Privacy Policy

Your privacy is important to us

Pact Support

In order to use some of our apps or websites, we may ask you to enter your name, email, current weight and height, target weight, fitness level, areas for improvement, and food preferences, and ask other onboarding questions. In some of our apps you are able to skip some of the onboarding questions by tapping on Skip or similar indication. We also automatically collect from your device: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and some other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the app, to serve ads.

For improving the app and attracting users, we use third party solutions. As a result, we may process data using solutions developed by Facebook, Firebase, Google, Apple, Crashlytics. Therefore, some of the data is stored and processed on servers of such third parties. This enables us to (1) analyze different interactions (how often users make subscriptions, the average weight and height of our users, how many users chose a particular area for improvement); (2) serve ads (and are able to show them only to a particular group of users, for example, to subscribers). Consequently, we, in particular, better understand in what of our features and content you see the most value and are able to focus on them to enhance your experience and increase the quality of our products.

Please read our Privacy Policy below to know more about what we do with data (Section 2), what data privacy rights are available to you (Section 5) and who will be the data controller (Section 12). If any questions will remain unanswered or you would like to exercise your privacy rights, please contact us at info@fllowfitness.com.

Privacy Policy

This Privacy Policy explains what personal data is collected when you use our mobile applications, websites and the services provided through them (together "App" or "Service"), how such personal data will be processed.

By using the service, you promise us that (i) you have read, understand and agree to this privacy policy, and (ii) you are over 16 years of age (or have had your parent or guardian read and agree to this privacy policy for you). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account and contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or by us if you purchased it directly from our websites; and (c) delete the App from your devices.

Any translation from English version is provided for your convenience only. In the event of any difference in meaning or interpretation between the English language version the English language version will prevail. The original English text shall be the sole legally binding version.

"GDPR" means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

"EEA" includes all current member states to the European Union and the European Economic Area.

"Process", in respect of personal data, includes to collect, store, and disclose to others.

Contents

  1. Categories of personal data we collect
  2. For what purposes we process your personal data
  3. Under what legal bases we process your personal data (Applies only to EEA-based users)
  4. With whom we share your personal data
  5. How you can exercise your privacy rights
  6. Age limitation
  7. International data transfers
  8. Changes to this privacy policy
  9. California privacy rights
  10. Data retention
  11. How "do not track" requests are handled
  12. Personal data controller
  13. Contact us

1. Categories of personal data we collect

We collect data you give us voluntarily (for example, when you choose your areas for improvement or send us an email). We also may receive data about you from third parties (for example, when you sign in via Apple). Finally, we collect data automatically (for example, your IP address).

1.1. Data you give us

You provide us information about yourself when you register for and/or use the Service. For example: name, age, gender, data on physical characteristics (including height, weight, areas for improvement), fitness level, food preferences (including diet preferences; preferred number of meals, foods you do not like), meditation preferences, sleep, type and duration of physical activities you engage in, food you log, email address, billing and mailing address.

Some pieces of information we collect may be regarded as special category of personal data or sensitive data under certain data protection legislation that we are subject to. When this is the case, for example, when we ask you whether you need a meal plan for diabetes or whether you decide to opt-in for a limb loss special program, we will strive to ask your consent for processing of such data and provide you with an easy option to withdraw the consent. If "All categories of personal data" or other generalization is used in the text below, it should mean to exclude special category of personal data or sensitive data.

1.2. Data provided by third parties

When you use sign in with Apple to register an account in the App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with Apple screen.

1.3. Data we collect automatically

  • Data about how you found us: We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
  • Device and Location data: We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
  • Activity data: When you sync your Pact device through the App, we collect your activity data such as steps, distance, pace, the type of physical activity you engage in and the duration of your activity, calories burned, heart rate, sleep and its quality.
  • Usage data: We record how you interact with our Service. For example, we log your taps on certain areas of the interface, the features, and content you interact with, workouts you do, the time and duration of your workouts, how often you use the App, how long you are in the app, your training program progress, and your subscription orders.
  • Advertising IDs: We collect your Apple Identifier for Advertising ("IDFA") or Google Advertising ID ("AAID") (depending on the operating system of your device).
  • Transaction data: When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data.
  • Cookies: A cookie is a small text file that is stored on a user\'s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies.

2. For what purposes we process your personal data

2.1. To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. This includes providing you with metrics tracking your steps, activity, heart rate, sleep, and other trends from your Pact device.

2.2. To customize your experience

We process your personal data, in particular, such as your characteristics and preferences, to adjust the content of the Service and provide content tailored to your personal preferences.

2.3. To manage your account and provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate.

2.4. To communicate with you regarding your use of our Service

We communicate with you, for example, by push notifications. These may include reminders and motivational messages encouraging you to follow your training and nutrition plan, or other information about the App.

2.5. To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products.

2.6. To send you marketing communications

We process your personal data for our marketing campaigns. We may add your email address to our marketing list, provided we receive consent or otherwise establish legal basis for sending you marketing communications.

2.7. To personalize our ads

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time.

2.8. To process your payments

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing.

2.9. To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud.

2.10. To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

3. Under what legal bases we process your personal data (Applies only to EEA-based users)

In this section, we are letting you know what legal basis we use for each particular purpose of processing. This section applies only to EEA-based users.

3.1. Your consent

  • To send you marketing communications
  • To process your personal data that is regarded as special category of personal data or sensitive data
  • To process data obtained from the Pact Band

3.2. To perform our contract with you

  • Provide our Service (in accordance with our Terms and Conditions of Use)
  • Customize your experience
  • Manage your account and provide you with customer support
  • Communicate with you regarding your use of our Service
  • Process your payments

3.3. For our (or others\') legitimate interests

Unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

3.4. To comply with legal obligations

4. With whom we share your personal data

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service.

4.1. Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:

  • Cloud storage providers (Amazon)
  • Data analytics providers (Facebook, Google, Firebase, Crashlytics)
  • Measurement partners
  • Marketing partners (in particular, social media networks, marketing agencies, email delivery services)
  • Payment processing providers
  • Communication services providers (Intercom, Zendesk)
  • Shipping providers

4.2. Apple Health Kit or Google Fit

Provided you give express permission on your device, we may receive (read) or/and write (share) data about your activity with/from Health App.

4.3. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.

4.4. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers\' information is generally one of the transferred business assets in these types of transactions.

5. How you can exercise your privacy rights

To be in control of your personal data, you have the following rights:

  • Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us in the profile section of the App.
  • Deleting your personal data. You can request erasure of your personal data, as permitted by law.
  • Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.

Additional information for EEA-based users

If you are based in the EEA, you have the following rights in addition to the above:

  • The right to lodge a complaint with supervisory authority. You have the right to lodge a complaint with a competent data protection supervisory authority.
  • The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data.

To exercise any of the available to you privacy rights, please send a request to info@fllowfitness.com.

6. Age limitation

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at info@fllowfitness.com.

7. International data transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy.

8. Changes to this privacy policy

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy.

9. California privacy rights

This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act ("CCPA") and California\'s Shine the Light law.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect, to delete their personal information, to opt-out of any "sales" that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at info@fllowfitness.com.

10. Data retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App.

11. How "Do not track" requests are handled

Except as otherwise stipulated in this Privacy Policy, this App does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.

12. Personal data controller

Fllow Ltd will be the controller of your personal data.

13. Contact us

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at info@fllowfitness.com.

Effective as of: April 5th, 2024