Privacy Policy

Last Updated and Effective: December 5, 2023

Welcome to iFIT's privacy notice.

iFIT respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the applicable data protection and privacy laws, including but not limited to the European Union General Data Protection Regulation (“GDPR”), the General Data Protection Regulation of the United Kingdom (“UK GDPR”)applicable U.S. state privacy laws, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and Lei Geral de Proteção de Dados (“LGPD”) (collectively, “Data Privacy Law”) protect you.

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below.

1. Important information and `who we are
2. The data we collect about you
3. How is your personal data collected?
4. Why and how we use your personal data
5. Disclosure and sharing of your personal data
6. International transfers
7. Data retention
8. Your legal rights
9. Risk of harm
10. Contact us
11. California privacy notice (Notice at Collection)

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how iFIT collects and processes your personal data through your use of our websites and apps, including all websites and apps that link to this privacy notice. This privacy notice also applies to the information we collect when you use our products and services or when you interact with our sales team or customer service specialists. We'll collectively refer to these as the “iFIT Products” below. Our website, apps and products and services are not meant for children. We do not knowingly collect data from children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

What is not covered by this notice?

This notice does not apply to the personal data of employees, business owners, directors, officers, and other staff of iFIT.

If we do not maintain information in a manner that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household, such information is not considered personal data and this Notice will not apply to our processing of that information. This includes aggregated data, as discussed further below.

Our role with respect to your personal data

Within the scope of this notice, iFIT is the controller or “business” for the personal data we process. This means that we decide how and why personal data is collected and further processed.

iFIT is made up of different legal entities, affiliates, partners, licensors, subsidiaries, or related companies. This notice is issued on behalf of iFIT, so when we mention iFIT, "we," "us," or "our" in this notice, we are referring to the relevant entity in the iFIT group responsible for processing your personal data.

Changes to the privacy notice and your duty to inform us of changes

• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
• We reserve the right to update and change this notice at any time. If we make a material change to our privacy practices, we will update this notice and update the last updated date accordingly. We encourage you to frequently check our notice for any changes to stay informed. Historic versions may be obtained by contacting us.

Third party links

The iFIT Products may include links to third party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Questions

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the contact information listed below.

2. The data we collect about you

Personal data, or personal information has the meaning given in the Data Privacy Law applicable to you, and includes any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect personal data directly from you and indirectly about you as described below. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped into categories as follows:

• Identity data includes first name, last name, username, or similar identifier, date of birth, and gender.
• Contact data includes billing address, mailing address, email address, and telephone numbers.
• Financial data includes bank account and payment card details.
• Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the iFIT Products.
• Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. It may also include information you share about your workouts or fitness goals, such as videos of a workout. We may use information that you share to create a profile of your aspirations, goals, and accomplishments to provide you with suggestions to help you reach the next level in your fitness challenge.
• Health/Sensitive data could be included in your profile. We may collect health data, including height and weight data, exercise data, including heartrate data, or other physical patterns or rhythms from your workouts or fitness goals. Under Data Privacy Law, this data may be classified as sensitive and be entitled to additional protections. 
• Usage data includes information about how you use the iFIT Products.
• Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Social Media Application data includes your public profile information, your social media connections, photos and "likes."
• Geolocation information may be recorded when you use certain features of the iFIT Products, which may be uploaded to your profile when synced with your account. We may collect precise geolocation information when you connect our Services to certain third-party apps, such as Strava, Garmin, Google or Apple.
• Professional or Employment-Related data includes information you provide on a job application or resume, including past employment or qualifications.

We also collect, use, and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data under Data Privacy Law, as this data does not directly or indirectly reveal your identity.

Where we need to collect personal data by law, or under the terms of a contract we have with you, if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, a membership agreement or warranty program). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

All data-sharing categories in this Privacy Notice exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

3. How is your personal data collected?

We may collect the categories of personal data described above either directly or indirectly, including the following categories of sources:

• Direct interactions. You may give us your identity, contact and financial data by filling in webforms or by corresponding with us by post, phone, e-mail, or otherwise. This includes personal data you provide when you:

  • Apply for our products or services
  • Create an account
  • Interact with a third party app by following a link on the iFIT Products
  • Subscribe to our service or publications
  • Request marketing to be sent to you
  • Enter a competition, promotion, or survey
  • Give us feedback
  • Apply for a job with us
• Automated technologies or interactions. As you interact with the iFIT Products, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
• Cookies. When you visit or use an iFIT Product, we may assign your device one or more cookies to facilitate access and to personalize your experience on that iFIT Product. A cookie is a small text file that we place on a user's browser or device. Through the use of a cookie, we may also automatically collect information about your online activity on an iFIT Product, such as the web pages you visit and the links you click. Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on iFIT websites or other Products.
• Other technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of iFIT Products. Web beacons are tiny graphics that are embedded in the webpage and are used for similar purposes as cookies to track activity. We may also include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to visitors of iFIT Products, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming, or other activities.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical data from the following parties:
    • Analytics providers such as Google based in or outside the US
    • Advertising networks based inside or outside the US
    • Search information providers based inside or outside the US
  • Contact, financial, and transaction data from providers of technical, payment, and delivery services based inside or outside the US
  • Identity and contact data from data brokers or aggregators based inside or outside the US
  • Identity and contact data from publicly available sources based inside or outside the US

4. Why and how we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following business purposes:

• When we need to perform a contract we are about to enter into or have entered into with you
• For the provision of our products and services or the operation of our business or a third party's business. All of our employees and contractors are required to follow our data privacy and security policies when handling personal data.
• For providing you with customized and personalized recommendations for other iFIT health or fitness opportunities that we think may be of interest to you.
• To analyze and understand our members use patterns, improve our services and optimize the features of our services.
• To evaluate your qualifications for a job position.
• Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
• When we need to comply with a legal or regulatory obligation.
• Where we need to protect your (or someone else's) interests.
• Where necessary in connection with the sale, merger, acquisition or other reorganization of our business.
• For marketing purposes.
• To process transactions.
• By creating an account with us, you agree that we may contact you for marketing purposes by phone, e-mail, mail, or text message, even if your number is on a do-not-call list or is a wireless number.

California residents, please review the California Privacy Notice below for additional disclosures about how we may use your personal data.

Other purposes for which we will use your personal data and the lawful bases for such processing

We have set out below a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Legitimate interest means that we conduct and manage our business to enable us to give you the best services and products and the most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required to or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Note that we may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below:

• Purpose/Activity: To register you as a new customer
  • Type of data: Identity and Contact
  • Lawful basis for processing: Performance of a contract with you
• Purpose/Activity: To process and deliver your order including (i) Manage payments, fees and charges and (ii) Collect and recover money owed to us
  • Type of data: Identity, Contact, Financial, Transaction, and Marketing and communications
  • Lawful basis for processing: Performance of a contract with you, and Necessary for our legitimate interests (to recover debts due to us)
• Purpose/Activity: To manage our relationship with you which will include (i) Notifying you about changes to our terms or privacy policy and (ii) Asking you to leave a review or take a survey
  • Type of data: Identity, Contact, Profile, and Marketing and communications
  • Lawful basis for processing: Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to recover debts due to us), and Consent (if the data is classified as sensitive data)
• Purpose/Activity: To enable you to partake in a prize drawing, competition, or to complete a survey
  • Type of data: Identity, Contact, Profile, Usage, and Marketing and communications
  • Lawful basis for processing: Performance of a contract with you, Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business), and Consent (if the data is classified as sensitive data or if otherwise required by law)
• Purpose/Activity: To administer and protect our business and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
  • Type of data: Identity, Contact, and Technical
  • Lawful basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise), and necessary to comply with a legal obligation
• Purpose/Activity: To deliver relevant Sites content and advertisements to you and to measure or understand the effectiveness of the advertising we serve to you
  • Type of data: Identity, Contact, Profile, Usage, Marketing and communications, and Technical
  • Lawful basis for processing: Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business, and to inform our marketing strategy), and Consent (if the data is classified as sensitive data or if otherwise required by law)
• Purpose/Activity: To use data analytics to improve our Sites, products and services, marketing, customer relationships, and experience
  • Type of data: Technical, and Usage
  • Lawful basis for processing: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Sites updated and relevant, to develop our business, and to inform our marketing strategy)
• Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you, including workout recommendations, and recommendations for other iFIT Products and services.
  • Type of data: Identity, Contact, Technical, Usage, and Profile
  • Lawful basis for processing: Necessary for our legitimate interests (to develop our products and services, and to grow our business), and Consent (if the data is classified as sensitive data or if otherwise required by law).

Generally, for those data subjects located in the European Economic Area (“EEA”), we do not rely on consent as a legal basis for processing your personal data, other than in relation to sensitive data, when we are using tracking technologies and sending third party direct marketing communications to you via e-mail or text message. You have the right to withdraw your consent at any time by contacting us using the contact information below or changing the settings on our cookie banner.

Health and Sensitive Information

As a user, as part of your profile, you may choose to enter health information into the Sites, like your height, weight or exercise data, or, in specific circumstances designed to protect the user, whether you are pregnant. If you choose to participate in a pregnancy-related survey or workout program, you may also provide sensitive information about your health and pregnancy.

Some of the Sites functionalities (e.g. free text fields) may allow a user to enter information the user wants to share with iFIT that could be of a sensitive nature. These free text fields may appear after completing workout reviews, submitting feedback on your experience of the Sites, or when completing customer surveys. Users may also choose to share potentially sensitive information when interacting with our support team.

iFIT may use or otherwise infer information about your health, including information about your medical conditions or requirements, as well as data on your physical characteristics from this information.

For users in jurisdictions that require it, iFIT requires explicit consent from users before they can add their health data (like height, weight and exercise data) into the Sites or otherwise submit sensitive information to iFIT. You may always withdraw your consent to the processing of your sensitive information.

You can withdraw your consent for the processing of health data you entered into the Sites at any time by contacting us using the contact information below. If you provided iFIT with consent to process any other sensitive information, or you're unsure about how to withdraw consent or about what information you did provide, please contact us using the contact information below. Withdrawing consent will not prohibit you from using the Sites, but please note some functionality across the Sites, like tracking weight loss progress, could be disabled or may not function properly.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can withdraw your consent for the processing of your personal data for marketing purposes at any time by changing the settings on our cookie banner.

Promotional offers from us

We may use your identity, contact, technical, usage, and profile data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (known in the industry as marketing).

You will receive marketing communications from us if you have requested information from us, have purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion, and, in each case, you have not opted out of receiving that marketing.

Opting out

We market our products in a variety of ways. If you opt-in to receive marketing communications from us, we may send you information about new products, services or discounted offerings. You can ask us or third parties to stop sending you these types of marketing messages at any time by logging into the iFIT Products and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us with a request at any time.

When you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience, or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the iFIT Products may become inaccessible or not function properly.

More information about your online activities and exercising choices across websites or services is available at www.aboutads.info or www.networkadvertising.org.

For more information about our use of cookies, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and, if required, explain our legal basis for and obtain your consent to the new use.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, when this is required or permitted by law.

5. Disclosure and sharing of your personal data

We may disclose or share your personal data to entities other than iFIT for a business purpose. We may disclose or share the categories of personal data listed in Section 2 with the following types of third parties or service providers:

Internal third parties

Other companies in the iFIT group act as joint controllers or processors, provide IT and system administration services, and undertake leadership reporting. When we share information internally, we require our affiliates and subsidiaries to process your personal data consistent with this notice.

External third parties

• Service providers acting as processors based inside or outside the US who provide IT and system administration services. We require all service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes, and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
  • Type of data: All categories of data listed in Section 2, only as necessary for the service being provided.
• Partners that offer health and fitness services only when you choose to link your account.
  • Type of data:Identity, profile, health/sensitive data, usage data, geolocation data.
• Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers based inside or outside the US who provide consultancy, banking, legal, insurance, and accounting services.
  • Type of data: Professional or employment-related data.
• Regulators and other authorities acting as processors or joint controllers based inside or outside the US who require reporting of processing activities in certain circumstances.
  • Type of data: All categories of data listed in Section 2.
• Any other entity when required by law. For example, in response to a court order or subpoena. We may also disclose information in response to requests from law enforcement agencies or other public agencies if we feel that such disclosure may prevent the instigation of a crime.
  • Type of data: All categories of data listed in Section 2.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.
  • Type of data: All categories of data listed in Section 2.
• Third parties that may provide us with analytics services or deliver advertising that is customized for you based on your interaction with our Sites and services.
  • Type of data: Technical data, usage data, marketing and communications data, social media application data.

6. International transfers

We share your personal data within the iFIT group. We store the information we collect—including your personal data—in the United States, so if you are accessing an iFIT site from another country, your information is being transferred to and from the United States and specifically outside of the European Economic Area (“EEA”) or Brazil.

We ensure that your personal data is protected by requiring all of iFIT's companies to follow the same rules when processing your personal data. Moreover, sensitive and private data exchanged between an iFIT site and you occurs over an SSL secured communication channel and is encrypted and protected with digital signatures.

We want you to feel confident using the iFIT Products. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal data, searches, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal data and should avoid sending personal data through insecure email. Please refer to the Federal Trade Commission's website www.consumer.ftc.gov for information about how to protect yourself against identity theft.

Note if you are located in the EU: Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it by using an approved data transfer mechanism, such as Standard Contractual Clauses (“SCCs”) approved by the European Commission, which give personal data the same protection it has in Europe.

Note if you are located in Brazil: Some of these third parties may be located outside of Brazil. In some cases, the Autoridade Nacional de Proteção de Dados (“ANPD”) may have determined that certain countries' data protection laws provide an equivalent level of protection to the LGPD. Where this is not the case, we will only transfer your personal data to third parties located in other countries when there are appropriate safeguards in place which the ANPD has confirmed as acceptable.

Please contact us if you want further information on the specific mechanism we use when transferring your personal data.

7. Data retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or 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 unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we must keep basic information about our customers (including contact, identity, financial, and transaction data) for seven years after they cease being customers, for tax purposes.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes—in which case, we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you may have rights under Data Privacy Law in relation to your personal data. In addition to the rights discussed in the opt-out section above, you may have the following rights.

• Request access to your personal data, commonly known as a data subject access request. This enables you to know the personal data we have collected from and about you.
• Request correction of your personal data. This enables you to correct or update any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data you provide us.
• Request erasure of your personal data. This enables you to ask us to delete your personal data. You also have the right to ask us to delete or remove your personal data when you have successfully exercised your right to object to processing (see below), when we may have processed your information unlawfully, or when we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which we will inform you, if applicable, at the time of your request.
• Object to processing of your personal data for certain purposes. You may object to the processing of your personal data when we are relying on a legitimate interest (or those of a third party) for the processing, and you believe that your rights and freedoms outweigh our legitimate interest. In some cases, we may demonstrate that we have compelling, legitimate grounds to process your information which override your rights and freedoms. You also have the right to request that we do not use your personal data for direct or targeted marketing.
• Request that we restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) when you believe that our use of the data is unlawful, but you do not want us to erase it; (c) when you need us to hold the data, even if we no longer require it, such as when you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. If we are processing sensitive personal data, such as your health data, you may ask that we limit our processing of that data in certain circumstances. Limiting this processing may compromise your access to the full capabilities of our services, such as goal tracking or heart rate monitoring.
• Request transfer of a copy of your personal data to you or to a third party. We will provide to you, or a third party that you have chosen, your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent at any time when we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Right to Non-Discrimination. You have the right not to be discriminated against for having exercised your privacy rights. We will not discriminate against you for exercising any of your privacy rights.
• Right to Opt-Out of the Sale or Sharing. We use tracking technologies, like cookies, beacons, Ad IDs, IP addresses and pixels for online advertising and analytics. We may disclose certain online identifiers with our advertising partners and analytics providers. Disclosing these identifiers with third parties for advertising or analytics purposes may be defined as the “sale” or “sharing” of your information under Data Privacy Law. You may have the right to opt-out of these uses. If you opt-out this type of “sale” or “sharing” of your information, we will not deliver customized advertising to you. You may still see non-targeted advertising about our products and services. You may opt-out of the sale or sharing of your information for marketing or analytics by clicking on the "Do Not Sell or Share My Personal Information” link and unselecting marketing and analytics cookies. We also recognize the Global Privacy Control (“GPC”) signal. As described on www.globalprivacycontrol.org, GPC is “a proposed specification designed to allow Internet users to notify businesses of their privacy preferences, such as whether or not they want their personal information to be sold or shared. It consists of a setting or extension in the user's browser or mobile device and acts as a mechanism that websites can use to indicate they support the specification.” You can download and enable the GPC via a participating browser or browser extension. Note that not all browsers support GPC. For more information, visit: https://globalprivacycontrol.org/#about.

If you wish to exercise any of the other rights set out above, you may submit a verifiable consumer request to us either by completing this form or calling us at 1.866.608.1798

We typically do not charge a fee to exercise these rights. However, we reserve the right to charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You may use an authorized agent to submit your consumer rights requests on your behalf if you provide the authorized agent written permission to do so. We will not act upon a request from an authorized agent if the agent does not submit proof (your written permission) that the agent has been authorized by you to act on your behalf. We will not act upon a request if we believe it is fraudulent.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

Appeals or Complaints

If we deny your request to exercise a particular consumer right, in certain circumstances, you may have the right to appeal that decision.

If you are in the EEA or UK, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your jurisdiction. For example, the supervisory authority for data protection issues in the UK is the Information Commissioner's Office (ICO) ico.org.uk.

If the LGPD applies to the processing of your personal data with us, the LGPD grants you the right to lodge a complaint with the ANPD if you are not satisfied with how we process your personal data.

We would, however, appreciate the chance to deal with your concerns before your supervisory authority, so please contact us in the first instance.

Advertising Disclaimer

iFIT shares no affiliation with any political party or its views. iFIT ads visible on political websites are there as a result of remarketing—not a partnership, affiliation, or endorsement.

Children's Information

Our services are not offered to children. We do not knowingly collect, use, sell or share the personal data of children that are less than 16 years of age.

9. Risk of harm

Whenever personal data is collected and processed, there is always a slight risk that the personal data may be breached, misused, or otherwise result in a harm to you. However, we take several measures to ensure that this risk is mitigated as much as possible. These measures include limiting the personal data about you that we collect and process to solely what is necessary, and implementing appropriate security measures, as described in this Notice.

10. Contact us

Full name of legal entity: iFIT Inc.
Data Protection Officer E-mail address: privacy@ifit.com
Postal address: 1500 S. 1000 W. Logan, Utah 84321 USA
Telephone number: 1.866.608.1798

iFIT has offices in France and the UK, where it can be contacted by EU and UK data subjects and data protection authorities for EU and UK data protection matters, respectively.

France
Full name of legal entity: iFIT Health & Fitness SAS
Email: privacy@ifit.com
Postal address: 5 Rue Alfred De Vigny 78112 Fourqueux France
Telephone number: +33 (0) 1 39 10 14 00

United Kingdom
Full name of legal entity: iFIT Health & Fitness Ltd.
Email: privacy@ifit.com
Postal address: 4 Westgate Court Silkwood Park Ossett WF5 9TT United Kingdom
Telephone number: +44 (0) 1924 847724

11. California privacy notice (Notice at Collection)

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the CCPA) requires that business disclose certain additional information about how it collects, uses, discloses, sells, or shares for cross-context behavioral advertising the personal data of a California resident. This California Privacy Notice (Notice at Collection) is part of iFIT's Notice.

This section only applies to California residents.

Personal Data We Collect About You

We may collect the following categories of personal data from or about you:

• Identity data includes first name, last name, username, or similar identifier, date of birth, and gender.
• Contact data includes billing address, mailing address, email address, and telephone numbers.
• Financial data includes bank account and payment card details.
• Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Sites.
• Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. It may also include information you share about your workouts or fitness goals, such as videos of a workout. We may use information that you share to create a profile of your aspirations, goals, and accomplishments to provide you with suggestions to help you reach the next level in your fitness challenge.
• Health/Sensitive data could be included in your profile. This data could include health data, including height and weight data, exercise data, including heartrate data, or other physical patterns or rhythms from your workouts or fitness goals. Under Data Privacy Law, this data may be classified as sensitive and be entitled to additional protections. 
• Usage data includes information about how you use our Sites, products, and services.
• Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Social Media Application data includes your public profile information, your social media connections, photos and "likes."
• Geolocation information may be recorded when you use certain features of our apps, which may be uploaded to your profile when synced with your account. We may collect precise geolocation information when you connect our Services to certain third-party apps, such as Strava, Garmin, Google or Apple.
• Professional or Employment-Related data includes information you provide on a job application or resume, including past employment or qualifications.

We also collect, use, and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data under Data Privacy Law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature, data entered when using iFIT Sites, pages most frequently accessed, browser type, links a user clicks, and other similar information. However, if we combine or connect aggregated data with your personal data, so it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.

How We Use Your Personal Data

We will only use your personal data in a manner that is consistent with Data Privacy Law. Most commonly, we will use the categories of personal data listed above for the following business purposes:

• When we need to perform a contract we are about to enter into or have entered into with you.
• For the provision of our products and services or the operation of our business or a third party's business. All of our employees and contractors are required to follow our data privacy and security policies when handling personal data.
• For providing you with customized and personalized recommendations for other iFIT health or fitness opportunities that we think may be of interest to you.
• To analyze and understand our members use patterns, improve our services and optimize the features of our services.
• To evaluate your qualifications for a job position.
• Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
• When we need to comply with a legal or regulatory obligation.
• Where we need to protect your (or someone else's) interests.
• Where necessary in connection with the sale, merger, acquisition or other reorganization of our business.
• For marketing purposes.
• To process transactions.

Sale or Sharing of Personal Data

As explained above, we use digital technologies, like cookies, beacons, Ad IDs, IP addresses and pixels for online advertising and analytics. We may disclose certain online identifiers with our advertising partners and analytics providers. Disclosing these identifiers with third parties for advertising or analytics purposes may be defined as the “sale” or “sharing” of your information under the CCPA. You have the right to opt-out of these uses. If you opt-out this type of “sale” or “sharing” of your information, we will not deliver customized advertising to you. You may still see non-targeted advertising about our products and services. You may opt-out of the sale or sharing of your information for marketing or analytics by clicking on the “Do Not Sell or Share My Personal Information” page which contains our Notice of the Right to Opt-Out and opt-out mechanism or call us at 1.866.608.1798

We also recognize the Global Privacy Control (“GPC”) signal. As described on www.globalprivacycontrol.org, GPC is “a proposed specification designed to allow Internet users to notify businesses of their privacy preferences, such as whether or not they want their personal information to be sold or shared. It consists of a setting or extension in the user's browser or mobile device and acts as a mechanism that websites can use to indicate they support the specification.” You can download and enable the GPC via a participating browser or browser extension. Note that not all browsers support GPC. For more information, visit: https://globalprivacycontrol.org/#about.

We may offer you certain financial incentives permitted by the CCPA, or different prices, rates, levels, or quality of goods or services that are reasonably related to your personal data's value to the business. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. For more information about the CCPA-permitted financial incentives that we offer, see our Notice of Financial Incentive.

Shine the Light

California Civil Code Section 1798.83 permits users of the iFIT Sites that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. We do not respond to Do Not Track signals.

Notice of right to opt-out

For California, Colorado, Virginia, Utah, Connecticut Residents

iFIT uses digital technologies, including online identifiers, to provide you with personalized marketing and perform online analytics. We may disclose these online identifiers to our analytics and marketing partners. You have the right to opt-out of having your personal data processed for the purposes of targeted advertising.

For California residents, the disclosure of your online identifiers to these partners may be considered the “sale” or “sharing” of your information. You have the right to opt-out of this use.

To opt-out of the disclosure of your online identifiers with our marketing or analytics providers, click on the “Do Not Sell or Share My Personal Information” link available here or on our homepage, and unselect the “marketing” and “analytics” cookies. You may also exercise your right to opt-out by calling us at 1.866.608.1798

Notice of financial incentive for California residents

This Notice of Financial Incentive is part of iFIT's Notice and includes an explanation of financial incentives we offer California residents. This Notice of Financial Incentive applies solely to California residents. We adopt this Notice of Financial Incentive in accordance with the CCPA.

From time-to-time, we offer coupons, discounted offerings, advance notices of sales and other special offerings and the opportunity to enter into contests and sweepstakes to consumers that have opted-in to the receipt of marketing material from us by providing us with certain personal data, such as their name, an email address, and a street address.

We may offer discounted pricing for certain products or services in the form of coupons or promo codes. We offer these incentives to encourage consumers to try our products and services or to learn more about our offerings. We offer other incentives based on a consumer's purchase history or demographic data, such as advance notice of sales. We value the personal data collected in connection with these incentives by determining the approximate additional spending per consumer, per year compared to individuals that do not participate in our incentives.

Participation in our financial incentive programs requires your prior opt-in consent. You can opt-in to participate in the financial incentives described by checking the box when you sign up for an account or otherwise indicating your consent when you request information from us.

You may revoke your consent and withdraw from a financial incentive program at any time by doing one of the following:

• Calling us at 1.866.608.1798
• Filling out the Notice of Financial Incentive found at this form