FitWorld Privacy Policy Last Updated: Feb 1, 2022 This Privacy Policy describes how FitWorld GmbH and its affiliates ( "FitWorld", "we", or "us") collect and process your personal information when you visit the FitWorld site, use any FitWorld services including FitWorld applications (the "App") or fitness equipment (such as the FitWorld LiveBox or Fitness Mirror), or when you interact with us via our call centers, customer support service including live chats and e-mail communications, social media channels, studios or retail shops including our showrooms or concession stores (together, the "Services"). 1. WHAT PERSONAL INFORMATION WE COLLECT The personal information that we process about you broadly falls into the following categories: 1.1 Information that you provide to us Contact Information: Your name, email address, mailing address, phone number that you provide to us, for example, when you register for any FitWorld Services, subscribe for FitWorld marketing, communicate with us or register for a test session. Purchase Information: Payment information (such as your credit card number), order details, delivery information (such as shipping and delivery address) that you provide when you purchase any FitWorld Services. User Profile Information: Any information that you provide to us in connection with your FitWorld "User Profile", such as contact information listed above, username, and any additional information you choose to provide to enhance your use of the Services, including your weight, height, age, gender, general location, tags, birthday, image or avatar. User Profiles are set to public by default, which means that other registered FitWorld users will also be able to view the information associated with your User Profile. Voice and Likeness: Your visual image, likeness and voice recording (e.g., via photographs, video and/or CCTV) if you visit our studios and/or showrooms or participate in live classes. Additionally, FitWorld fitness equipment and the FitWorld App may contain a camera, microphone and voice control features. These features are in use only when activated by you, for example, to take a FitWorld user profile photo or to initiate or work out with audio & video interactions from another user and, for usage of the FitWorld App, any device settings that you have activated. Communications Information: Any details of your communications/interactions with us, including when you call, email, live chat, video call or text with our customer or technical support teams or communicate with us via social media channels or community forums. We may record customer and technical support calls for training and monitoring purposes and to help resolve customer issues. We will tell you before recording and, where required by applicable laws, obtain your consent for the collection of these recordings. Survey and Review Information: Any information you provide to us (or otherwise publish) in connection with a survey you complete or review / testimonial you provide about FitWorld goods and/or Services. Promotions, Sweepstakes and Competition Information: Any information that you provide to us in connection with any promotions, sweepstakes and/or competitions we run, including for example, responses to competition questions. Other User Information: Any other information that you may provide to us in connection with your use of FitWorld products or Services, visits to FitWorld studios or retail shops and / or other contact that you have with the FitWorld team. 1.2 Information that we collect automatically Information generated through use of the Services: Such as classes registered for and participated in, FitWorld users you are following and who are following you, details of workout performances such as leaderboard rank, total workout output, workout speed, distance and calories burned, in-class heart rate, in-studio attendance history. Information from your device. Information from and about the device you use when you use our Services including IP address, identifiers, type, mobile carrier, browser type and language, location (see below) and operating system. We may also collect information about how your device interacts with our Services, such as the content you access, pages and sites visited before and after you reach the Services, the date and time of your use, the amount of time spent on the Services, and other actions taken through use of the Services such as preferences. Location Information. Depending on how you use the Services and your device settings, type and connectivity, we may collect location-based information including your IP address, GPS location, city, county, zip code and region and your smart device’s proximity to “beacons”, Bluetooth networks and/or other proximity systems. You will have the ability to opt-in or out of our collection of location information by selecting the location and Bluetooth settings in your device but this may affect your ability to use certain location dependent Services (such as track your run functionality). Some of this information may be collected using Cookies and Similar Technologies as described below. 1.3 Information we collect from third parties Third Party Applications: If you access our Services through a third party application, such as the Apple App Store or Google Play App Store (together with any similar applications, "App Stores") or Social Networking Sites ("SNS") such as Instagram, Twitter, Facebook or WeChat, we may collect information about you from that Third-Party application that you have made public via your privacy settings. This may include: your name, your SNS user ID, your App Store user name, location, sex, birth date, email, profile picture and your contacts on the SNS. Third Party Sources: We may receive information about you from other sources to supplement information provided by you or where we are conducting a joint marketing campaign with a selected partner and you have provided consent for us to receive your information. The supplemental information allows us to enhance our ability to provide you with information about our business, products and Services and to provide you with any marketing communications that you have provided your consent to receive. 2. HOW WE USE PERSONAL INFORMATION We use your information for the following purposes: To provide you with the Services: Including to verify your identity and set up your FitWorld account, to process payments and fulfil product orders, to provide you with access to our Services such as class bookings and participation, workout tracking performance and statistics, and to enable you to compete and communicate with other FitWorld users. To communicate with you: Including for administrative matters (such as account management, updates to terms, or system maintenance), to provide you with information about our Services (such as product delivery and logistics, servicing and technical support), and to respond to any questions, comments or requests you have about our Services. To send you marketing: Including contacting you by phone, email, postal mail or SMS with information about news, offers, products and/or Services that might be of interest to you, as permitted by applicable law. For analytics, research and product and Service improvement purposes: Including monitoring and measuring your use of our products and Services and conducting research/surveys, to understand how they are being used and how they can be improved. For quality assurance and training purposes: Including monitoring communications and interactions with you to ensure the quality of our customer and technical support services, appropriate training of our people and to resolve your complaints. We will provide notice and consent options for monitoring of communications as required by applicable law. For personalisation and advertising: Including to provide you with a personalised and tailored Service, to serve you with FitWorld advertising on third party properties and to serve you with relevant advertising and content on our Services. To ensure the security and integrity of our Services: Including to detect and combating any abuse or any harmful activity, fraud, spam, and illegal activity affecting our Services, or in the case of CCTV images, the prevention & detection of crime and for health and safety of individuals on FitWorld premises. To comply with any applicable law and/or regulations. For any other lawful business purpose: Including any incidental business purpose related to or in connection with any of the above, or for any other purpose disclosed to you at the point at which we collect your personal information. 3. COOKIES AND SIMILAR TRACKING TECHNOLOGIES We use cookies and similar tracking technologies such as pixel tags/web beacons and social media widgets (collectively "Cookies") to collect and use personal information about you, including for analytics purposes and to serve you interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookies Policy. 4. WHO WE SHARE YOUR PERSONAL INFORMATION WITH We may disclose your personal information to the following categories of recipients: Group Companies, Third Party Service Providers and Business Partners: We may share your personal information with other users of our group, with our third party service providers (such as those who provide IT, analytics, payment processing, and customer sales, technical support or delivery services), third party business partners who otherwise process personal information for purposes that are described in this Policy (such as advertising partners) or who are otherwise notified to you when we collect your personal information (such as financing partners if you select this option during the checkout process). We do not sell your personal information. Third Party Apps that you link to your FitWorld account: As part of the functionality of our Services, we offer pairing functionality to enable you to connect your FitWorld account with third party applications. If you choose to connect your FitWorld account, we will share certain personal information with the paired application dependent on what information you choose to share with such third party apps or have otherwise been notified will be shared during the pairing process. The information may include information generated through your use of the Services (i.e. workout information) and other contact and profile information. The processing of your personal information by such third party applications shall be governed by the privacy policies of those third parties. Other Users: Depending on your User Profile settings and how you interact with our Services, certain personal information of yours may become available for other FitWorld users to see. User profiles are set to public by default. Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts or other Third Parties: We may share your personal information, including CCTV images, with competent law enforcement bodies, regulators, our insurers, external legal advisors, government agencies, courts or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise, establish or defend our legal rights (including to collect amounts owed to FitWorld); (iii) to protect your rights or vital interests or those or any other person; or (iv) to detect, prevent or otherwise address security, fraud or technical issues. Potential Buyers (and their agents and advisors): We may share your personal information with actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, provided that we inform the buyer or transferee that it must use your personal information only for the purposes disclosed in this Privacy Policy. 5. INTERNATIONAL DATA TRANSFERS Your personal information may be transferred to, processed and stored in countries other than the country in which you are resident. The recipients of such information may be located in any country where FitWorld has a place of business and additional territories where our suppliers and partners may transfer data, details of which can be provided upon request. We take appropriate safeguards to protect your personal information in accordance with this Privacy Policy specifically in relation to any international transfer. This includes implementing an intra-group data sharing agreement that includes safeguards and protections for any use of your personal information by our group entities and incorporates the European Commission's Standard Contractual Clauses, which require all group companies to protect relevant information in accordance with Switzerland, European Union and UK data protection laws. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request. 6. YOUR RIGHTS 8.1 Consent If we have collected and process your personal information with your consent (including any sensitive or special category data), then you can withdraw your consent at any time by using settings on the FitWorld product or App (as applicable), via settings on your device or by contacting us using the details provided under How To Contact Us. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. 6.2 Direct Marketing We may send marketing communications for purposes notified to you (including as specified in section 2 above) and, where required by applicable law, with your consent. You can unsubscribe from direct marketing at any time by following the instructions below or by contacting us using the details provided under the How To Contact Us. We will process your request within a reasonable time after receipt, in accordance with applicable laws. Unsubscribe options are provided in electronic marketing communications as required by applicable law. Email, SMS and Telephone: You can unsubscribe from email communications at any time. To stop receiving our promotional emails, follow the unsubscribe instructions in the email messages you receive from us, or contact us using the details provided under the How To Contact Us. We will process your request as soon as practicable after receipt, in accordance with applicable laws. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding FitWorld and our Services and, to the extent permitted by law, you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy). If you opt in, you will receive text messages from FitWorld. “FitWorld Account” text messages are non-promotional messages from FitWorld alerting you to important information, like the details of your delivery, failed subscription payments and other alerts related to your FitWorld subscription or purchases.  We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within the timescales required by law. Push Notifications: If you opt-in on your device, FitWorld may occasionally send you push notifications through our Apps with updates, achievements and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your device. 6.3 "Do Not Track" Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that, because there has been no agreed industry standard, we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. 6.4 Your rights to access and manage personal information We recognize the importance of your personal information and provide simple ways for you to exercise the following rights: access (right to know), portability, rectification (correction or update), deletion (erasure), object and to restrict processing. You can exercise these rights via the following ways: Submit a request via our email hello@fitworld.live Update your profile and account settings. Contact us if you have any questions 7. DATA RETENTION FitWorld retains the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. CCTV images are retained for 14 days in Germany and 30 days elsewhere. When we are no longer required to retain the personal information as described above, we will destroy, erase, or de-identify it. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold it. 8. SECURITY OF YOUR INFORMATION We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical and physical safeguards (which vary depending on the sensitivity of the personal information) designed to protect against unauthorized use, disclosure or access of personal information. 9. LEGAL BASIS FOR PROCESSING Our legal basis for collecting and using the personal information described above will depend on the personal information concerned, applicable laws and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as to provide our Services), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Services, to communicate with you as necessary to provide our Services to you, and for our legitimate commercial interests such as responding to your queries, improving our products and Services, undertaking marketing, or detecting and preventing illegal activities. We may have other legitimate interests and we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, you can contact us using the details provided under the How To Contact Us section below. 10. CHILDREN’S PRIVACY You are not permitted to use our Services if you do not meet the minimum age requirement applicable in your jurisdiction, and if you do not meet the age requirements as specified in our Terms of Service. If you learn that your child does not meet the requirements set out above and has provided us with Personal Information, you may alert us at hello@fitworld.live. We will take steps to delete such information from our files as soon as possible and terminate the child’s account. 11. HOW TO CONTACT US If you have any questions about our privacy practices, this Privacy Policy or would like to contact us or our Data Protection Officer, you can do so by email at hello@fitworld.live You can also complain to a data protection authority about our collection and use of your personal information if you feel that FitWorld has not acted in accordance with applicable laws. For more information, please contact your local data protection authority. 12. UPDATES TO OUR PRIVACY POLICY We may update our Privacy Policy from time to time. When we do, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this notice.