Last Updated: February 2023
Within this Privacy Notice we will cover the following topics:
About us and this notice
The information we collect and how we collect it
How we use the information we have collected
How information is shared
Storage and security
Notice in respect of children
Retention of your personal data
How to access or delete your data
ABOUT US AND THIS NOTICE
Company Name: sportreact d.o.o.
Company Registered Number: 74074278578
Company Registered Office Address: Zagreb (Grad Zagreb), Avenija Dubrovnik 15
Sportreact is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
Personal information means any information about an individual from which that person can be identified. When you use our Services, we collect the following types of personal information:
Information you provide to us:
Order and Personal Data Information
Some information is required to place an order for our products on our website, which includes your first and last name, email address, delivery address and contact telephone number (if relevant).
Once you download our app, you will need to create a sportreact App account, this does not link to your Website account. Therefore, we will ask you to provide some personal information, including your email address and name. Your sportreact device will link exclusively to your App account and no one else’s. This account will be password protected and you will use your email address to access your account. You can add other information to your account profile such as your location, gender, height, weight, date of birth, activities you participate in (e.g. football, running, fighting etc.), and similar. This information will be used for customising your workouts and to provide insights about your activities (durations, distances, etc.).
To help improve your experience or enable certain features, you may choose to provide us with further additional information. For example, you may connect with athletes/coaches on the Service or invite athletes/coaches who have not yet joined by providing their email addresses or using a contact list on your device. We do not store your contact list and delete it after it is used for adding contacts as friends.
If you contact us or participate in a survey, contest or promotion, we collect the information you submit such as your name, contact information and message.
If you purchase sportreact products on our website, you provide your payment information, including your name, credit, debit card, Apple Pay or PayPal account details and billing address. We do not store this information. We do store your shipping address to fulfil your order.
Information we receive from your use of our Services:
Sportreact Product Information
Sportreact devices collect raw data to estimate certain metrics regarding your training activity. These metrics may include: Activity duration, Number of signals, Average time, Fastest time, Slowest time, etc. The measurements recorded depend upon the workout mode you perform. Your device will transfer the raw data to your App Account via Bluetooth. You will be able to view your current workout metrics on your App. When your App Account syncs with our servers over internet connection, the measurement metrics are backed up to our servers. This back up enables you to track your progress and view your historic workouts. Our Services include certain features that use location data, including GPS, accelerometers, Wi-Fi, and Bluetooth.
We collect usage data when you use our Services. This includes information about your interaction with our Services, for example when you view content, install applications, create an account, pair your device or interact with your device via the application, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We also collect cookie information and IP address information about the device or computer you use to access our Services. This will only be used for analysis purposes.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
HOW WE USE THE INFORMATION
Sportreact uses the collected data for various purposes:
To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
For payment processing purposes
To comply with the law
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as fulfilling your order or providing our service).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW INFORMATION IS SHARED
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. The following third-party service providers process personal information about you for the following purposes: AWS (Amazon Web Services), Google Firebase and Wix.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
STORAGE AND SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
NOTICE IN RESPECT OF CHILDREN
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
RETENTION OF YOUR PERSONAL DATA
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
If you fail to access your sportreact account for a period of 12 months, we will securely destroy all your personal information we hold in accordance with applicable laws and regulations, at which point you will no longer be able to access your sports measurements and records.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Sportreact aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where sportreact relies on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page:https://policies.google.com/privacy?hl=en
Meta remarketing service is provided by Meta Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Meta, please visit Meta Data Policy: https://www.facebook.com/privacy/explanation
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Facebook Analytics tracks and reports your website traffic, collecting information regarding your users behaviour.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
HOW TO ACCESS OR DELETE YOUR DATA
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our customer service team by emailing firstname.lastname@example.org.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, for instance to provide you with marketing communication via email or SMS, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our customer service team by emailing email@example.com.