- Contact Financial and Profile Data from providers of technical, payment, and delivery and fulfilment services;
- Identity and Contact Data from publicly available sources such as Companies House and the Driver and Vehicle Licensing Agency;
- Technical and Usage Data from analytics providers.
- Identity, Contact, Financial, Profile and Vehicle Data from our dealer network; and
- Identity, Contact, Financial, Profile, Marketing and Communications, and Vehicle Data from our marketing and research providers.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including  basis of legitimate interest
To register your account and/or membership  of our Royal Enfield Riders  Club, and to enable you to update details	To register your account and/or membership  of our Royal Enfield Riders  Club, and to enable you to update details (a) Identity(b) Contact(c) Profile Performance of a contract with you	Performance of a contract with you
To process and deliver your membership of the Royal Enfield Riders Club and/or any orders including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Identity(b) Contact(c)  Financial(d) Profile(e) Marketing  and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To find your local dealer or store when you make a request on our website	Technical	Necessary for our legitimate interests (necessary to fulfil your requests relating to our products and services)
To register your warranty, provide you with warranty and after-sales services, or to determine whether a repair can be undertaken under warranty	(a) Identity(b) Contact(c) Vehicle	Performance of a contract with you
To validate ownership of a bike	(a) Identity(b) Contact(c) Vehicle	Performance of a contract with you
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey(c) To manage and respond to your requests (including relating to test rides, apparel and accessories), queries and complaints about our products, services or dealers(d) Complying with requests from you to exercise your data subject rights(e) Analysing how you use our products and services	(a) Identity(b) Contact(c) Profile(d)  Marketing and  Communications(e) Vehicle	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)(d) Necessary for our legitimate interests (necessary for managing your requests, queries, complaints and claims, and for sending communications to you in relation to such requests, queries, complaints and claims)
To contact you in the event of any urgent safety or product recall notices	(a) Identity(b) Contact(c) Vehicle	Necessary in order to protect your vital interests or the vital interests of another person
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity(b) Contact(c) Profile(d)  Usage(e) Marketing  and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and to study how customers use our products/services, to develop them and grow our business)
To notify you about the opening and closing of our dealers in your area	(a) Identity(b) Contact(c) Vehicle	Necessary for our legitimate interests (to keeping to informed about where you can access sales and after-sales services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To make suggestions and recommendations, deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact(c) Technical(d)  Profile(e) Usage(f) Marketing  and Communications	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings	(a) Identity(b) Contact(c) Financial(d)  Profile(e) Usage(f) Marketing  and Communications(g)  Technical(h) Vehicle	-
For the purposes of corporate restructures, reorganisations, or sale of our business or assets	(a) Identity(b) Contact(c) Financial(d)  Technical(e) Profile(f) Usage(g)  Marketing and  Communications(h) Vehicle	Necessary for our legitimate interests (necessary to enable the restructure, reorganisation, sale, or integration of our business)

EU Data Act Information Notice

1. Introduction

This notice provides information about data generated through the use of the Flying Flea electric motorcycle and its associated connected services.

This notice explains:

a) what data the motorcycle and its connected services can generate;

b) the format, estimated volume, and frequency of that data;

c) where the data is stored and how long it is retained;

d) how you can access, retrieve, or erase available data;

e) how you can ask us to share data with a third party;

f) how we may use the data; and

g) how you can contact us or raise a complaint.

Where data referred to in this notice is Personal Data, our collection and use of that Personal Data is governed by the Flying Flea Privacy Notice, available at [Privacy Notice Link]. This notice should be read alongside, and does not duplicate the information already provided there.

2. Scope

This notice applies to:

a) the Flying Flea [FF.C6 / applicable model(s)];

b) the software and connectivity systems installed on the motorcycle;

c) the Flying Flea mobile application

d) the Flying Flea user account and vehicle-pairing system;

e) navigation, route-planning, and "walk to motorcycle" services;

f) remote vehicle-control services (lock/unlock, digital key sharing);

g) security and tamper/theft-monitoring services, including geofencing;

h) diagnostic and vehicle-health services;

i) over-the-air (OTA) software services

j) other digital services that affect, control, or support the operation or behaviour of the motorcycle.

The precise data generated may vary according to motorcycle

model and model year, hardware and software configuration, installed equipment, activated services, user settings, country, connectivity availability, and how the motorcycle and connected services are used.

3. Royal Enfield as Data Holder

The prospective Data Holder for the purposes of the EU Data Act is:

a) Full legal name of the EU entity: Royal Enfield Europe B.V

b) Registered address: Middelweg 3, 4023AR Rijswijk (GLD)

c) Company registration number: 93329016

d) Email: privacy.eu@royalenfield.com

4. Key Definitions

a) Connected Motorcycle — the Flying Flea motorcycle that generates or collects data concerning its use, performance, or environment, and is capable of communicating that data through an electronic communications service, physical connection, or on-device access.

b) Product Data — data generated by the use of the Connected Motorcycle that is designed to be retrievable from the motorcycle, a remote server, or another technical interface.

c) Related Service — a digital service connected to the motorcycle such that its absence would prevent the motorcycle from performing one or more of its functions, or which affects or adapts the motorcycle's functions or behavior (e.g., the Fleaware.OS app, remote lock/unlock, live tracking).

d) Related Service Data — data representing your actions, events, or interactions relating to a Related Service.

e) User — a person or organisation that owns the Connected Motorcycle, has a contractual right to use it, rents or leases it, or receives a Related Service. This includes a secondary rider granted access via Digital PIN Share.

f) Readily Available Data — Product Data and Related Service Data that we lawfully obtain, or can lawfully obtain, from the Connected Motorcycle or Related Service without disproportionate effort.

5. Data Generated by Connected Vehicles

The table below reflects the data categories and parameters generated by the FF

Data Category	Data Parameters	Storage Location
Bluetooth	MAC ID, Device Name	Processed transiently for pairing/connection only
Vehicle Status	Parked, Riding, Charging	Remote (backend systems hosted in Germany and Switzerland)
Location Data	Latitude and Longitude, Charging Points, Location Tags, SOS	Remote (backend systems hosted in Germany and Switzerland)
Vehicle Data	VIN, Colour, Seat, Model, Nickname, Vehicle PIN, SOS	Vehicle PIN stored on-motorcycle (secure hardware memory); remaining vehicle data (VIN, Colour, Seat, Model, Nickname, SOS) stored remotely
Telemetry Data	TPMS (tyre pressure), Motor/Battery/LTE/GPS Health, Odometer Reading, Trip Details, Vehicle Component Firmware/Hardware Versions (VCU, MCU, BMS, OBC, ABS, BCM)	Remote (backend systems hosted in Germany and Switzerland)
Wi-Fi	Device Name, MAC ID	processed transiently for pairing/connection only
Software	Version, Status, Time	Remote (backend systems hosted in Germany and Switzerland)
Riding Modes	Custom, City, Rain, Highway, Sport	Remote (backend systems hosted in Germany and Switzerland
Battery Status	Charging Time, Charging Type, Range, Battery Level, Battery Temperature, Battery Heat/Cold Alerts, Charging Alert	Remote (backend systems hosted in Germany and Switzerland
Remote Lock/Unlock Events	Action type (lock/unlock), method (LTE or Bluetooth), processing status, success/error result, timestamp, location, and user ID logged for every action	Remote (backend systems hosted in Germany and Switzerland
Incognito Mode Status	Active/inactive status, countdown timer, auto-deactivation trigger (crash/SOS override)	Remote (backend systems hosted in Germany and Switzerland
Tamper / Tow / Theft Alerts	Unauthorised movement detection, component tampering detection, GPS coordinates at time of alert, Harsh Acceleration/Braking Alerts, Overspeed Alerts	Remote (backend systems hosted in Germany and Switzerland
Emergency / Crash Detection	Crash detection trigger, automatic override of Incognito/Vacation modes	Remote (backend systems hosted in Germany and Switzerland
Geofencing	Polygon boundary (up to 10 points) or radius-based boundary configuration, breach events	Remote (backend systems hosted in Germany and Switzerland
Navigation — "Walk to Motorcycle"	Last parked location, walking directions, distance, estimated time (requires GPS)	Remote (backend systems hosted in Germany and Switzerland
Ride Mode Customisation (Custom Mode)	Power output, torque map, regen coast, regenerative braking level (10% increments), ABS level (1–4)	Remote (backend systems hosted in Germany and Switzerland
Regenerative Braking	Configurable braking regeneration setting	Remote (backend systems hosted in Germany and Switzerland
Lean-Angle ABS	ABS level setting (1–4; Level 1 = Rear ABS Off)	Remote (backend systems hosted in Germany and Switzerland
Traction Control & Hill Hold	Status (display-only, synced from vehicle cluster)	Remote (backend systems hosted in Germany and Switzerland
Digital PIN Share (Phone-as-Key)	Digital key share status (Active/Inactive), share duration, revocation events	Remote (backend systems hosted in Germany and Switzerland
Vehicle PIN Reset/Renewal	OTP-authenticated reset events, failed attempt count (lockout after 3 failed attempts)	the Vehicle PIN itself is stored on-motorcycle (secure hardware memory); the reset/renewal event log is stored remotely (backend systems)
Data Sync Metadata	Last-synced timestamp; sync typically occurs within 5 seconds across app, cloud, and vehicle cluster	Remote (backend systems hosted in Germany)
Remote Live Tracking (Shared Access)	Secure link generation for non-app users, OTP-authenticated access, link validity period	session-based; not retained beyond session expiry
Vehicle CAN Data	Motor and battery control signals (e.g., motor RPM/torque, battery cell voltage/current, charger input-output values), vehicle mode and drive-state signals, sensor and diagnostic signals from vehicle control units	Remote (backend systems hosted in Germany and Switzerland
Diagnostic Trouble Code (DTC) Data	Fault/malfunction codes generated by onboard control units (e.g., battery, motor, charging, braking systems), used for diagnostics and maintenance	Remote (backend systems hosted in Germany and Switzerland
Contextual Vehicle Warnings	On-display warnings such as battery derating, low SOC, thermal/insulation faults, sensor faults	Remote (backend systems hosted in Germany and Switzerland
Network Connectivity Data	Signal strength and quality indicators (e.g., LTE/Wi-Fi/Bluetooth signal strength, network latency, connection type), used to maintain connected services	Remote (backend systems hosted in Germany and Switzerland
Inertial/Motion Data (IMU)	Lean angle, acceleration, orientation data used to support ABS, traction control, and crash-detection features	Remote (backend systems hosted in Germany and Switzerland
Component Fault & Status Signals	Status and fault indicators from vehicle subsystems (e.g., lock/handlebar module, lighting, charge port), used for diagnostics and remote support	Remote (backend systems hosted in Germany and Switzerland
Vehicle Software/Version Data	Firmware, hardware, and bootloader version identifiers for individual vehicle control units, used for OTA updates and diagnostics	Remote (backend systems hosted in Germany and Switzerland

6. Data Format

Product Data and Related Service Data may be generated internally in formats including numeric values, Boolean/status values (e.g., ACTIVE/INACTIVE), text strings, timestamps, geographical coordinates, event/log records, diagnostic trouble codes (DTCs), and structured telemetry formats.

Data made available to you will be provided in PDF, together with the metadata necessary to understand and use the data (e.g., timestamp, user ID, and location).

Some data generated within individual vehicle components may use proprietary technical formats. Where such data constitutes Readily Available Data, it will be converted into, or accompanied by information that renders it in, a comprehensive, structured, commonly used, and machine-readable format.

7. Estimated Data Volumes

a) On-motorcycle data generated: 15 MB per day considering a 2 Hr ride

b) Related Service Data (app-level): 450 MB/month

The actual volume will depend on factors including frequency and duration of use, number and length of journeys, activated connected services (e.g., live tracking, navigation use, software version, network availability, occurrence of warning/diagnostic/security events, and user settings.

8. Continuous and Real-Time Data Generation

Some data is generated and synced continuously or near-continuously while the motorcycle is in use:

a)Live location tracking updates every 2–5 seconds when active.

b) App-cloud-vehicle cluster sync for settings and status changes typically completes within 5 seconds.

c) The app displays a "Last synced" timestamp and will notify the user if data is outdated (e.g., not synced within 24 hours).

Other data is generated on a periodic or event-triggered basis, including at ignition on/off, at app connection/synchronization, when a connected function is used (e.g., a lock/unlock command), when a warning, fault, tamper, or safety event occurs (e.g., crash detection, geofence breach), during charging, during servicing/diagnostics, or when a remote command is issued.

9. Storage and Retention

Data Category	Retention Period
Vehicle authentication credentials, certificates, keys	1 year
Vehicle Status, Location Data, Telemetry Data, Trip Details, Riding Modes, Battery Status	7 years
Remote Lock/Unlock Events, Tamper/Tow/Theft Alerts, Emergency/Crash Detection, Geofencing	7 years
Digital PIN Share, Vehicle PIN Reset/Renewal events	7 years
Remote Live Tracking (Shared Access)	7 years
Bluetooth, Wi-Fi (MAC ID, Device Name)	7 years

10. Your Rights

You may access Readily Available Data generated through your use of Connected Motorcycle and Related Services. Some data is directly accessible through the motorcycle's display cluster, the Flying Flea app, or your user account for example, battery state of charge, charging time remaining, vehicle health status, and current ride mode.

Other data may only be available from Flying Flea's backend systems and must be requested through a request by email: [to be shared by Legal]

We shall share your Data, without undue delay, free of charge and in a secure (location and sensitive data are encrypted during transmission and storage), comprehensively, structured, commonly used, and machine-readable format with the relevant metadata necessary to interpret and use it; at the same level of quality available to us; and continuously and in real time where relevant and technically feasible.

Some products or related service data may contain or be linked to trade secrets. We will inform you if any part of the requested data is subject to such protections, and will work with you to provide access in a way that respects both your rights and our legitimate interests as well as of our third parties including but not limited to where we identify data that constitutes a trade secret and we will require you and/or your designated third party to agree to proportionate technical and confidentiality measures (such as non-disclosure and usage restrictions) prior to granting access.

Right to Erasure

Where technically available, you may erase or initiate erasure of relevant data by:

● deleting a journey or record in the app;

● removing a motorcycle from your account;

● resetting the motorcycle;

● deleting your account; or

● contacting us at privacy.eu@royalenfield.com

Deletion may not be available for:

● data automatically overwritten by the motorcycle (circular storage);

● data required for an active service (e.g., an active Digital PIN Share, active geofence);

● data required for safety, security, or legal obligations;

● records required to establish or defend legal claims;

● data that must be retained under warranty or product-safety obligations

If you sell or otherwise transfer ownership of your motorcycle, you should notify us so that your account and data can be delinked from the vehicle. To do this, please contact our customer care team or write to us at privacy.eu@royalenfield.com providing details of the vehicle and the change in ownership.

Once we receive your request, we will process the removal of the vehicle from your account and perform the necessary steps on our end to ensure that the new owner cannot view any of your historical data associated with that vehicle, including ride history, diagnostics, and location data.

Please note that we may retain certain data relating to the vehicle and its prior ownership where required to comply with our legal, regulatory, warranty, or safety obligations (for example, in connection with recalls, roadworthiness reporting, or dispute resolution), even after the vehicle has been delinked from your account. Any such retained data will continue to be handled in accordance with this Notice and our data retention practices described in the notice.

10.2. Right to share Data with Third Parties

You may request us to make Readily Available Data available to a third party of your choice for example, an independent repairer, maintenance/diagnostic provider, insurer, fleet-management provider, charging provider, mobility service, roadside-assistance provider, or another service provider selected by you.

You can submit and manage a sharing request through: privacy.eu@royalenfield.com

Once available, you will be able to select the relevant motorcycle, identify the recipient, select the data to be shared, specify the purpose (not mandatory) and duration of sharing, approve the request, and end or revoke future sharing. Data will be provided to an eligible third party without undue delay and, where relevant and technically feasible, continuously and in real time. Where such sharing involves a fee, this will be offered on fair, reasonable, and non-discriminatory (FRAND) terms.

We may ask you for information reasonably necessary to verify that you are the owner, lessee, renter, or otherwise authorised user (e.g., a secondary rider with an active Digital PIN Share) of the motorcycle. We will not request more information than is necessary to verify your entitlement and securely fulfil the request. Repeated failed identity/PIN verification attempts may result in a temporary lockout (3 failed attempts triggers a 15-minute lockout), consistent with the motorcycle's existing security design.

10.3. Right to Lodge a Complaint

You have the right to lodge a complaint alleging an infringement of the Data Act with the competent authority designated for this purpose in your Member State. However, we shall recommend you to first write to us about concerns and give us an opportunity to remediate them before reaching to a Supervisory Authority.

11. Purposes for Processing your Data

We may use non-personal Product Data and Related Service Data for the following purposes:

● delivery of connected services (remote lock/unlock, live tracking, geofencing, navigation, including real-time weather data obtained from our weather-service provider to support route and charging-stop recommendations);

● diagnostics and maintenance (vehicle health reports, fault alerts, temperature/thermal alerts);

● battery and range management;

● safety and security (tamper/theft alerts, crash detection, incognito-mode override logic);

● warranty administration;

● product improvement;

● aggregate analytics;

● service-network planning; and

● development of future products.

12. Changes to This Notice

We may update this Notice from time to time to reflect changes in our practices, our products, or applicable law. We will post the updated Notice on this page with a revised “Effective Date” and, for material changes, notify you via email or an in-app/website notice.

13. Contact Us

If you have questions about this Notice or how we handle your data or would like to exercise any of your rights, please contact us: privacy.eu@royalenfield.com

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