Privacy Policy

Last updated: January 18, 2024

Welcome to the TrueFitness Privacy Policy. In this document, we outline how and why we collect, store, use, and share your information when you use our services (“Services”). This includes actions such as downloading and using our mobile application (TrueFitness) or engaging with us through sales, marketing, or events. Understanding your privacy rights and choices is crucial, so please read this privacy notice carefully. If you disagree with our policies and practices, we recommend refraining from using our Services. Should you have any questions or concerns, reach out to us at support@truefitness.app.

SUMMARY OF KEY POINTS

This summary offers a quick overview, but you can delve into specific sections for more details. Use the provided links or refer to our table of contents.

Personal Information Processing: Depending on your interactions, choices, and usage of our Services, we process personal information. Learn more

Sensitive Personal Information: Sensitive information may be processed with your consent or as permitted by law. Explore details

Third-Party Information Sharing: We do not receive information from third parties. Find out more

Processing Purposes: Your information is processed to provide, enhance, and manage our Services, communicate with you, ensure security and prevent fraud, and comply with the law. Other purposes may require your consent. Detailed information

Information Sharing: We may share information in specific situations with particular third parties. Learn about sharing practices

Security Measures: While we implement organizational and technical processes to safeguard your information, no system is entirely foolproof. Discover more

Privacy Rights: Your location may grant you specific rights concerning your personal information, in accordance with applicable privacy laws. Understand your rights

Exercising Your Rights: Exercise your privacy rights by submitting a data subject access request or contacting us. Know how

Full Privacy Notice: For a comprehensive understanding of our information handling practices, review the complete privacy notice.

Thank you for choosing TrueFitness. Your privacy is of utmost importance to us.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We gather personal information voluntarily provided by you during interactions with the Services. This includes activities such as registration, expressing interest in our products and services, or contacting us. The types of personal information collected depend on the context of your interactions, choices, and usage of the Services. This may include:

Names

Phone numbers

Email addresses

Billing addresses

Usernames

Contact or authentication data

Sensitive Information: With your consent or as permitted by applicable law, we may process sensitive information, including health and biometric data.

Payment Data: If you make purchases, we collect payment data necessary for processing, such as payment instrument numbers and associated security codes. RevenueCat stores all payment data; their privacy notice is available here.

Application Data: If you use our application(s) and grant access or permission, we may collect the following:

Geolocation Information: To provide location-based services, we may request access to track location-based information from your mobile device.

Mobile Device Access: We may request access to features like your device’s camera, microphone, reminders, and calendar. Adjust permissions in your device’s settings.

Mobile Device Data: Automatic collection includes device information, operating system details, device and application identification numbers, browser type, hardware model, Internet service provider, mobile carrier, IP address (or proxy server), and more.

Push Notifications: We may request to send push notifications regarding your account or application features. You can opt out in your device’s settings.

This information is crucial for maintaining application security, troubleshooting, and internal analytics. It is essential that all provided personal information remains true, complete, and accurate. Notify us promptly of any changes to ensure the accuracy of your data.

Information Automatically Collected

In Short: We automatically collect certain information, such as your Internet Protocol (IP) address and device characteristics, when you visit our Services.

When you visit, use, or navigate our Services, specific information is automatically collected, including device and usage details. This data, while not identifying you personally (like your name or contact information), encompasses IP addresses, browser and device characteristics, operating systems, language preferences, referring URLs, device names, countries, locations, and details about your usage of our Services. This information is crucial for maintaining security, operational functionality, and internal analytics.

The information we collect includes:

Log and Usage Data: This service-related data involves diagnostic, usage, and performance information automatically collected by our servers as you access or use our Services. It may encompass your IP address, device information, browser type, settings, activity timestamps, viewed pages and files, searches, and other actions within the Services.

Device Data: We gather information about the device you use to access the Services, including details about your computer, phone, tablet, or other devices. Device data may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider, mobile carrier, operating system, and system configuration.

Location Data: We collect location data, which can be precise or imprecise, depending on your device type and settings. For instance, GPS and similar technologies may be used to gather geolocation data based on your IP address. You have the option to opt out of this data collection by either denying access or disabling location settings on your device. However, choosing to opt out may limit your access to certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for various reasons based on your interactions with our Services, including but not limited to:

Facilitating Account Creation and Authentication: Processing your information to enable you to create and log in to your account, ensuring its proper functioning.

Responding to User Inquiries/Providing Support: Processing your information to respond to your inquiries and address any issues you may encounter while using our Services.

Enabling User-to-User Communications: Processing your information when you choose to use features allowing communication with other users.

Requesting Feedback: Processing your information to seek feedback and contact you about your experiences with our Services.

Sending Marketing and Promotional Communications: Processing personal information for marketing purposes, aligned with your preferences. You can opt out of marketing emails anytime.

Delivering Targeted Advertising: Processing your information to develop and display personalized content and advertising tailored to your interests and location.

Protecting Our Services: Processing your information as part of efforts to ensure the safety and security of our Services, including fraud monitoring and prevention.

Determining Marketing Effectiveness: Processing your information to understand how to provide relevant marketing and promotional campaigns.

Saving or Protecting Vital Interests: Processing your information when necessary to protect an individual’s vital interests, such as preventing harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We process your personal information based on valid legal reasons, including consent, contractual obligations, legitimate interests, legal obligations, and protection of vital interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR necessitate clarification of the legal bases relied upon for processing personal information. We may rely on the following legal bases:

Consent: Processing your information when you have given explicit permission for a specific purpose, with the option to withdraw consent at any time.

Performance of a Contract: Processing personal information necessary to fulfill contractual obligations, such as providing Services or fulfilling requests before entering a contract.

Legitimate Interests: Processing information to achieve legitimate business interests, ensuring they do not override your rights and freedoms.

Legal Obligations: Processing information to comply with legal obligations, cooperate with law enforcement or regulatory agencies, and exercise or defend legal rights.

Vital Interests: Processing information to protect vital interests, including potential threats to safety.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates: Your information may be shared with our affiliates, and we will ensure they adhere to this privacy notice. Affiliates include our parent company, subsidiaries, joint venture partners, or other entities under common control with us.

Business Partners: We may share your information with business partners to provide you with certain products, services, or promotions.

Other Users: When you share personal information, such as comments or contributions, in public areas of the Services, it may be viewed by all users and made publicly available. Other users can view your activity descriptions, communicate with you within our Services, and access your profile.

Offer Wall: Our application(s) might display a third-party hosted “offer wall,” where third-party advertisers offer virtual currency, gifts, or other items for completing an advertisement offer. Clicking on an offer wall may take you to an external website, and a unique identifier (e.g., your user ID) may be shared for fraud prevention and reward crediting.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We retain your personal information only for the duration necessary to fulfill the purposes stated in this privacy notice, unless a longer retention period is mandated or allowed by law (such as tax, accounting, or legal requirements). Once the need for processing your information ends, we will either delete or anonymize it. If deletion is not immediately feasible (e.g., due to storage in backup archives), we will securely store and isolate your information until deletion becomes possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented reasonable technical and organizational security measures to safeguard the personal information we process. Despite our efforts, no electronic transmission or storage can guarantee absolute security. We cannot assure that unauthorized third parties will not breach our security and access, steal, or modify your information. While we strive to protect your data, accessing the Services remains at your own risk, and you should only do so within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not intentionally solicit data from or market to individuals under 18 years of age. By using the Services, you affirm that you are at least 18 years old or, if you are the parent or guardian of a minor, consent to their use of the Services. Upon discovery that we have inadvertently collected personal information from individuals under 18, we will deactivate the account and take prompt steps to delete such data. If you are aware of any such data, please contact us at support@truefitness.app.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In certain regions, including the European Economic Area (EA), the United Kingdom (UK), and Switzerland, you possess specific rights under applicable data protection laws. These rights may encompass:

Access and Copies: You have the right to request access to and obtain a copy of your personal information.

Rectification or Erasure: You can request the correction or deletion of your personal information.

Restriction of Processing: You have the right to restrict the processing of your personal information.

Data Portability: Under certain conditions, you may be entitled to data portability.

Objection to Automated Decision-Making: In specific situations, you can object to automated decision-making.

Should you wish to exercise any of these rights, contact us using the details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” section below. We will handle and respond to your requests in compliance with applicable data protection laws.

If you are situated in the EA or UK and believe that we are unlawfully processing your personal information, you have the right to file a complaint with your Member State data protection authority or the UK data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing Consent: If we are relying on your consent for processing your personal information, you have the right to withdraw it at any time. You can do so by contacting us through the provided contact details. Please note that withdrawal of consent will not affect the lawfulness of processing before withdrawal or processing based on other lawful grounds.

Opting Out of Marketing Communications: Unsubscribe from our marketing communications anytime by clicking the unsubscribe link in our emails, replying “STOP” or “UNSUBSCRIBE” to SMS messages, or contacting us through the details in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” section. However, you may still receive non-marketing communications necessary for account administration or in response to service requests.

Account Information:

If you want to review or modify information in your account or terminate it, follow these steps:

Upon account termination request, we will deactivate or delete your account and associated information from active databases. Some data may be retained in our files to prevent fraud, troubleshoot issues, aid investigations, enforce legal terms, or meet legal requirements.

For privacy rights-related queries, email us at support@truefitness.app.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications offer a Do-Not-Track (“DNT”) feature to express your preference against having online browsing activities monitored. As there is no finalized technology standard for DNT signals, we currently do not respond to such signals. If a standard emerges in the future, we will inform you through an updated privacy notice.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Residents of California, Colorado, Connecticut, Utah, or Virginia have specific rights regarding access to their personal information.

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you have specific privacy rights concerning access to your personal information. Here are the categories of personal information we have collected in the past twelve (12) months:

A. Identifiers:

Examples: Real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

B. Personal information as defined in the California Customer Records statute:

Examples: Name, contact information, education, employment, employment history, and financial information

C. Protected classification characteristics under state or federal law:

Examples: Gender and date of birth

D. Commercial information:

Examples: Transaction information, purchase history, financial details, and payment information

E. Biometric information:

Examples: Fingerprints and voiceprints

F. Internet or other similar network activity:

Examples: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

G. Geolocation data:

Examples: Device location

H. Audio, electronic, visual, thermal, olfactory, or similar information:

Examples: Images and audio, video, or call recordings created in connection with our business activities

I. Professional or employment-related information:

Examples: Business contact details to provide our services at a business level or job title, work history, and professional qualifications if you apply for a job with us

J. Education Information:

Examples: Student records and directory information

K. Inferences drawn from collected personal information:

Examples: Inferences drawn to create a profile or summary about an individual’s preferences and characteristics

L. Sensitive personal Information:

Examples: Biometric data, account login information, and health data

We will use and retain the collected personal information as needed to provide the Services or for:

Category B: As long as the user has an account with us

Category K: As long as the user has an account with us

Category L: As long as the user has an account with us

Category L information may be used or disclosed to a service provider or contractor for additional specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

Additional Personal Information Collection:

We may also collect other personal information outside of the mentioned categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels.

Participation in customer surveys or contests.

Facilitation in the delivery of our Services and responding to your inquiries.

Use and Sharing of Personal Information:

Learn about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?”

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered to be the “selling” of your personal information.

We have not disclosed, sold, or shared any personal information with third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

California Residents:

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice:

This section applies only to California residents. Under the California Consumer Privacy Act (CPA), you have the rights listed below.

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data:

Right to request deletion of the data – Request to delete:

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be Informed – Request to Know:

Depending on the circumstances, you have the right to know:

Whether we collect and use your personal information.

The categories of personal information that we collect.

The purposes for which the collected personal information is used.

Whether we sell or share personal information to third parties.

The categories of personal information that we sold, shared, or disclosed for a business purpose.

The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose.

The business or commercial purpose for collecting, selling, or sharing personal information.

The specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights:

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information:

If the business collects any of the following sensitive personal information:

Social security information, driver’s licenses, state ID cards, passport numbers.

Account login information.

Credit card numbers, financial account information, or credentials allowing access to such accounts.

Precise geolocation.

Racial or ethnic origin, religious or philosophical beliefs, union membership.

The contents of email and text unless the business is the intended recipient of the communication.

Genetic data, biometric data, and health data.

Data concerning sexual orientation and sex life.

You have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services. Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal information collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as publicly available information. To exercise your right to limit use and disclosure of sensitive personal information, please email support@truefitness.app or submit a data subject access request.

Verification Process:

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. Depending on the type of request you submit, we may ask you to provide certain information so that we can match it with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other Privacy Rights:

Objection to Processing:

You may object to the processing of your personal information.

Correction and Restriction:

You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.

Authorized Agent:

You can designate an authorized agent to make a request under the CPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

Opt-Out Request:

You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by submitting a data subject access request, by email at support@truefitness.app, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Colorado Residents:

This section applies only to Colorado residents under the Colorado Privacy Act (CPA). You have the following rights:

Right to be Informed:

Whether or not we are processing your personal data.

Right to Access:

Your personal data.

Right to Correct:

Inaccuracies in your personal data.

Right to Request Deletion:

Of your personal data.

Right to Obtain a Copy:

Of the personal data you previously shared with us.

Right to Opt-Out:

Of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

To submit a request to exercise these rights, please email support@truefitness.app or submit a data subject access request. If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@truefitness.app. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents:

This section applies only to Connecticut residents under the Connecticut Data Privacy Act (CTDPA). You have the following rights:

Right to be Informed:

Whether or not we are processing your personal data.

Right to Access:

Your personal data.

Right to Correct:

Inaccuracies in your personal data.

Right to Request Deletion:

Of your personal data.

Right to Obtain a Copy:

Of the personal data you previously shared with us.

Right to Opt-Out:

To submit a request to exercise these rights, please email support@truefitness.app or submit a data subject access request. If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@truefitness.app. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents:

This section applies only to Utah residents under the Utah Consumer Privacy Act (UCPA). You have the following rights:

Right to be Informed:

Whether or not we are processing your personal data.

Right to Access:

Your personal data.

Right to Request Deletion:

Of your personal data.

Right to Obtain a Copy:

Of the personal data you previously shared with us.

Right to Opt-Out:

Of the processing of your personal data if it is used for targeted advertising or the sale of personal data.

To submit a request to exercise these rights described above, please email support@truefitness.app or submit a data subject access request.

Virginia Residents:

Under the Virginia Consumer Data Protection Act (VCDPA), if you are a “consumer,” meaning a natural person who is a resident of the Commonwealth acting only in an individual or household context, you have the following rights:

Right to be Informed:

Whether or not we are processing your personal data.

Right to Access:

Your personal data.

Right to Correct:

Inaccuracies in your personal data.

Right to Request Deletion:

Of your personal data.

Right to Obtain a Copy:

Of the personal data you previously shared with us.

Right to Opt-Out:

Exercise your rights provided under the Virginia VCDPA:

You may contact us by email at support@truefitness.app or submit a data subject access request.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification Process:

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to Appeal:

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@truefitness.app. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

Updates to Privacy Notice:

Yes, the organization will update this privacy notice as necessary to stay compliant with relevant laws. Any updates will be indicated by a revised date, and the updated version will be effective as soon as it is accessible. Material changes to the privacy notice may be communicated to you by prominently posting a notice of such changes or by directly sending you a notification. It is encouraged to review this privacy notice frequently to stay informed about how your information is being protected.

Contact Information:

If you have questions or comments about this notice, you can reach out via email at support@truefitness.app or by post at the following address:

TrueFitness

38 Highfield

Dungarvan, Waterford x35 ee61

Ireland

Review, Update, or Delete Your Data:

Depending on the applicable laws of your country, you may have the right to request access to the personal information collected from you, make changes to that information, or delete it. To request a review, update, or deletion of your personal information, you can fill out and submit a data subject access request.