Below, we describe the privacy practices for our devices, applications, software, websites, APIs, products, and services (the “Services”). You will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.
INFORMATION WE COLLECT
When you use our Services, we collect the following types of information.
INFORMATION YOU PROVIDE US
Some information is required to create an account on our Services, such as your name, email address, password, age, exercise data, birth sex, height, weight, and in some cases your mobile telephone number. This is the only information you have to provide to create an account with us. You may also choose to provide other types of information, such as a profile photo and location for Bluetooth connection to your Suji device.
PAYMENT AND CARD INFORMATION
If you purchase Suji merchandise on our website, you provide your payment information, including your name, credit or debit card number, card expiration date, CVV code, and billing address. We do not store this payment information. We store your shipping address to fulfill your order. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms
INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES
Your device collects data to provide you with a better selection of exercises and overall user experience. Learn more about the features of our device and app. When your device syncs with our applications or software, data recorded on your device is transferred from your device to our servers.
The Services include features that use precise geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We do not collect this type of data but will use it for the Services if you grant us access to your location. You can always remove our access using your mobile device settings.
When you access or use our Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, when you start a programme, install applications or software, create or log into your account, or connect to or interact with your Suji device.
We also collect data about the devices and computers you use to access the Services, including operating system, Suji device information, mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.
INFORMATION WE RECEIVE FROM THIRD PARTIES
If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Fitbit or Strava, we may receive information like your name, profile picture, age range, language, email address, exercise activity, biometrics such as heart rate, and your friend list. You may also choose to grant us access to your exercise or activity data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.§
We may partner with third parties, such as employers and insurance companies that offer Suji Services to their employees and customers. In such cases, those companies may provide us with your name, email address, or similar information (like a telephone number or subscriber ID) so that we can invite you to participate or determine your eligibility for particular benefits, such as discounts or free services.
HOW WE USE INFORMATION
We use the information we collect for the following purposes.
PROVIDE AND MAINTAIN THE SERVICES
Using the information we collect, we are able to deliver the Services to you and honor our Terms of Service contract with you. For example, we need to use your information to improve your ability to track your exercise, activity, and other trends; to enable the community features of the Services; and to give you customer support.
For the Services’ community features, we may use your information to help you find and connect with other users and to allow other users to find and connect with you. For example, we may allow another user to connect with you if they have your email or mobile phone number in their contact list or in their friend network on a connected service.
IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES
We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.
When you allow us to collect precise location information, we use that information to provide and improve features of the Services such as recording where a session took place.
We also use your information to make inferences and show you more relevant content. Here are some examples:
- Information like your height, weight, gender, and age allows us to improve the accuracy of your suggested exercises.
- We may personalize exercise and activity goals for you based on the goals you previously set and your historical exercise or activity data.
COMMUNICATE WITH YOU
We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in.
PROMOTE SAFETY AND SECURITY
We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
HOW INFORMATION IS SHARED
We never sell the personal information of our users. We do not share your personal information except in the limited circumstances described below.
WHEN YOU AGREE OR DIRECT US TO SHARE
You may direct us to disclose your information to others, such as when you use our community features like forums and other social tools.
You may also direct us to share your information in other ways, for example, when you give a third-party application access to your account. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications in the profile section of the mobile application.
FOR EXTERNAL PROCESSING
We transfer information to our corporate affiliates, service providers, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.
FOR LEGAL REASONS TO PREVENT HARM
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.
Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.
We may share non-personal information that is aggregated or
de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us.
If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.
YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA
From the “Profile” section in the mobile application we give you tools to access and control your personal data, as described below, regardless of where you live. If you live in certain jurisdictions, you may have legal rights with respect to your information.
Accessing and Exporting Data. By logging into your account, you can access much of your personal information, including your training log with your daily exercise and activity statistics. Using your Profile settings, you can update much of your personal information.
Editing and Deleting Data. By contacting the Company you can request your account is deleted. Contact information is provided at the end of this document.
If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data recorded by your Suji device and other data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm.
We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. For instance, when you provide your contact list for finding friends on the Services, we delete the list after it is used for adding contacts as friends. We keep other information, like your exercise or activity data, until you contact us to delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Information and How Information Is Shared sections.
ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
OUR POLICIES FOR CHILDREN
Persons under the age of 18, or any higher minimum age in the jurisdiction where that person resides, are not permitted to create accounts unless their parent has consented in accordance with applicable law. If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at email@example.com.
We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact the Company. Contact information is provided below.
OUR INTERNATIONAL OPERATIONS AND DATA TRANSFERS
We operate internationally and transfer information to the United States and other countries for the purposes described in this policy.
We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent and EU Commission approved model contractual clauses, which require certain privacy and security protections.
Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a Suji account and click “I agree” to data transfers, irrespective of which country you live in. If you later wish to withdraw your consent, you can delete your Suji account as described in the Your Rights To Access and Control Your Personal Data section.
EUROPEAN PRIVACY DISCLOSURES
If you live in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please review these additional privacy disclosures under the European Union’s General Data Protection Regulation (“GDPR”).
YOUR DATA CONTROLLER
SecondPerspective Ltd (trading as Suji or Suji BFR), a Scottish company, is your data controller and provides the Services if you live in the EEA, UK, or Switzerland. For our contact information, please see the Contact Us section and contact us.
HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA
To the extent that information we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your device to your account or grant us access to your exercise or activity data from another service. You can login in to the Suji mobile application to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, or contacting us to delete your data or your account.
OUR LEGAL BASES FOR PROCESSING PERSONAL DATA
For personal data subject to the GDPR, we rely on several legal bases to process the data, including:
- When you have given your consent, which you may withdraw at any time by contacting us;
- When the processing is necessary to perform a contract with you, like the Terms of Service; and
- Our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described in the How We Use Information section.
HOW TO EXERCISE YOUR LEGAL RIGHTS
Please review the Your Rights To Access and Control Your Personal Data section for how your mobile app settings and by contacting the Company allow you to exercise your rights under the GDPR to access and control your personal data.
If you need further assistance regarding your rights, please contact us at firstname.lastname@example.org, and we will consider your request in accordance with applicable laws. You also have a right to lodge a complaint with your local data protection authority or with the ICO, our lead supervisory authority.
CHANGES TO THIS POLICY
We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services.
WHO WE ARE AND HOW TO CONTACT US
If you have questions about this policy, or need help exercising your privacy rights, please contact at email@example.com
You may also contact us at:
SecondPerspective Ltd. (Trading as Suji or Suji BFR)