We believe that transparency is the key to any positive relationship. We are all about relationships. We appreciate that you are trusting us with information that is important to you, and we want to be transparent about how we use it.
Here we describe the privacy practices for our devices, applications, software, websites, products, and services (the “Services”). You will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.
Specifically, we’ll cover:
- Information We Collect
- How We Use Information
- How Information Is Shared
- Your Rights To Access and Control Your Personal Data
- Data Retention
- Analytics and Advertising Services Provided by Others
- Our Policies for Children
- Information Security
- Our International Operations and Data Transfers
- Changes to This Policy
- Who We Are and How To Contact Us
INFORMATION WE COLLECT
When you use our Services, we collect the following types of information.
INFORMATION YOU PROVIDE US
Some information is required to create an account on our Services, such as your name, email address, password, date of birth, gender and in some cases your mobile telephone number. This is the only information you have to provide to create an account with us. You may also choose to provide other types of information, such as a profile photo, biography, country information and community username.
To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information.
You may also connect with friends on the Services or invite friends who have not yet joined by providing their email addresses, accessing social networking accounts, or using the contact list on your mobile device. We do not store your contact list and delete it after it is used for adding contacts as friends.
If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, contact information, and message.
INFORMATION FROM THIRD-PARTY SERVICES
If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friend list. You may also choose to grant us access to your data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.
PAYMENT AND CARD INFORMATION
If you purchase merchandise on our website, you provide your payment information, including your name, credit or debit card number, card expiration date, CVV code and billing address. We do not store this payment information. We store your delivery address to fulfil your order. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms.
INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES
The Services include features that use precise location data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can always remove our access using your device or mobile device settings. We may also derive your approximate location from your IP address.
When you access or use our Services, we receive certain usage data. This includes information about your interaction with the Services, for example, when you view or search content, install applications or software and create or log into your account.
We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, operating system or mobile device information (including device and application identifiers), the referring web page, pages visited, location and cookie information.
HOW WE USE INFORMATION
We use the information we collect for the following purposes.
PROVIDE AND MAINTAIN THE SERVICES
Using the information we collect, we are able to deliver the Services to you. We may use your information to help you find and connect with other users and to allow other users to find and connect with you. For example, your account contact information allows other users to add you as a friend. When another user has your email or mobile phone number in their contact list or in their friend network on a connected service, we show that user that you are a user of the Services.
IMPROVE, PERSONALISE AND DEVELOP THE SERVICES
We use the information we collect to improve and personalise the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.
When you allow us to collect precise location information, we use that information to provide and improve features of the Services.
We also use your information to make inferences and show you more relevant content.
COMMUNICATE WITH YOU
We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in.
PROMOTE SAFETY AND SECURITY
We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
For personal data subject to the European Union’s General Data Protection Regulation (“GDPR”), we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time and other tools; when the processing is necessary to perform a contract with you, like our legitimate business interests, such as in improving, personalising, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.
HOW INFORMATION IS SHARED
We do not share your personal information except in the limited circumstances described below.
WHEN YOU AGREE OR DIRECT US TO SHARE
You may direct us to disclose your information to others. You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account, or with your employer when you choose to participate in an employee wellness program. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications or employee wellness programs.
FOR EXTERNAL PROCESSING
We transfer information to our corporate affiliates, service providers, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.
FOR LEGAL REASONS OR TO PREVENT HARM
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.
Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.
We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us, or as part of the community benchmarking information we provide to users of any of our subscription services.
If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.
YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA
Touch and control your personal data, regardless of where you live. If you live in the European Economic Area, United Kingdom, and Switzerland (the “Designated Countries”), you have a number of legal rights with respect to your information.
Accessing and Exporting Data.
By contacting us you can access much of your personal information.
Editing and Deleting Data.
By contacting us you can change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish.
If you choose to delete your data, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm.
Objecting to Data Use.
If you live in a Designated Country, in certain circumstances, you can object to our processing of your information based on our legitimate interests. You have a general right to object to the use of your information for direct marketing purposes.
Restricting or Limiting Data Use.
In addition to the various controls that we offer, if you reside in a Designated Country, you can seek to restrict our processing of your data in certain circumstances. Please note that you can always delete your account at any time.
If you need further assistance regarding your rights, please contact our Data Protection Officer on email@example.com.
We keep any account information, like your name, email address and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. For instance, when you provide your contact list for finding friends on the Services, we delete the list after it is used for adding contacts as friends. We keep other information. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm.
ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
OUR POLICIES FOR CHILDREN
We appreciate the importance of taking additional measures to protect children’s privacy.
Persons under the age of 13, or any higher minimum age in the jurisdiction where that person resides, are not permitted to create accounts unless their parent has consented in accordance with applicable law. If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us.
We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. This includes using Transport Layer Security (“TLS”) to encrypt many of our Services. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact us at firstname.lastname@example.org.
OUR INTERNATIONAL OPERATIONS AND DATA TRANSFERS
We operate internationally and transfer information to other countries for the purposes described in this policy.
We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and Swiss-US Privacy Shield, and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us on email@example.com. We comply with the Privacy Shield principles regarding the collection, use, sharing and retention of personal information.
Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create an account and click “I agree” to data transfers, irrespective of which country you live in.
CHANGES TO THIS POLICY
We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services.
WHO WE ARE AND HOW TO CONTACT US
If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact us on firstname.lastname@example.org.