PRIVACY STATEMENT

Who is responsible for processing your (personal) data?

If you use our services, we are the data controller for the processing of your personal data according to the General Data Protection Regulation ("GDPR"). This means that we can determine the purposes for which and the means by which the personal data is processed. We see it as our responsibility to treat your data with due care and confidentiality.

Which personal data might be collected?

We collect this data in various ways, including when you log in to our app (which means you are ‘online’), when you enter it when using our services, contact our customer service or participate in surveys or marketing promotions.

When you contact us or create an account:

→ First- and last name;

→ Phone number;

→ Mailling address;

→ Email address;

→ Financial information;

→ And other relevant information.

When you use our services we collect:

→ Your age and gender;

→ Speed and tempo and perceived effort;

→ Username and password;

→ Date and time;

→ Health related data and features, such as your height, weight (history), heart rate, distance travelled. With regard to health information synchronised to our services, you expressly consent to the processing of such health information by us. We only collect and process health data from sensors connected to or linked to our services, from files that you have manually uploaded to us and from files that you have imported from other services.

→ Geolocation Information. We collect and process location information when you sign up for and use our software and applications. OPTIONAL: We do not track the location of your device when you are not using our services and are not online. In order to provide our best services, it is necessary for us to track the location of your device while you are using our services. If you want to stop tracking, you can do so at any time by changing the settings on your device.

→ Connected devices and apps. We collect information from devices and apps that you connect to our Services. For example, you may connect a watch, home trainer, heart rate

monitor or another device to our Services and information from these devices and apps is then transmitted to us.

→ Third Party Accounts. We allow you to register and sign in to our Services using accounts you have with third parties such as Strava, Google or Apple ("Third Party Accounts").

When you access our services through Third Party Accounts, we collect the information you choose to make available, such as your name, email address, profile information and preferences. The information is collected by the provider of the Third Party Account and is provided to us according to the provider's privacy statement. You can generally control the information we receive from these sources by using the privacy settings in your Third Party Account.

If you visit our web application

To make our web application(s) and website work properly, we may use cookies. A cookie is a small text file that is placed on your device when you visit our web application(s) and website. In such a cookie, information is stored about the way you use our web application(s) and website. You can find more information about the cookies we use in our cookie policy. If you use our web application(s) and website, data about you will be processed automatically. This concerns the following information:

→ Information on the browser used (type, version, screen resolution, etc.);

→ IP-address;

→ Language preferences;

→ Data related to the use of the web application(s);

→ Contact details left via the contact form.

In doing so, we may combine the information we have obtained with the information we have obtained from other sources, e.g. through the web application(s) and website. This allows us to improve the accuracy and completeness of the information.

Special and/or sensitive personal data?

We have no intention of collecting data from persons under 16 years of age, unless permission is obtained from their parents or guardian. However, we cannot check whether a website visitor is older than 16 years. For this reason, we encourage parents to be involved in the online activities of their children, in order to prevent the collection of data without parental consent. If you are convinced that we have collected personal information about a minor without this permission, please contact us using the contact details below. We will then make sure that this data will be deleted.

What are our processing purposes?

We may only process personal data if we have a legal basis for doing so. In most cases, this will be the performance of a contract, a legal obligation or our legitimate interests. Our legitimate interests may include marketing purposes and improving our services. If there is a legitimate interest, we will of course check that your interests do not outweigh ours.

We want to offer you the best possible service. To do this, we process data. Below, we indicate the purposes for which we process personal data:

→ Identify you as a person and address you appropriately;

→ To process and respond to your queries/questions;

→ Contact you;

→ Execute the agreement we have with you, including the performance of work and the processing of payment;

→ To keep our software and applications working properly;

→ To record your activities and analyse your performance. For example, to compare your past efforts, analyse your training and use your heart rate data to provide you with interesting and useful performance analysis;

→ To manage your training. For example, to set goals and use your training dashboard;

→ To customise your experience. We use the information we collect about you and your activities to personalise your experience. For example, we might suggest segments, routes or challenges that might interest you or new features you might want to try;

→ To improve our service. We also use your information to analyse, develop and improve our services.

How long will your personal data be kept?

We do not keep the data collected any longer than is strictly necessary for the purpose for which it was originally collected or processed. Insofar as no statutory retention period is specified for certain data processing purposes, we shall not retain such data longer than seven (7) years after the data is no longer necessary. For the retention period of data collected through cookies, please refer to our cookie policy.

How is your data protected?

Your privacy is important to us, and we ensure that your data is treated confidentially and with care. We have therefore implemented appropriate technical and organisational security measures to protect against the loss, theft or other unlawful processing of this data. For example, we ensure that only the necessary people have access to your data, that access to the data is protected and that our security measures are checked regularly.

With whom are personal data shared?

We may share/ disclose your personal data with third parties if we determine that such disclosure is legally required or reasonably necessary for the execution of the agreement. Relevant examples of such disclosure include submitting your personal data to a third party that is responsible for executing an agreement or using this data to accurately respond to questions or complaints. Furthermore, your data will only be passed on to persons or bodies outside the European Economic Area (EEA) if the country in question has an appropriate level of data protection.

Your rights regarding your personal information

We would like to inform you of your rights concerning the collection and use of your data. Under European law, individuals have the right to:

• Access their personal data

  Individuals have the right to access the personal data we collect and may obtain a copy of this data by contacting us.

  → Right to rectification

  Individuals have the right to have personal data rectified if it is incomplete and/or erroneous and can make a request for rectification. You can change (some of) your personal data in your account by editing your profile or by contacting us.

  → Right to erasure ('right to be forgotten')

  In some circumstances, you have the “right to be forgotten”. Those circumstances include:

  • The personal data are no longer necessary in relation to the purposes for which they were collected and/or processed;

  • You withdraw the (explicit) consent you previously provided to process the information, and there is no other legal ground for the processing;

  • You object to the processing of your personal data and have legitimate, compelling reasons which supersede our interests and reasons for processing your data;

  • You object to your personal data being processed for direct marketing purposes;

  • There are (no longer) any legal grounds for processing your data;

  • We are obligated to delete your personal data after the time limits set by laws or other regulations;

  • You are below the age of 16 and our website has collected your personal data.

  → Right to restriction of processing

  Individuals reserve the right to minimize the processing of your personal data. If we are informed that we are using incorrect personal data, we will not use this data until it has been rectified. We will furthermore restrict processing data if the processing is either unlawful or no longer necessary, or you oppose the erasure of your personal data and instead request the restriction of their use.

  → Right to data portability

  You reserve the right to data portability, i.e. to receive the personal data concerning you that you have provided to us.

  → Right to object

  You have in some cases the right to object to the processing of your personal data, for example because of your specific situation or against direct marketing.

  If you would like to exercise any of these rights, please get in touch with us using the contact details provided below.

  
  

Contact

MoveLab Studio B.V. Moutlaan 35

7523 MC ENSCHEDE

support@movelab.studio

Complaints?

If you are unhappy with the way we collect, store, or process your personal data, please contact us. If the situation is not resolved to your satisfaction, you may file a complaint with the Dutch Data Protection Authority (DPA).

Updates to our privacy policy

We reserve the right to adjust this privacy statement. If there are any changes, we will publish them on our website.