PRIVACY POLICY

Last updated 8 September 2022.

We believe you should always know what personal data we collect about you, how we use it, and what control you have over this data. We want to be transparent and explain this information to you in our privacy policy below (“Privacy Policy”).

About Us

We are SIA WSWCF Workout APP, registration number 4020328858, registered address Dambju street 2, Marupe county, LV-2107, Latvia, operating under the name WSWCF Workout APP (“we”, “us” or “our”). We are the controller of your personal data.

You can contact us by e-mail address wswcfworkoutapp@gmail.com.

About Our Privacy Policy

This Privacy Policy explains

  • what personal data we collect about you;
  • how we use your personal data;
  • your rights concerning your personal data.

The Privacy Policy applies to the use of the website wswcf.app (“Website”) and application WSWCF Workout App (“Application”) and our communication concerning the use of the Website and Application.

Definitions

Authentication data – login information needed to identify you as a system user, e.g., password, username.

Contact information – data needed to contact you, e.g., e-mail address, phone number, postal address.

Identification data – information that allows us to establish and verify who you are, e.g., name, surname, or social media username.

Order information – details regarding the delivery of your order, e.g., products and services ordered, order status, or invoice number.

Payment details – information needed to receive and transfer payments, e.g., payment method, billing address, bank account number, payment card details (including card number, CVV/CVC code, card expiration date).

Payment status – details related to your payment, e.g., whether the payment was successful, payment amount, date, time and place.

Traffic and performance data – information that is used by website or application analytical tools, e.g., IP address, location, demographic data, device type.

User ID – an identifier that relates to an individual device, browser or app, e.g., an International Mobile Equipment Identity (IMEI) number, Media Access Control (MAC) address, Widevine Device ID, Firebase installation ID, or advertising identifier.

How Do We Use Your Personal Data and Why?

We use only the minimum amount of personal data needed.

We will indicate where the provision of personal data is voluntary or necessary.

Below, we describe why and how we use your personal data and what is the legal basis.

User Profiles

What do we do with your personal data and why? What personal data do we use? Legal basis
We collect and store your data from social networks (Google, Apple) that you use to create your user profile.
Identification data
Contact information
Birthday
Age
Gender
Profile picture from Google or Apple account
E-mail
Country
To perform the contract with you
We collect, store, and verify your data when you sign up or log in, to allow you to create your user profile and give you access to it.
Identification data
Authentication data
Contact information
It’s important for us to establish and verify your identity so that only you have access to your account (legitimate interests)
We collect your data to provide you tailored services.
Fitness level
Weight
Height
Workout preferences
To perform the contract with you
We send information about changes to our terms, conditions, or policies to keep you updated.
Identification data
Contact information
It’s required by law (GDPR, local consumer rights protection laws)

Orders & Delivery

What do we do with your personal data and why? What personal data do we use? Legal basis
We collect your data to prepare and deliver your order.
Identification data
Contact information
Order information
Payment details
Payment status
To perform the contract with you
We access your data to send you reminders, including in the form of push notifications, about scheduled workouts or livestream.
Calendar events
Your consent

Payments

We use Apple Pay and Google Pay services for processing your payments. We receive from them information about the status of your payment.

What do we do with your personal data and why? What personal data do we use? Legal basis
We receive the data from the payment service providers and store it to have a proof of our transaction for tax and accounting purposes.
Identification data
Payment status
To perform the contract with you It’s required by law (local tax and accounting laws)

Marketing

What do we do with your personal data and why? What personal data do we use? Legal basis
We send you marketing information (e.g., newsletters, information on discounts, sales, new products, or services) to keep you updated about our offers.
Identification data
Contact information
It’s important for us that users are kept updated about our products and services (legitimate interests)
We analyse your reactions to our messages to understand the effectiveness of our messages and marketing campaigns.
Whether you have opened the message or its attachments
Whether you have clicked on the links in our message
It’s important for us to understand the results of our campaigns (legitimate interests)
It’s important for us to provide even better campaigns in the future (legitimate interests)
It’s important for us to improve our communication with our users
We show you adverts as you browse the web to inform you about our offerings. You can also check for more information in our cookie policy here.
Traffic and performance data
Contact information
Your consent

We use Mailchimp for sending marketing information (see their privacy policy here).

Lotteries, Giveaways, Competitions

What do we do with your personal data and why? What personal data do we use? Legal basis
We collect and analyse your application to run lotteries, giveaways, or competitions.
Identification data
Contact information
Your replies
To perform the contract with you
It’s important for us to know the user’s review about our products and services (legitimate interests)
It’s important for us to let the participants know the winner (legitimate interests)
It’s required by law (the local law on lotteries and competitions, the local consumer rights protection laws)
We announce publicly if you are the winner to let everyone know who the winner is.
Identification data
The fact that you have won
Your photo
We inform you privately if you are the winner to let you know that you have won and how to claim the prize.
Identification data
Contact information
The fact that you have won

Analytics

What do we do with your personal data and why? What personal data do we use? Legal basis
We analyse the Website's and Application's traffic and performance to continuously improve our Website and Application, and the user experience. We use the following analytical tools:
- Google Analytics for Firebase (see their privacy policy here)
- Apple iOS App Analytics (see their privacy policy here)
Traffic and performance data
User ID
Your consent
We analyse sales information to understand our users’ tastes and use this information for offering new products and services.
Identification data
Contact information
Order information
Payment status
Traffic and performance data
User ID
It’s important for us to improve our services and provide the best service to you (legitimate interests)

Interactions with social media

What do we do with your personal data and why? What personal data do we use? Legal basis
If you wish, we enable you to share information on social media about your progress or work with us.
Photos or videos
Workout activities
Social media accounts
Your consent
To perform the contract with you
We send you push notifications about social post interactions
Information that you have shared with others
Your consent

Fraud prevention and security

What do we do with your personal data and why? What personal data do we use? Legal basis
We collect your data to prevent fraud and ensure secure use of our application
Traffic and performance data
User ID
It’s important for us to prevent fraud and ensure security of our application (legitimate interests)

Data Security Practices

We have implemented the following Data Security Practices in the Application:

  • Authentication that allows to ensure that only the existing users can access the Application
  • Authorisation that allows validating that the user is allowed to access and use the Application
  • Logging that records when and who accessed which aspects of the Application that is helpful especially when there is a security breach in the Application

Cookies and Similar Technologies

We use cookies and similar technologies on our Website and Mobile application. You can see our cookies policy here.

Where Do We Obtain Your Personal Data?

We obtain your personal data:

  • from payment service providers (Apple Pay, Google Pay)
  • from e-mail marketing service provider (Mailchimp)
  • from social media platforms if you log in by using your social media account (Google, Apple)
  • directly from you (for example, when you purchase a product or a service, contact us with a question or complaint, create user’s profile, respond to a survey or sign-up to receive marketing communications)
  • from our group companies that you have interacted with

To Whom We Disclose Your Personal Data?

We disclose your personal data to the following categories of data recipients:

  • payment service providers (Apple Pay located in USA, Google Pay located in USA)
  • analytical service providers (Google Analytics, Google Analytics for Firebase, Apple iOS App Analytics)
  • e-mail marketing service provider (Mailchimp)
  • accounting service providers located in Latvia
  • data centre service providers located in Belgium
  • IT maintenance service providers located in Romania

We confirm that any third party with whom we share your personal data will provide the same or equal protection of personal data as stated in this Privacy Policy.

How Long Do We Store Your Personal Data?

We will not store your personal data longer than necessary. We will destroy it once we have determined that we no longer need to hold your personal data.

The criteria used to determine the period of storage of your personal data are:

  • the purpose, why personal data was collected;
  • the length of time, while we have a contractual relationship with you;
  • the existence of a legal obligation under the applicable law;
  • the necessity to store the personal data considering our legal position (such as applicable statutes of limitations, the existence of litigation or investigation).

What Rights Do You Have In Relation to Your Personal Data?

You have various rights in relation to your personal data that we process. We have described these rights in the table below. There are some exceptions to these rights, however. If we refuse your request, we will explain the reasons for doing so.

If you wish to exercise any of these rights, please get in touch with us by sending an e-mail to wswcfworkoutapp@gmail.com.

Your rights Explanation
Right to request access
You are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data.
Right to rectification
You may request that we rectify any inaccurate or incomplete personal data that we process about you.
Right to erasure (“right to be forgotten”)
You have the right to request that we erase your personal data. You can also delete some of your personal data within the settings section of our Application.
Right to restrict processing
You have the right to request that we restrict our processing of your personal data where:
- you believe such data to be inaccurate (for a period while we verify the accuracy of this data); or
- our processing is unlawful, but you want to restrict data processing, not delete the data; or
- we no longer need the data, but you need it for the establishment, exercise or defence of legal claims; or
- you have objected to personal data processing (for a period while we are conducting the review).
Right of data portability
You have the right to transfer your personal data between data controllers. This means that you can request your personal data that you have provided to us, in a structured, commonly used, and machine-readable format and transfer this data to another controller.
Right to object
You have the right to object to the processing of your personal data where we are processing your personal data:
- based on our legitimate interests (or those of a third party); or
- for the performance of a task in the public interest; or
- in the exercise of official authority.
You can always object to the processing of your personal data for direct marketing purposes (including profiling that is related to such direct marketing).
You can also object to the processing of your personal data for scientific or historical research purposes or statistical purposes unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Right to withdraw consent
If you have consented to our processing of your personal data, you have the right to withdraw consent at any time, free of charge. You can also withdraw your consent to our access to and processing of certain personal data within the settings section of your mobile device.

How to Complain?

If you have any concerns about our use of your personal data, you can make a complaint to us by sending it to e-mail wswcfworkoutapp@gmail.com.

In case you could not solve your problem with us directly, or you believe that there are breaches in the processing of your personal data, you can also complain to a data protection authority in a European Union Member State of your habitual residence, place of work or place of the alleged breach. Contact information of these authorities is accessible on the website of the  European Data Protection Board.

This privacy policy was created using Ligalio Privacy Policy Generator.