PRIVACY POLICY

Fitu Technologies Ltd (we) are committed to protecting and respecting your privacy.

This policy (together with the User Terms of Service) applies to any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the Data Protection Act 1998 and the EU General Data Protection Regulation (GDPR 2016/679), the data controller is Fitu Technologies Ltd. of 7, 162-164 Abbey Street, London, England, SE1 2AN, registered with the ICO under registration number ZA286805, whoserepresentative and nominated Data Protection Officer is Koen van den Heuvel.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

Information you give us (Submitted information): This is information you give us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us whether by e-mail, phone or online chat). It includes information you provide when you register to use the App Site, download or register the App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, book a class or event, share data via an App’s social media functions, enter a competition, promotion or survey, or connect with your friends on our app and when you report a problem with an App, our Services, or any of our Sites. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, date of birth, address, e-mail address and phone number, the Device’s phone number, age, username, password and other registration information, financial and credit card information, personal description and photograph, the city you live in and your gender.

• Where you enter any details relating to a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us. For the avoidance of doubt, any reference in this Privacy Policy to your data shall include data about other individuals that you have provided us with.

Information we collect about you and your device (Aggregate and technical data). Each time you visit one of our Sites or use one our Apps we will automatically collect the following information:

• technical information, including the Internet Protocol (IP address), type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting (Device Information);
• information stored on your Device, including social media friends lists, contact list, login information, photos or other digital content and check ins (Content Information);
• details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to traffic data, weblogs and other communication data and the resources that you access (Log Information);
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Location information. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by going to your Privacy Settings and turning off your location services on your device either for all our apps or for our app specifically.

• Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

COOKIES

We use cookies to distinguish you from other users of the App, App Site, Appstore or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our sites. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

HOW WE USE YOUR PERSONAL DATA

We use information held about you in the following ways:

• Submitted Information: to create an account with us, make class and event bookings and allow us to understand more about you so we can make better and more personalised class recommendations to you.
• Device information: to understand more about the different bugs and fixes required on different devices, how the content can be presented better and for continuous improvement of our Site and App.
• Content Information: to allow you to connect with your friends on the App, invite them to join you at a fitness event and upload your picture.
• Log information: to understand how you interact on our Site or App, which features you use most and understand more about what we can do to improve the Site or App and the experience we give to you.
• Location information: to enable us to show you what classes and fitness events are taking place near and around you.
• Third Party Information: to enable payments to be made seamlessly and get the support that we need to provide you with a better service from our trusted partners.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SE1). We will use the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

DISCLOSURE OF YOUR INFORMATION

We will disclose the data we collect from you to the following third parties:

Category of data

Recipient

Purpose

Submitted Information

Stripe Payments UK Ltd

Contract performance, i.e to allow our technical partner to process your payment for in-app purchases. Stripe enables the payment through Apple Pay and Google Pay.

Submitted Information; Aggregate and technical data

Event Organisers

Contract performance. We will be sharing information submitted by you with our business partners for the purpose of identifying you and allowing them to perform their services; we will also be sharing aggregate/technical data so that they may better respond to our customers' needs, convenience and preferences.

Submitted Information; Aggregate and technical data; Third Party Information

Technical partners, subcontractors

Legitimate interest. We may share data with technical support partners in the scope of business development/ improvement, including troubleshooting, data analysis, testing, research, statistical and survey purposes to ensure the content on our Site and App is presented in the most effective manner on your computer or mobile device.

Submitted Information; Aggregate and technical data; Third Party Information

Third party platforms, namely: Facebook; Branch; Databox; SendGrid; Mindbody; Glofox; zingfit; TablePlus; Hubspot; Instagram; Google.

Legitimate interest. We will be sharing information submitted by you as well as aggregate data (i.e. data generated from your activity on the Site or App) for the assessment of user behaviour in order to improve our product/experience, marketing campaigns and analysis of our business performance.

All information

The Authorities

Legal obligation. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Fitu Technologies Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud
protection, credit risk reduction, law enforcement and regulatory authorities proceedings. Furthermore, we may need to disclose information in order to enforce our Terms of Service and other agreements or to investigate potential breaches.

You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We will disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Fitu Technologies Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

WHERE WE STORE YOUR PERSONAL DATA

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

All Information we process is processed by our staff in the UK. however for the purposes of IT hosting and maintenance, this information is located on servers within the European Union. Our software developers are located in El Salvador and so your data will be exported to them. We have agreements with our developers to ensure that they have the mechanisms in place to ensure that your data is secure and that they adhere to the EU Commission’s standards for personal data flows with the United States.

Whilst we do our best to protect your personal data, the transmission of information via the internet is not completely secure, therefore we cannot guarantee the security in the transmission of your data to Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security measures to prevent unauthorised access.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

WHAT WE WOULD ALSO LIKE TO DO WITH THE INFORMATION

At Fitu Technologies Ltd we take your privacy seriously and will only use your Information as mentioned
above.

However from time to time we would like to inform you of our future offers and similar products. This Information is not shared with third parties and you can unsubscribe at any time via phone, email or our website.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at hello@fituapp.com

YOUR RIGHTS

If at any point you wish to know which Information we are processing about you, or if you do not wish for us to process your Information anymore or if you believe the Information we process on you is incorrect or obsolete you can request to see this Information and/or have it corrected or deleted by us by contacting us hello@fituapp.com

If you wish to raise a complaint on how we have handled your Information, please contact us at the email address above to have the matter investigated.

If you are not satisfied with our response or believe we are processing your Information not in accordance with the law you have the right to complain to the Information Commissioner’s Office https://ico.org.uk/

Our App and Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

ACCESS TO INFORMATION

The Data Protection Act 1998 and the EU General Data Protection Regulation (GDPR 2016/679) give you the right to access information held about you. Your right of access can be exercised in accordance with the Regulations. We will provide you with such information free of charge.

To access your personal data and update it or delete it please log into your account, access the side menu, click on your profile and update your settings.

CHANGES TO THE PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites or via email. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed
to the Data Protection Officer at hello@fituapp.com