Privacy Policy

[Last Updated on: 02.09.2024]

The Sense4Fit app and the services provided herein (the “App”) are the property of Sense4Fit Development SRL (“Sense4Fit”). By using this app, you, as a “User”, acknowledge and agree to the contents of this document.

Sense4Fit is committed to protecting your rights and freedoms in order to process your personal data safely and in accordance with all legal obligations. We value your personal data and will maintain its integrity and confidentiality. This notice is meant to help you understand what personal data we collect, how we use it, with whom we share your personal data and what steps you need to take in order to ensure your personal data’s security when you interact with us through our website. To reflect any changes to the way we process your personal data or any changes to your legal requirements, periodic updates and changes to this Privacy Policy will be posted on this page. We abide by the highest standards and we value your personal data, therefore, our Policy is established in accordance with the rules imposed by the EU Regulation 2016/679 (GDPR).

This Privacy Policy (“the Policy” covers the information we collect about you when you use the App. This Policy also explains what choices you have regarding the information we process about you, including how you can object, access and update certain information about you.

To reflect any changes to the way we process your personal data or any changes to your legal requirements, periodic updates and changes to this Privacy Policy will be posted on this page.

Summary

We hope you will read this entire Privacy Policy carefully as we tell you what kind of data we collect and for what reason, but if you are in a hurry, here are some main ideas extracted from the Policy.

  1.  Who Are We?

Sense4fit Development SRL is a Romanian company headquartered in Voluntari, Sos. București Nord 15-25, Ilfov County, Romania, fiscal number 45711933, Commercial registration number: J23/4643/2022.

For data protection purposes, we are a data controller (the entity that determines the purposes and means of personal data processing) when we process your personal data as a data subject (identified or identifiable natural person to whom it relates the data).

Sense4Fit is an independent project which aims to become a leader in the field of fitness and wellness, especially by combining the fitness workouts/activities with the benefits provided by using the blockchain technology and the SFIT Token.

You can always contact us at dpo@sense4fit.com if you wish to learn more about our data processing activities.

  1.  What Information Do We Collect About You?

What Personal Data Do We Collect About You?
We may collect the following categories of Personal Data about you, which are described in more detail below:
(A) Personal Data you provide to us
(B) Personal Data we may automatically collect
(C) Personal Data we may receive from third parties

A. Personal Data You Provide Directly to Us:

User Data:
In using the App, you may provide us with the following Personal Data:

This information is essential to secure and provide you with access to our services.

Sensitive Information:
You may share with us information about medical conditions that could affect your goals.

Newsletter Subscription:
We collect your email address when you subscribe to our newsletter. Subscription is 100% voluntary, and you can unsubscribe at any time by contacting us at dpo@sense4fit.com or using the Unsubscribe button in the emails you receive.

Sorting Out Your Requests:
We use your contact information (e.g., email, name) and the content of your messages when you submit a request, so we can respond to your inquiries.

B. Data We May Automatically Collect About You:

The App may automatically collect certain information about you. We use this data to help us improve our services and better suit your needs. This data may include:

C. Personal Data We May Receive from Third Parties:

When creating an account, you can sign up and log in using third-party accounts such as Google or Apple. If you access our App through these accounts, we will collect the information you have agreed to share, which may include:

This information is collected by the third party and provided to us under their privacy policies. You can control the information we receive from these sources using the privacy controls available in your third-party account or by contacting us directly.

Connect devices and apps

We collect information from devices (fitness trackers) and apps (Apple Health, Garmin) you decide to connect to our app. When you link any fitness trackers or health apps the  information from these devices and apps will be passed along to Sense4Fit: connection is done automatically, by default, when you turn on this option. The entirety of the data collected by the fitness tracker and/or health apps is shared with us. These data include: BPM, steps taken, sleep analysis.

  1.  Purpose of Data Processing

The processing of personal data is based on at least one of the following legal bases:

• processing may be required for the conclusion of a legal relationship / contract and / or for its execution;

• the processing may be required in order to fulfil a legal obligation incumbent on us (eg those relating to the management of tax supporting documents, reporting to the relevant public authorities, obligations to keep evidence for certain periods of time, etc.);

• processing is necessary for the purpose of our legitimate interests;

• processing is based on your consent.

Purpose of data processing

We use your personal data as follows:

To provide our services

We collect your personal information in order to set up your account and access our services. We use your data to track users participation and progress in order to provide them with personalised feedback and suggestions, essential for fulfilling the purpose of the app. This processing is based on the execution of the contract between the user and our app.

To sort out your requests

We collect your data in order to provide you with information of interest to you as a beneficiary of our services. We will use the contact details provided by you, respectively the email address, exclusively with the purpose of processing your specific request.

We always make sure that processing is carried out in accordance with your rights and freedoms and that the decisions taken on the basis of them do not affect you.

To improve our services

In order to provide you with the best online browsing experience on our app, we may collect and use certain information about your activity on the app. We rely on our legitimate interest to carry out activities for you in optimal conditions, while taking care to respect your fundamental rights and freedoms. We collect behavioral data to understand how services are being used and how to improve them.

To defend our legitimate interests

In certain situations, we will use or transmit information to protect our rights and activities. Among these we list:

• Various measures to protect the website and its users against cyber attacks.

• Measures to prevent and detect fraudulent attempts, including the transmission of information to the competent public authorities.

• Various other risk management measures.

In some cases, we base our processing on legal provisions such as the obligation to ensure the safeguarding of goods and values under the applicable legislation in this regard, or various audit, due diligence or reporting obligations.

To protect our  legal interests

 Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we may use the personal data provided by you in connection with legal claims, compliance, regulatory, and audit functions.

5. For How Long Do We Keep Your Personal Data?

We retain the personal data we process only for as long as is necessary for the purpose for which it was collected or as required by laws:

All account data and fitness information is kept for as long as you decide to keep an account. Once you delete your account, we will no longer store your data. Inactive accounts will be deleted after 3 years.

All data sent to us when you make a request will be used strictly to provide you with an answer and to resolve your request, it will be kept for a period of 1 year from the date of receipt of the request.

By way of exception to the foregoing, we may retain any data, if any, until the expiry of the general limitation period of 3 years, in respect of situations in which we have a legitimate interest in retaining certain personal data in connection with a potential dispute that may arise between the parties (for example, in the context of the possible employment of our legal liability or that of the data subject).

In any other case or in the absence of specific legal, regulatory or contractual requirements, our reference period for the retention of personal data is 3 years from the date of termination of relations / the last contact between us and you.

In any case, except as provided by applicable law, we will delete your data at the time you request it. The applicable exceptional situations will be communicated to the applicant through the answer submitted by Sense4Fit in connection with the request to delete the data.

6.  How Do We Protect Your Personal Data?

Here at Sense4Fit we have implemented the appropriate technical and organizational measures needed to ensure an adequate level of security and confidentiality to your personal data.

The purpose of these measures is to protect your personal data against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing. The measures include but are not limited to:

a. people who have access to our filing system are only those nominated by Sense4Fit Development to access the system, they use individual accounts and passwords which are changed periodically.

b. all our employees, collaborators and service providers who are in contact with personal data must act in accordance with the principles and policies regarding the processing of personal data. They were informed and they have assumed respect of the GDPR by signing Data Protection notices, confidentiality agreements orData Processing Agreements or as an effect of the law.

c. our employees and collaborators access personal data for the performance of their professional duties and only in accordance with the stated purpose of data collection.

d. Call omputers from which the filing system is accessed are password-protected and have antivirus, anti spam and firewall security updates.

e. personal data is printed only by authorized users, if it is absolutely necessary to perform our activity or to fulfill our legal obligations.

7. Use By Minors

The App is not directed to minors under the age of 16 and we do not allow these individuals to provide any personal information through our website. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us at dpo@sense4fit.com.

8.  To Whom Do We Transfer Your Personal Data?

Where applicable, we may transmit or provide access to certain personal data of yours to various categories of suppliers, personnel, or other companies with which we may develop partnerships necessary for the conduct of our business, provided that there is a good reason. We use external providers for IT services, for customer relations and e-mail marketing.

Your personal data provided by contacting us (your email address) will not be transmitted to any third party without your consent.

We may also disclose certain personal data to public authorities, auditors, investors or other entities towards which we may have reporting obligations, if we have a legal obligation or if it is necessary to defend a legitimate interest.

We ensure that access to your data by third parties under private law is made in accordance with the legal provisions on data protection and confidentiality of information, based on contracts concluded with them. Therefore, all data is transmitted with appropriate safeguards, by encrypting the transmitted files.

9. In Which Countries Do We Transfer Your Personal data?

We currently store and process your personal data in Romania. However, we may transfer certain of your personal data to entities located outside Romania. Romania is a member of the European Union and is subject to the rules imposed by the General Data Protection Regulation and other applicable laws.

We take all measures to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests, and we allow such transfers only when absolutely necessary, applying the principle of minimization. Data transfers will always be protected by contractual commitments and, where appropriate, by other guarantees of a technical or organizational nature. To find out more about the countries where we transfer your data, you can contact us at any time.

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, according to industry standards.

Despite the measures taken to protect your personal data, we do not take responsibility for vulnerabilities in systems that are not under our control. We remind you that the transmission of information via the Internet is not completely secure, there is a risk that the data will be viewed and used by unauthorized third parties regardless of our intervention.

10. Links to Other Websites

Our app contains links to other websites such as Facebook, Google, Maiar. Once you click those links, you leave the realm of our app, which means our policies no longer apply, but instead, those websites’ policies apply. Our Privacy Policy does not apply to those companies' web sites, you should refer to each of those sites to obtain information on their privacy policies. If you cannot find the privacy policy on any of these sites once you have arrived at their site via a link from our site, you should contact that site directly for more information or you can e-mail at us dpo@sense4fit.com

We are not responsible for the contents of those sites and they will process your personal data in accordance with their privacy policy.

11. What Are Your Rights?

You have the following rights as a data subject:

Access

You can ask us to confirm whether we process your personal data, as well as to provide you with a copy of it and to present to you the data we have, what we use it for, to whom we disclose it, if we transfer it abroad, how we protect it, how long we keep it, what rights you have, how you can file a complaint, where we got your data from, to the extent that the information has not already been provided to you in this page.

Rectification

You may ask us to rectify or complete your inaccurate or incomplete personal data. It is possible to check the accuracy of the data before rectifying it.

Data deletion

You can ask us to delete your personal data, but only if:

• they are no longer necessary for the purposes for which they were collected;

• you have withdrawn your consent (if the data processing was based solely on your consent);

• they were processed illegally;

• exercise a legal right to oppose;

• we have a legal obligation in this regard.

We are not required to comply with your request to delete personal data in any circumstance. The most likely situations in which we could deny your request are:

• for compliance with a legal obligation;

• for establishment, exercising or the defense of a right in court.

Restricting data processing

You can request that we restrict the processing of personal data only if:

• their accuracy is challenge and we need to verify their accuracy;

• they are no longer needed for the purposes for which they were collected, but you need them to establish, exercise or defense of a right in court;

• processing is illegal, but you do not want the data to be deleted;

• you have exercised your right to object, and the verification of our rights prevails is ongoing.

We may continue to use your personal data following a request for restriction if we have your consent, or to ascertain, exercise or ensure the defense of a right in court or to protect the rights of Sense4Fit  or another natural or legal person.

Data portability

You can ask us to provide you with personal data in a structured, commonly used and automatically readable format, or you can request that it be ported directly to another data controller, provided that the processing is based on on your consent or on the conclusion or execution of a contract with you and to be done by automatic means, as well as to make the porting technically possible.

The opposition

You may object to the processing of your data at any time if you believe that your fundamental rights and freedoms prevail over our legitimate commercial interest.

Automated decisions

You may request that you not be subject to a decision based solely on automatic processing when that decision:

• produces legal effects on you;

• it affects you in a similar way and to a significant extent.

This right will not apply where the decision was reached by following automated decision-making:

• we are required to enter into or enter into a contract with you;

• is authorized by law and there are adequate guarantees for your rights and freedoms;

• is based on your explicit consent.

Complaints

You have the right to submit a complaint regarding the processing of your personal data and we assure you that we will make every effort to resolve any issues in a reasonable and peaceful way.

You may contact us by email at dpo@sense4fit.com. We promise to respond to any valid requests within a maximum of 30 days, unless this is particularly complicated or if you have made multiple requests,, in which case we will respond within a maximum of 60 days, prior to which you will be contacted about the delay.

Alternatively, you can also submit your request to exercise your rights by post, at the following address:

Sense4Fit Developments SRL

Voluntari, Sos. București Nord 15-25, Ilfov County, Romania,

Given the global reach of our App, we strongly recommend that you contact us by email at the address provided above. We cannot guarantee the arrival on time by post. If you, however, choose to submit a request through the mail, we recommend that you mail your request with confirmation of receipt.

12. Changes to this Policy

We reserve the right to make changes to this Policy on the protection of personal data at any time by notifying users on this page or - as far as technically and legally possible- sending a notification to users through any contact information available to us. It is strongly recommended that you check this page frequently, referring to the date of the last change listed under the title.

If the changes affect the processing activities performed based on the User’s consent, we will collect a new consent from the User, if necessary.

13. Contact

We are always open to finding out your thoughts and views and to provide you with any additional information you may need regarding the processing of your data. If you have any questions about the content of this document or wish to exercise your rights, please do not hesitate to contact us by email at our address: dpo@sense4fit.com