Policy summary
Personal Data processed for the following purposes and using the following services:
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Backup saving and management
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Collection of privacy-related preferences
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Content performance and features testing (A/B testing)
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Data transfer outside of the UK
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Data transfer outside the EU
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Device permissions for Personal Data access
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Displaying content from external platforms
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Hosting and backend infrastructure
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Infrastructure monitoring
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Managing contacts and sending messages
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Managing data collection and online surveys
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Registration and authentication provided directly by SPORTABLE Training & Member Solution
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Traffic optimisation and distribution
Further information about the processing of Personal Data
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Data security
We invest heavily in protecting your data.
Our security systems are constantly analysing threats and helping to avert them. If we believe that something critical has occurred that affects you, we will inform you immediately.
To protect data, we use a mixture of technical, administrative and physical measures. This includes the use of Transport Layer Security ("TLS") to encrypt all data transmissions. However, no method of data transmission or storage is completely secure. If you have a security concern, please contact us.
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User identification via a universally unique identifier (UUID)
SPORTABLE Training & Member Solution may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use SPORTABLE Training & Member Solution only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use SPORTABLE Training & Member Solution.
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Unique device identification
SPORTABLE Training & Member Solution may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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localStorage
localStorage allows SPORTABLE Training & Member Solution to store and access data right in the User's browser with no expiration date.
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Pseudonymous use
When registering for SPORTABLE Training & Member Solution, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on SPORTABLE Training & Member Solution shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on SPORTABLE Training & Member Solution, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.
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Push notifications
SPORTABLE Training & Member Solution may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for SPORTABLE Training & Member Solution, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of SPORTABLE Training & Member Solution.
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Push notifications for direct marketing
SPORTABLE Training & Member Solution may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by SPORTABLE Training & Member Solution).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for SPORTABLE Training & Member Solution or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of SPORTABLE Training & Member Solution.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
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sessionStorage
sessionStorage allows SPORTABLE Training & Member Solution to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
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“Do Not Track”
Because there is no legal or industry consensus yet on how “Do Not Track” signals should be recognized or honored, SPORTABLE Training & Member Solution does not support “Do Not Track” requests at this time.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
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Equal protection of User Data
SPORTABLE Training & Member Solution shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
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Owner and Data Controller
Datenschutzbeauftragter:
David Heieck
V-formation GmbH
Stephanienstr. 18
76133 Karlsruhe
www.v-formation.de
Tel.: +49 721 181292-15
Unternehmen:
SPORTABLE AG
Borsigstraße 26
73249 Wernau
Deutschland
Owner contact email: datenschutz.sportable@v-formation.de
Full policy
Owner and Data Controller
Datenschutzbeauftragter:
David Heieck
V-formation GmbH
Stephanienstr. 18
76133 Karlsruhe
www.v-formation.de
Tel.: +49 721 181292-15
Unternehmen:
SPORTABLE AG
Borsigstraße 26
73249 Wernau
Deutschland
Owner contact email: datenschutz.sportable@v-formation.de
Types of Data collected
Among the types of Personal Data that SPORTABLE Training & Member Solution collects, by itself or through third parties, there are:
Trackers; Data communicated while using the service; email address; first name; last name; Usage Data; various types of Data; Camera permission; Storage permission; Reminders permission; NFC Reader permission ; Photo Library permission; Health Data read permission; Health Data update permission ; gender; date of birth; general activity data; movement activity; body measurements & indexes; food related activity ; sleeping activity; heart rate and other vital data; username; phone number; physical address; password; company name; profile picture; website; language; picture; answers to questions; payment info; name; billing address; user content; contact info; Universally unique identifier (UUID); crash data; device information.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using SPORTABLE Training & Member Solution.
Unless specified otherwise, all Data requested by SPORTABLE Training & Member Solution is mandatory and failure to provide this Data may make it impossible for SPORTABLE Training & Member Solution to provide its services. In cases where SPORTABLE Training & Member Solution specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by SPORTABLE Training & Member Solution or by the owners of third-party services used by SPORTABLE Training & Member Solution serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through SPORTABLE Training & Member Solution.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of SPORTABLE Training & Member Solution (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Beta Testing, Displaying content from external platforms, Data transfer outside the EU, Data transfer outside of the UK, Collection of privacy-related preferences, Backup saving and management, Device permissions for Personal Data access, Handling activity data, Hosting and backend infrastructure, Content commenting, Contacting the User, Registration and authentication provided directly by SPORTABLE Training & Member Solution, Social features, Content performance and features testing (A/B testing), Managing contacts and sending messages, Managing data collection and online surveys, Infrastructure monitoring and Traffic optimisation and distribution.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Device permissions for Personal Data access
Depending on the User's specific device, SPORTABLE Training & Member Solution may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependant on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of SPORTABLE Training & Member Solution.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by SPORTABLE Training & Member Solution.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Health Data read permission
Allows reading the User’s health Data.
Health Data update permission
Allows the updating of the User’s health Data.
NFC Reader permission
Allows SPORTABLE Training & Member Solution to read contact-less tags.
Photo Library permission
Allows access to the User's Photo Library.
Reminders permission
Used for accessing the Reminders app on the User's device, including the reading, adding and removing of entries.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Backup saving and management
This type of service allows the Owner to save and manage backups of SPORTABLE Training & Member Solution on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to SPORTABLE Training & Member Solution.
Amazon Glacier (Amazon Europe )
Amazon Glacier is a service to save and manage backups provided by Amazon Web Services Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Luxembourg – Privacy Policy.
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Beta Testing
This type of service makes it possible to manage User access to SPORTABLE Training & Member Solution, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of SPORTABLE Training & Member Solution in a personally identifiable form.
Google Play Beta Testing (Google Ireland Limited)
Google Play Beta Testing is a beta testing service provided by Google Ireland Limited.
Personal Data processed: email address.
Place of processing: Ireland – Privacy Policy.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: email address; first name; last name.
Place of processing: United States – Privacy Policy.
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Collection of privacy-related preferences
This type of service allows SPORTABLE Training & Member Solution to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Consent Database (iubenda srl)
The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service; Trackers.
Place of processing: Italy – Privacy Policy.
iubenda Privacy Controls and Cookie Solution (iubenda srl)
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information and in particular to the use of Cookies and other Trackers on SPORTABLE Training & Member Solution.
Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
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Contacting the User
Phone contact (SPORTABLE Training & Member Solution)
Users that provided their phone number might be contacted for commercial or promotional purposes related to SPORTABLE Training & Member Solution, as well as for fulfilling support requests.
Personal Data processed: phone number.
Mailing list or newsletter (SPORTABLE Training & Member Solution)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning SPORTABLE Training & Member Solution. Your email address might also be added to this list as a result of signing up to SPORTABLE Training & Member Solution or after making a purchase.
Personal Data processed: email address; first name; last name; phone number; Usage Data.
Referral marketing
If a user invites a friend within the app who is to be contacted by sportable AG or an affiliated gym, sportable AG processes the transmitted personal data of the friend (e.g. name, e-mail address, telephone number) within the scope of the consent received. The user is responsible for ensuring that the friend's consent to the forwarding of his/her data to sportable AG and the relevant fitness studio has been obtained. sportable AG may forward the contact details provided to the fitness studio selected by the user to enable contact to be made. The gym stores the data in its own CRM system and uses it to make contact in accordance with its own data protection guidelines. The data is processed and forwarded on the basis of the user's voluntary consent, which can be revoked at any time with effect for the future. The rights of the data subjects (revocation of consent, deletion, information) remain fully safeguarded and can be asserted by contacting the data protection officer.
Legal basis for processing: Consent.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of SPORTABLE Training & Member Solution.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly (SPORTABLE Training & Member Solution)
SPORTABLE Training & Member Solution has its own internal content comment system.
Personal Data processed: Usage Data; username.
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyse the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of SPORTABLE Training & Member Solution.
Firebase Remote Config (Google Ireland Limited)
Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
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Device permissions for Personal Data access
SPORTABLE Training & Member Solution requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (SPORTABLE Training & Member Solution)
SPORTABLE Training & Member Solution requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Camera permission; Health Data read permission; Health Data update permission ; NFC Reader permission ; Photo Library permission; Reminders permission; Storage permission.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of SPORTABLE Training & Member Solution and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows SPORTABLE Training & Member Solution to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows SPORTABLE Training & Member Solution to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualisation service provided by Vimeo, LLC that allows SPORTABLE Training & Member Solution to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
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Handling activity data
This type of service allows the Owner to use the activity or biometric data collected by your device in order for SPORTABLE Training & Member Solution to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
Depending on what is described below, third parties may be involved in the activity tracking.
Most devices allow for the User to control which Data is accessed or stored.
Apple HealthKit (Apple Inc.)
HealthKit is an activity data handling service provided by Apple Inc. that enables the Owner to access or store activity data.
Personal Data processed: body measurements & indexes; date of birth; food related activity ; gender; general activity data; heart rate and other vital data; movement activity; sleeping activity.
Place of processing: United States – Privacy Policy.
Activity data tracked by your device (SPORTABLE Training & Member Solution)
SPORTABLE Training & Member Solution uses some activity data tracked by your device to operate or to provide specific features.
Personal Data processed: body measurements & indexes; date of birth; food related activity ; gender; general activity data; heart rate and other vital data; movement activity; sleeping activity.
Health Connect
Provider:
Google LLC
Purpose:
Handling of activity data
Personal data collected:
Gender
Date of birth
General activity data
Activities related to exercise
Body measurements & indices
Activities related to nutrition
Activity related to sleep
Heart rate and other vital data
Description:
Health Connect is an activity data service provided by Google LCC that allows the owner to access or store activity data.
The use of information received from Health Connect will adhere to the Health Connect Permissions policy, including the Limited Use requirements.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable SPORTABLE Training & Member Solution to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of SPORTABLE Training & Member Solution.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Firebase Cloud Functions (Google Ireland Limited)
Firebase Cloud Functions is a hosting and backend service provided by Google Ireland Limited.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
TourOnline AG
Touronline AG hosts the backend of the application.
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Infrastructure monitoring
This type of service allows SPORTABLE Training & Member Solution to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of SPORTABLE Training & Member Solution.
Crashlytics (Google Ireland Limited)
Crashlytics is a monitoring service provided by Google Ireland Limited.
Personal Data processed: crash data; device information; Universally unique identifier (UUID).
Place of processing: Ireland – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Firebase Cloud Messaging (Google Ireland Limited)
Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy; United Kingdom – Privacy Policy; Germany – Privacy Policy; Netherlands – Privacy Policy.
Firebase Notifications (Google Ireland Limited)
Firebase Notifications is a message sending service provided by Google Ireland Limited. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy; Netherlands – Privacy Policy; United Kingdom – Privacy Policy; Germany – Privacy Policy.
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Managing data collection and online surveys
This type of service allows SPORTABLE Training & Member Solution to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Data provided via online forms, managed directly (SPORTABLE Training & Member Solution)
SPORTABLE Training & Member Solution makes use of online forms that can be used to collect Data about Users.
Personal Data processed: answers to questions; billing address; company name; contact info; date of birth; email address; first name; gender; language; last name; name; payment info; phone number; physical address; profile picture; Trackers; Usage Data; user content.
Data provided via online forms, managed directly (SPORTABLE Training & Member Solution)
SPORTABLE Training & Member Solution makes use of online forms that can be used to collect Data about Users.
Personal Data processed: answers to questions; billing address; company name; contact info; date of birth; email address; first name; gender; language; last name; name; payment info; phone number; physical address; profile picture; Trackers; Usage Data; user content.
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Registration and authentication provided directly by SPORTABLE Training & Member Solution
By registering or authenticating, Users allow SPORTABLE Training & Member Solution to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (SPORTABLE Training & Member Solution)
The User registers by filling out the registration form and providing the Personal Data directly to SPORTABLE Training & Member Solution.
Personal Data processed: company name; email address; first name; language; last name; password; physical address; profile picture; Usage Data; username; website.
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Social features
Inviting and suggesting friends (SPORTABLE Training & Member Solution)
SPORTABLE Training & Member Solution may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed: various types of Data.
Public profile (SPORTABLE Training & Member Solution)
Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with SPORTABLE Training & Member Solution.
Personal Data processed: gender; picture; username.
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Traffic optimisation and distribution
This type of service allows SPORTABLE Training & Member Solution to distribute their content using servers located across different countries and to optimise their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between SPORTABLE Training & Member Solution and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Bunny CDN (BunnyWay d.o.o.)
Bunny CDN is a traffic optimisation and distribution service provided by BunnyWay d.o.o.
Personal Data processed: Usage Data.
Place of processing: Slovenia – Privacy Policy.
Further information about the processing of Personal Data
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Data security
We invest heavily in protecting your data.
Our security systems are constantly analysing threats and helping to avert them. If we believe that something critical has occurred that affects you, we will inform you immediately.
To protect data, we use a mixture of technical, administrative and physical measures. This includes the use of Transport Layer Security ("TLS") to encrypt all data transmissions. However, no method of data transmission or storage is completely secure. If you have a security concern, please contact us.
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User identification via a universally unique identifier (UUID)
SPORTABLE Training & Member Solution may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use SPORTABLE Training & Member Solution only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use SPORTABLE Training & Member Solution.
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Unique device identification
SPORTABLE Training & Member Solution may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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localStorage
localStorage allows SPORTABLE Training & Member Solution to store and access data right in the User's browser with no expiration date.
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Pseudonymous use
When registering for SPORTABLE Training & Member Solution, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on SPORTABLE Training & Member Solution shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on SPORTABLE Training & Member Solution, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.
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Push notifications
SPORTABLE Training & Member Solution may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for SPORTABLE Training & Member Solution, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of SPORTABLE Training & Member Solution.
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Push notifications for direct marketing
SPORTABLE Training & Member Solution may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by SPORTABLE Training & Member Solution).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for SPORTABLE Training & Member Solution or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of SPORTABLE Training & Member Solution.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
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sessionStorage
sessionStorage allows SPORTABLE Training & Member Solution to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
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“Do Not Track”
Because there is no legal or industry consensus yet on how “Do Not Track” signals should be recognized or honored, SPORTABLE Training & Member Solution does not support “Do Not Track” requests at this time.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
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Equal protection of User Data
SPORTABLE Training & Member Solution shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer to countries that guarantee European standards
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Transfer of Personal Data outside of the United Kingdom
Data transfers according to a UK adequacy regulation
If this is the legal basis, the transfer of Personal Data from the UK to third countries may take place according to a so called “adequacy regulation” of the UK Government.
The UK Government adopts adequacy regulations for specific countries or territories whenever such countries or territories guarantee Personal Data protection standards comparable to those set forth by UK data protection legislation. Users can find an updated list of all adequacy regulations on the website of the Information Commissioner’s Office (ICO).
Data transfer abroad based on standard contractual clauses (UK)
If this is the legal basis, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfer abroad based on consent (UK)
If this is the legal basis, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via SPORTABLE Training & Member Solution.
Other legal basis for Data transfer abroad (UK)
If no other legal basis applies, Personal Data shall be transferred from the UK to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
- the data transferred is sourced from a public register created under UK law;
- subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via SPORTABLE Training & Member Solution.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of SPORTABLE Training & Member Solution or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, SPORTABLE Training & Member Solution may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, SPORTABLE Training & Member Solution and any third-party services may collect files that record interaction with SPORTABLE Training & Member Solution (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within SPORTABLE Training & Member Solution and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through SPORTABLE Training & Member Solution (or third-party services employed in SPORTABLE Training & Member Solution), which can include: the IP addresses or domain names of the computers utilised by the Users who use SPORTABLE Training & Member Solution, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using SPORTABLE Training & Member Solution who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of SPORTABLE Training & Member Solution. The Data Controller, unless otherwise specified, is the Owner of SPORTABLE Training & Member Solution.
SPORTABLE Training & Member Solution (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by SPORTABLE Training & Member Solution as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to SPORTABLE Training & Member Solution, if not stated otherwise within this document.