PRIVACY POLICY

At JSC “Equity Algorithm” (hereinafter – the «Champions Fitness Center») Champions Fitness Center, we’re continuously striving to provide you with the best possible experience – and your privacy is important to us.

With the following Privacy Policy we want to:

1. IN GENERAL

1. JSC “Equity Algorithm Center, 8/13 office B XVIII F 5 office 541 Pravdy street, Moscow, Russia, 125040 (“Champions Fitness Center “), Champions Fitness Center process your personal data when you use our app (“App”) or website (“Website” and, together with the App, “Products”). The processing of your personal data takes place in compliance with applicable local data privacy laws, e.g. the EU General Data Protection Regulation (“GDPR“) and the Russian Federation data protection act in its current form.

2. In this privacy policy (“Privacy Policy”) we want to provide you with information about us, the nature, scope and purposes of the data collection and use, giving you insights into the processing of your personal data.

2. CONTROLLER

1. Controller. In general, the controller of data processing is Champions Fitness Center. You can contact us via email under the Email Address.

2. Data Protection Officer. Our data protection officer can be contacted under the Email Address support@equityalgorithm.com. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact him/her.

3. WHICH DATA WE COLLECT AND PROCESS

1. In General. Champions Fitness Center processes personal data that you as a user of the Products make available to us, for example by using our Products, and that others provide to us (“Data”).

2. Categories of Personal Data.

These are the categories of Personal Data we collect directly or indirectly from you:

Identity information – includes: name (first, last), date of birth, e-mail address, gender, profile picture, unique consumer identifier number, social media identifiers and information passed along to us via your Facebook or Google account, and gift card (if applicable) codes that are assigned to you. We can use it to verify your identity.

Contact information - includes: your phone number, shipping and billing address, e-mail address, Messenger ID, social media handle, any other communication channel you have used to contact us for more information. We use it to contact you for different reasons depending on the purpose.

Location information - includes: your residential location, current log-in location (IP address), and/or GPS location (if you wish to share us, for example through your mobile device settings) or other phone related location data (e.g. via WiFi or Bluetooth), or the specific Champions Fitness Center site you have visited that might give us clues about where you are. We use it to operate our products and adapt your product experience to your location.

Size information - includes: height, weight, chest, waist, hip, inseam, body shape, heel-toe measurement, other biometric data, including those collected using artificial intelligence. We use it to operate our products and make sure your gear fits.

Purchase information - includes: payment provider, duration of your Champions Fitness Center subscription, price, currency, VAT (based on country info). We use payment providers to process payments. Although we do not store any credit card information ourselves, we store a payment ID number that is given out by the respective provider (e.g. Apple, Google, PayPal) and can be allocated to you. We use it to process your payments.

Behavioral and Profile information - includes: your shopping history, your shopping preferences, in-store interactions, product reviews, social media interactions with us, and any other intelligence we have about you to help us learn you as a consumer better, including “Community information”. We use it to know you better as a consumer, so we can send you marketing messages containing only products and services that we think you might be interested in.

Community information – includes: friendship and follower information in the Champions Fitness Center community, information provided by you when you participate in various Champions Fitness Center events and groups/communities either as a trainer, team member, a participant or as a promoter of our events, including for example: pictures, videos, your team, your interests and preferences, your feedback, leaderboards, event participation, joined groups and registration details.

We use Community information to operate our products, to organize the events and communities, and to connect you with other members within our communities.

Social Media information – includes: information obtained through your interaction with us on various social media channels such as Facebook, Instagram, Google, etc., including: any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”. We obtain this information from the social media network (e.g. Facebook, Snapchat, Instagram, etc.) directly or indirectly through third-party agencies we have agreements with.

Device information – includes: Information about your device or browser that give us an idea about your browsing behavior or device usage. Your device information is collected by our app, and your browser information is collected by our cookies, tags, and pixels. This is often required for network security purposes. This includes, but not limited to: IP address, date and time of the visit, how long you remained on our website, transmitted data volume, the referral URL (if you came to our site via a different site or an advertisement), the pages visited on our site, your browser type (including language and version of the browser software) and add-ons, device identifier and features, device type, versions, operating system.

Activity information - includes: fitness data (for example workout start and end times, activity type, sports category), sensor data (this includes, but not limited to: step goal, duration, pace, distance, calories, heart rate, and speed), nutrition information (e.g. time, calories, meal information (name, type, macronutrients, micronutrients), and other data (e.g. routes and photos including location data) related to your fitness app. We use it to operate our products, to help you improve your performance goals and improve your user experiences and identify what products might be best for you based on your exercise patterns.

Preference information - includes: preferred language, log-in location, units (distance, weight, temperature), personal goals and motivation (e.g. yearly running goal, weight goal), training plan information (e.g. start date, training plan, associated fitness activities), and your product reviews. We use it to give you convenience when you visit and/or shop on our sites and app.

3. Data from Others.

Registration via Facebook or Google

If you register a Champions Fitness Center account via social login, we will receive the following information:

Facebook Friend List

We will receive information about your friends on Facebook if you explicitly allow us to access it. We will use this information to make friend suggestions in the Products, but do not store it.

Import Fitness Activity Information from Connected Accounts

General. We offer an automatic import of your fitness activity information from other platforms like Garmin, Nokia Health (Withings), and Fitbit. You have to explicitly agree to connect your account from those platforms to your Champions Fitness Center account beforehand in order to import such data.

Apple HealthKit. We use Apple’s (Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, USA; “Apple”) HealthKit (for more information see here) framework, which provides a central repository for health and fitness data on iPhone and Apple Watch and – with the user’s explicit consent – lets app communicate with the HealthKit store to access and share this data. We process the following Data, obtained through the HealthKit framework and the Apple CoreMotion processor (for more information see here), for the purposes described below and with explicit consent by the user: steps, calories, duration, and heart rate. New data attributes may be added to the HealthKit framework, which will be portrayed in the Product and which you have to consent to. Champions Fitness Center and Champions Fitness Center’s analytics service providers may analyze engagement data for research purposes designed to provide a personalized experience and motivate engagement in healthy habits. Champions Fitness Center does not use information gained through the HealthKit framework for advertising or similar services. You can always stop Champions Fitness Center from accessing your data by changing the settings of your mobile device.

Google Fit. We use Google’s Fit SDK (for more information see here) which is an open platform that lets users control their fitness data. We process the following Data, obtained through the Google Fit SDK, for the purposes described below and with explicit consent by the user: steps, calories, duration, and heart rate. New data attributes may be added to the Google Fit framework, which will be portrayed in the Product and which you have to consent to.

4. Service Use

Google Analytics

This Website uses Google Analytics, a web analysis service of Google. Google Analytics uses cookies. See our Cookie Policy for more information on cookies and how to opt-out of them. We use Google Analytics to analyze and constantly improve the use of our Products. The Products use Google Analytics in conjunction with the option “_anonymizeIP()”. This means, IP addresses are processed in a shortened form in order to prevent transmission of any personal data. The basis for the processing of Data are our legitimate interests.

Firebase & Google Analytics for Mobile

General. For App on iOS and Android we use Google’s Firebase (for more information see here) and Google Analytics for Mobile (for more information see here). User data is transmitted in an anonymized form to Google. Our App use identification for mobile devices, including the Google Advertising ID (“GAID”) and the ID for Advertising for iOS (“IDFA”), as well as technologies similar to cookies for the use execution of the Analytics for mobile service.

Purpose. We use Firebase and Google Analytics to analyze and constantly improve the use of our Products. Through the statistics we are able to improve our services and make them more interesting for users. In those special cases in which personal data is transmitted to the USA, Google is certified via EU-US privacy shield. The basis for the processing of Data are our legitimate interests.

Adjust

For App on iOS and Android we use the services of Adjust. This allows us to us to track and analyze which marketing channels or sources are producing the best results for directing users to download the Products and to help us understand how our users are using our app. For this purpose, Adjust processes mobile identifiers such as the IDFA, GAID or similar mobile identifiers. For more information on Adjust, see here, especially section 3. To opt out of tracking by Adjust please go here. The basis for the processing of Data are our legitimate interests.

Champions Fitness Center Event Tracking

When you are using our Products, we will collect certain event information (e.g. opening a Champions Fitness Center app, starting a sport activity, visiting our Website) and send them to our servers (servers of our partners). This allows us to analyze and constantly improve the use of our Products.

Facebook Analytics

For App on iOS and Android we use Facebook Analytics (for more information see here). This allows us to us to track and analyze which marketing channels or sources, in connection with Facebook, are producing the best results for directing users to download the Products and to help us understand how our users are using our app. For this purpose, Facebook Analytics processes mobile identifiers such as the IDFA, GAID or similar mobile identifiers. For more information on Facebook Analytics, see here. The basis for the processing of Data are our legitimate interests.

5. Cookies and Similar Technologies.

Cookies

What Are Cookies. The Website uses 'cookies' – small text files that are placed on your computer, mobile device and/or stored by the browser. The basis for the processing of Data via cookies are our legitimate interests.

Cookie Policy. For more information on the cookies we use, which, if any, personal data they collect, and how to disable them, please see here.

Do Not Track Signals. The Products do not recognize or respond to browser-initiated Do Not Track signals. To learn more about Do Not Track signals, you can visit https://allaboutdnt.com

4. WHY WE PROCESS DATA (“PURPOSES”)

1. Operating the Products. Champions Fitness Center process your Data to be able to provide you with a seamless user experience when using the Products.

Providing Services. To operate the Products and provide the services, including to

Global credential to Champions Fitness Center. We know you don’t like to remember usernames and passwords, or having to register multiple times. To enable our users to log on to all platforms, portals, services, communities and app operated by or on behalf of Data Controllers (which includes the Champions Fitness Center App and services) (“Champions Fitness Center Platforms”) with one set of log-in credentials (“Champions Fitness Center Log-In”), we store your Champions Fitness Center Log-In in the global authentication platform. When you use your Champions Fitness Center Log-In to enter Champions Fitness Center Platform, we will use a token to verify your identity from Champions Fitness Center global authentication platform. This also further ensures our network and domain security. The basis for the processing of Data are our legitimate interests.

Connect with Friends. To make it easier for you to find and connect with others. We may use the information you have shared within the Products, including GPS data, to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your friends’ use of the Products, and information you and others provide, to suggest people you may know or may want to transact with through our Products.

Customer Support. To investigate, respond to your requests, and resolve complaints and service issues, e.g. to contact you about a question you submitted to our customer service team.

2. Business Needs. We process your Data to manage our business needs.

Performance. We process Data to monitor, analyse, and improve the use of our Products, as well as protect the security or integrity of the Products, and their performance and functionality. For example, we analyze user behaviour and perform research about the way you use our Products.

Research and Development. We process Data, including public feedback, to conduct research for the further development of our Products, in order to provide you and others with a better, more intuitive and personalized experience, and drive user growth and engagement in our Products.

Marketing General. We process Data to deliver (tailored) marketing materials about Champions Fitness Center products and online services to you.

Email/Push Message Marketing. With your consent, Champions Fitness Center will send you personalized marketing emails or push messages with information on fitness and health-related topics as well as products. Based on your consent, Champions Fitness Center and our partners shares personal data for personalization purposes and vice-versa.

We would like to inform you that we assess your user behavior when reading the emails with the help of so-called web beacons or tracking pixels. The information created by this is then linked to the information collected in in 3.2 Categories of Personal Data, your email address, and an individual ID. With this merged information, we can create a user profile to personalize our marketing emails / push messages. We collect data on when you “Click on” our emails, or which links you click, and combine this with your actions in the Product.

We store and use your Data for the purpose of email marketing or marketing on the Website by Champions Fitness Center. You can revoke your consent to the marketing emails and push messages at any time, by clicking the link at the end of the email or changing your device settings concerning push messages. We store the tracking information as long as you are subscribed to our marketing emails.

Targeted messages on 3rd-party advertising platform.

Champions Fitness Center use third-party advertising platforms, such as (but not limited to) Facebook, Google, YouTube, Instagram, Twitter, Snapchat, Pinterest to send you messages that are targeted at you, based on your behaviour and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. Champions Fitness Center use third-party solutions such as Google Audience and Facebook Audience (but not limited to) to help us do a better job at targeting our campaigns and messages for our consumers. Your Personal Data (see 3.2 Categories of Personal Data) is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (e.g the page you are browsing) to show you an advertisement from Champions Fitness Center. We also need to analyse necessary information to understand the impact of our campaigns. If you don’t accept that we use and share your personal data for this purpose, you will still see Champions Fitness Center advertisements on other platforms at random.

The basis for the processing of your personalized Data is based on your Marketing Consent. An opt-out is possible at any time in your privacy settings. It may take a few days after the opt-out until you are removed from all audiences.

3. Compliance and Enforcement.

Compliance. We process your Data to comply with our obligations and in compliance with all applicable laws and regulations.

Enforcement. We process your Data, if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our Terms & Conditions or this Privacy Policy and/or attempts to harm our members or visitors.

5. SHARING OF PERSONAL DATA

1. General.

We share Data with third parties

We attempt to notify you about legal demands for your Data when we think it is appropriate, unless prohibited by law or court order, or when the request is an emergency. We may dispute such demands when we believe that the requests are overbroad, vague or lack proper authority.

Special categories of personal data, such as heart rate data or other health data, will never be shared with advertisers or similar agencies.

2. Our Services.

Profile. Your profile is fully visible to your friends on Champions Fitness Center by default. This means, as soon as you add friends in the Products, those people will be able to see your profile, including when you join groups and events. In your privacy settings you can also set your profile visibility to “Only me” or “Everybody”. Please note that your first name, last name, and profile picture are visible to everybody at all times. This is necessary to enable others to send you a friend request.

News Feed. Our services allow viewing and sharing information, including through posts, likes, and comments. Certain actions, such as tracking an activity, starting a training plan, upgrading to Premium Membership or establishing a new friendship connection, will be automatically posted in the News Feed. By default setting, only you and your friends will be able to see such activities in their News Feed. You can modify the visibility anytime in your privacy settings.

Leaderboard. If you track an activity, you will automatically join a weekly/monthly Leaderboard of accumulated distance, duration, or number of steps/ exercise among your friends. This means, once you add friends, you will be part of the Leaderboard. You can opt out of this at any time in your privacy settings.

Heart Rate Monitor. Personal health information collected and stored by Champions Fitness Center, and subsequently shared by the user via Heart Rate Monitor, may not be protected under the American Health Insurance Portability and Accountability Act (HIPAA).

HealthKit. If a registered user explicitly consents, Champions Fitness Center may share said registered user’s data obtained through the HealthKit framework with a third party for medical research.

Artificial Intelligence. We collect and process your biometric data while using the App using artificial intelligence. The App provides the “Artificial Intelligence” function, which gives you the opportunity to see your fitness progress, including in real-time mode.

3. Services You May Use. Champions Fitness Center lets you connect to third-party services. For example, to enable you to connect other accounts to your Champions Fitness Center profile or for sharing your activities with friends.

Health and Fitness Services. Champions Fitness Center transfers your information to other health and fitness services, such as Apple HealthKit, Google Fit or MyFitnessPal, only after you explicitly consent to the transfer when you connect to such services.

Social Networks and Messenger Services. You can decide to share finished activities via Facebook, Twitter, WhatsApp, Telegram or any other messenger service you may use on your mobile device. Please note that we do not have any influence on or knowledge of the scope and the further use of the Data by the respective messaging service, and cannot take any responsibility for the use of your Data by the respective messaging provider. Please see the messaging service’s respective privacy policies for details.

4. Service Providers

Service Providers. We share your information to others who help us provide and improve our Products (e.g. maintenance, analysis, audit, payments, fraud detection, marketing and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf, and are obligated not to disclose or use it for other purposes. We use processors such as Adjust, Google, Facebook, Amazon Web Services, Inc., Emarsys eMarketing Systems AG, Pushwoosh, Inc., NewRelic, Inc., Apptimize, Inc. or Zendesk, Inc.

5. Champions Fitness Center

We share personal data (categories of personal data:

for the described purposes (see 4. Why We Process Data) with the following data controllers (categories of recipients):

6. HOW LONG WE STORE DATA

1. Retention Period. We need to maintain your data for as long as you have an account with us. If you are a user within the EU and you stop using our services without requesting to delete your data, we will keep it for 25 months after your last interaction with any Champions Fitness Center touchpoint. Beyond that, we only store Data, if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.

2. Account Deletion. If you decide to delete your account, all Data Champions Fitness Center has about you will be deleted, with the following exceptions:

A deletion request does not affect Data, if the storage is legally necessary, for example for accounting purposes.

7. WHICH RIGHTS YOU HAVE

1. Exercise your Rights. To exercise your rights defined in sections 7.2 to 7.8, please send a request via email to the Email Address or via mail to our postal address.

2. Revocation of Consent. You can revoke your consent – in those cases where consent for processing is necessary – for future data processing at any time. However, this does not affect the lawfulness of Data processing based on the consent before the revocation. In certain cases, we may continue to process your information after you have withdrawn consent, if we have another legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

3. Right of Access. You have the right to obtain (i) confirmation as to whether or not your Data is being processed by us and, if so, (ii) more specific information on the Data. The more specific information concerns, among other things, processing purposes, categories of Data, potential recipients, or the duration of storage.

4. Right to Rectification. You have the right to obtain the rectification of inaccurate Data concerning you from us. In case the Data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification. Please note that (i) you can rectify much of your information in the settings and (ii) it is not technically possible for us to rectify all kinds of data in our Product.

5. Right to Erasure. You have the right to delete Data we store about you. Should you decide to do so, please contact us via the Email Address. As a safety measure, we will send you an email in order for you to confirm this deletion. We will delete your Data after this confirmation. Please note that your phone may still have Data stored on it after deletion of your account.

6. Right to Restriction of Processing. You have the right to obtain a restriction of processing of your Data from us in the following cases:

7. Right to Data Portability. You have the right to (i) receive a copy of your Data in a structured, commonly used and machine-readable format and (ii) transmit those Data to another controller without hindrance from us. You can download a copy of your Data in your account settings on the Website.

8. Right to Object. You have the right to object at any time to the processing of Data for which our legitimate interests are the legal basis, including profiling based on those provisions. You also have the right to object to processing of Data for direct marketing purposes.

9. Right to File a Complaint. You have the right to file a complaint with your local supervisory authority, if you think that the processing of Data infringes applicable law.

8. FURTHER IMPORTANT INFORMATION

1. Legal Bases. Data protection laws regulate that we are only allowed to collect and process your Data, if we have lawful bases for processing. The lawfulness of Data processing stems from:

Our legitimate interests include protecting you, Champions Fitness Center, or others from security threats or fraud, complying with all applicable laws, managing and improving our business (e.g. customer service, reporting) including possible corporate transactions (e.g. M&A), enabling users to share their and connect via their fitness experiences, and express all fitness and health-related opinions.

2. Security Measures. We are committed to protecting your Data and implement appropriate technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage. Those security measures are constantly revised to comply with the latest technological developments.

3. What does Champions Fitness Center do when we transfer your Personal Data outside of the EU/EEA? Depending on the Personal Data processing activity, your Personal Data is shared with different “Categories of Recipients”. Where the recipient is located outside the EU/EEA, we have implemented necessary measures such as singing the EU Standard Contractual Clauses approved by the EU Commission or selecting vendors that certify and comply with the EU-US Privacy Shield Framework.

9. CHANGES TO THE PRIVACY POLICY

1. General. We review and update the Privacy Policy periodically to reflect any changes resulting from our day-to-day business operations. You can always check the date of the Privacy Notice to find out when we last made any changes. We will notify you when we make significant changes that you must be aware of.

2. Last Updated. This Privacy Policy was last modified on 07 October, 2019.

10. QUESTIONS, COMPLAINTS AND SUPPORT

Ask customer service: support@equityalgorithm.com

Personal Data Protection Supervisory Authority http://rkn.gov.ru/