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2. DATA COLLECTED
We collect your personal data when you purchase services in the service platform, use or register into our service platform, enter into a sales promotion or a campaign, or otherwise interact with us. Below are examples of the categories of the data we collect on you.
2.2 Information you provide us When you register to our service platform, make a purchase, enter a sales promotion or otherwise interact with us, we may ask you to provide us with certain information such as your name, email address, as well as user names, passwords and other such credentials that are used to authenticate users and to validate their actions or that may be needed to provide you with the services you have requested or to communicate with you, as well as information uploaded by you such as location, route information, pictures etc. We may collect training data, demographic information, for example, your age, gender, postal code and language preferences. We may also collect other information you provide, such as your consents, preferences and feedback, information relating to your devices and other such information you provide us with. Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data. Our service platform allows you to submit your information to other people, for example, for your coach or other team members. Many of the services may require service specific information sharing for the service provider selected by you (for example sharing your meal calendar with a nutrition service).
2.4 Payment information When you subscribe our service platform, we do not store or process your billing information or other invoicing data provided by you. All billing information is processed by trusted third party companies whose sole purpose is to verify your financial qualifications and to collect payment from you. The use of your data by our invoicing service provider is subject to its privacy policies.
2.5 Your transactions with us We collect, or request information relating to your purchase or use of services inside our service platform as well as your other interactions with us. Such information may include, for example, details of the queries or requests you have made, details on the products and services provided (including delivery details), details of agreements between you, Coach4Pro and any service providers selected by you, records of contacts and communications and, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other similar contact points.
2.7 Data obtained from third parties. In addition to the personal exercise data we obtain from you, we may obtain, in accordance with applicable laws, certain personal data from list broker services and other publicly available sources. This may include personal data such as address information updates.
3. THE PURPOSES OF PROCESSING
Coach4Pro processes your personal data for the purposes described in this Policy and/or any additional service specific privacy information. Please note that one or more purposes may apply simultaneously.
3.1 Provision of products and services We may process and use your personal data to provide you the service you have requested, fulfil your other requests, process your order, or, as necessary, to perform and enforce the contract between you and Coach4Pro. We may also process and use your personal data to ensure the functionality and security of our services, to identify you, and to prevent and detect fraud and other misuses.
3.2 Development of products and services We may process and use your personal data to develop our service platform and related services. However, for the most part we only use aggregate and statistical information in the development of our service platform and related services, not data directly identifiable to you. We may also process and use your personal data to personalize our offers and to provide you with services more relevant to you, for example, to make recommendations and to display customized content and advertising. We may combine personal data collected in connection with your use of certain services with other personal data we may hold about you, except in situations where such personal data was collected for a different purpose.
3.3 Communicating with you and marketing We may process and use your personal data to communicate with you, for example, to provide information relating to our service platform or services you are using or to contact you for customer satisfaction queries. We may process and use your personal data for marketing. Marketing purposes may include using your personal data for personalized marketing or for research purposes in accordance with applicable laws, for example, to conduct market research or to inform you about our services and promotions via our own- or third-party services. In addition, some of our service platform’s services may be used to promote products and services of other companies. However, Coach4Pro does not disclose your personal data to such companies for their marketing purposes without your prior consent.
3.4 Profiling We may process and use your personal data for profiling for such purposes as targeted direct marketing and improvement of our services. We may also create aggregate and statistical information based on your personal data. Profiling includes automated processing of your personal data for evaluating, analysing, or predicting your personal preferences or interests to, for example, send you marketing messages concerning products or services best suitable for you, or adjust services according your needs.
You may also buy special profiling services via our service platform where information provided by you is used for profiling purposes selected by you.
4. TRANSFERS OF YOUR PERSONAL DATA
We may disclose your personal data to third parties solely as stated below in this Policy, or as obligated by mandatory law.
4.1 Opting-out from e-mail/SMS based marketing. You may opt-out from brand marketing e-mails by following the guidance in those e-mails (typically provided via “unsubscribe” link) or contacting the company via the contact points given on the website. If you opt-out, we may still send you non-marketing e-mails, such as service notifications or other information or if you are a business customer, we may send business related information. You may also opt-out from any SMS based direct marketing by contacting Coach4Pro via the website or via SMS as may be applicable.
4.1 Service providers and other authorized third parties. We may transfer your personal data to authorized third parties who process personal data on behalf of Coach4Pro for the purposes described in this Policy, such as e.g., technical, logistical and other service providers. Such parties are not permitted to use your personal data for any other purposes than for what your personal data was collected for, and we require them to act consistently with applicable laws and this Policy as well as to use appropriate security measures to protect your personal data. We may also transfer your personal data in a non-identifiable format, including exercise related data like heart rate data, biometrical data, or other health related data, to a service partner, if you use such services where a third-party company needs to process such data for the provision of the respective service or where you separately agree that a third-party company may process your data in connection with the service platform of Coach4Pro.
4.2 International transfers Our services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services, including to countries outside the European Economic Area (EEA), where the level of data protection may not be deemed adequate by the European Commission. In such cases we take steps to ensure that adequate protection for your personal data is provided as required by applicable laws. For international transfers of your personal data, we generally rely on agreements that are based on the Standard Contractual Clauses (“SCCs”) of the European Commission. You may find the SCCs here. http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm. If you wish to know more about international transfers of your personal data, you may contact us via the contact details given below.
4.3 Other disclosures We may disclose and otherwise process your personal data in accordance with applicable laws to defend Coach4Pro’s legitimate interests, for example, in civil or criminal legal proceedings.
4.4 Mergers and Acquisitions If we decide to sell, buy, merge, or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers, for the purposes of such transactions.
5. DATA CONCERNING MINORS
Coach4Pro does not seek to collect any information from or engage in any transactions with persons under the legal age in their respective country. Our databases may nevertheless contain personal data of children since it is not always possible to determine precisely the age of the user. We reserve the right to block the service platform from any person who is or whom we reasonably suspect of being a minor. Coach4Pro’s policy is to request that minors do not make purchases or engage in other legal acts on our products and services inside the service platform without the consent of a parent or legal guardian, unless otherwise permitted by applicable law. If you are a minor but have your legal guardian’s consent, you must be able to prove that such consent exists upon request.
6. DATA QUALITY AND RETENTION
We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data. Our service platform may allow you to manage your profile and the information in such profile. We encourage you to access your personal data via your profile from time to time to ensure that it is correct and up-to-date. Please remember that for such electronic services where you may manage your profile, it is your responsibility to provide us with correct details as well as to update the personal data you have provided us in case of any changes. We store your personal data only for a period necessary for the purpose in question or as long as required by applicable laws.
7. DATA SECURITY
Coach4Pro implements appropriate technical and organizational security measures to prevent and minimize risks associated with providing and processing personal data. Such security measures include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection and sufficient training of processors and other necessary measures to provide appropriate protection for your personal data against unauthorized use or disclosure. Where appropriate, we may also take back-up copies and use other such means to prevent accidental damage or destruction of your personal data. If a particular part of the Coach4Pro website supports online transactions, we will use an industry standard security measure, such as the one available through “Secure Sockets Layer” (“SSL”), to protect the confidentiality and security of online transactions.
9. YOUR RIGHTSYou have the right to request information and access to the personal data we have collected from and of you. You also have the right to request that we replenish, rectify, anonymize or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with binding legal obligations or if the personal data must be retained according to applicable laws. You have the right to request and receive the personal data we have collected on you in a commonly used and machine-readable form. In case you consider your personal data collected by us to be inaccurate, you do not wish your personal data to be deleted where the processing of your personal data has been deemed unlawful or the personal data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data. You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time. In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this Policy. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you. We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal and other data and allow you to effectively manage our data. Please note that Coach4Pro may need to identify you and to ask for additional information in order to be able to fulfil your requests above. Please also note that applicable laws may contain restrictions and other provisions that relate to your above rights.
10. THE CONTROLLER OF YOUR PERSONAL DATA AND CONTACT DETAILS
The data controller responsible for the purposes of the applicable data protection laws is: Coach4Pro Oy Sinikalliontie 18 A 02630 Espoo Finland
Last Update: 14th of May 2019