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Privacy Policy

PERSONAL DATA

General

The company FITXCHANGE LTD controls the processing of personal data of each user of the website and the app. For the processing of such data the Company relies on (i) the execution of a binding legal agreement in order to provide user registration, activity monitoring and recognition services through the app and, where applicable, to fulfil purchases through the online store at www.fitxchange.app, to the extent that the relevant processing is necessary for those contractual services, (ii) the legitimate interests of the Company in improving its services, analysing participation trends where lawful, and detecting and preventing fraud, subject to the rights and interests of users and (iii) user’s explicit consent to the sending of informative/promotional messages and/or material and the analysis of their consumer behaviour (profile) exclusively on the basis of automated processing. FITXCHANGE LTD accordingly provides the following information about its processing of personal data. Where consent is required, it will be sought separately and may be withdrawn in accordance with applicable law. Processing of health-related data requires an applicable condition under Article 9 GDPR in addition to an Article 6 lawful basis:

DATA PROCESSING

The Company will process the personal data of users, provided during registration and, where applicable, online purchasing, together with activity data collected through the app, including dates, times, geographic location and heart rates through the app. Expressly, the app will have access to heart rate data, data on the type of training activity as well as data on the duration of such activity from Health Kit on the iOS platform of mobile phone devices, as well as from Google Health Connect on any android platform. Subject to the user’s choices and applicable lawful bases, such data may be used to record and monitor physical activity, calculate relevant activity statistics, measure participation, recognise achievements through activity badges and encourage sustained engagement in movement and wellbeing initiatives. Activity badges do not constitute a general condition of eligibility to purchase Company merchandise, except where expressly stated otherwise.  Furthermore, and provided that the user has given further express consent, the processing of personal data for the purpose of sending commercial informative and promotional material and/or for the preparation of the user’s purchase profile and possible improvement of the Company’s customer base and the operation of its online store www.fitxchange.app and its mobile fitness application platform.

Where the app is used in connection with workplace wellbeing initiatives, FITXCHANGE may process relevant activity and participation data to support engagement reporting and provide participating organisations with aggregated statistical information and insights into participation and activity trends. Reports must be designed to protect individual confidentiality, including where reporting groups are small. Any disclosure of identifiable user or health-related data to an employer requires a separate lawful basis, appropriate transparency and any additional safeguards required by law. The respective data protection roles of FITXCHANGE and participating organisations will be determined by their actual processing arrangements.

As a registered user of the app or online store, personal data will be retained in accordance with the retention criteria set out below. Users may request correction of inaccurate data through the available account functions or by contacting [email protected]; certain verified registration details may not be directly editable in the app.

In order to carry out any transaction through our online shop and to place orders for the Company’s merchandise and products, the following personal information shall be requested: (i) full name and surname, (ii) the delivery address of the merchandise and the postal code of the region, (iii) the billing address of the order (if different from the shipping address), (iv) the invoicing details, (v) the mobile and landline telephone number and (vi) the e-mail address of the customer.

In the event that a delivery of merchandise is requested to a third person other than the registered user, the latter acknowledges that they shall be fully responsible for the information and full consent of the person who is designated as the recipient, for the disclosure of that third party’s personal data to the Company for the sole purpose of delivery to such person of the relevant merchandise and assumes full responsibility for any claims of such person against the Company.

Credit card details are not stored by the Company during an online transaction but are directly registered in a secure environment of the third-party provider of the payment service.

Data processing in connection with online purchases shall be carried out for the purposes of (i) execution of the contract and the completion of the specific order, (ii) communication with the user-customer and the sending of informative messages concerning the stages of the processing of the order, (iii) the provision of clarifications related to the order and generally the information on purchases made, the delivery of the order to the place of choice of the user-customer, the confirmation and identification of the user-customer in any necessary case and the information on the existing stock. The registered user is informed that the provision of the above mandatory personal data as well as the transaction data is necessary and is a prerequisite for the proper execution of the order and delivery of products and services. For this reason, the consent of the user-customer is not required for this specific processing.

Each user-customer who uses the www.fitxchange.app online store is informed that their personal data concerning the receipt, execution and delivery of an order as well as queries regarding purchases, products and services of the Company and orders placed on www.fitxchange.app will be processed for the purpose of serving the user-customer, both by the authorised employees of FITXCHANGE LTD and by third-party recipients and/or processors on behalf of FITXCHANGE LTD in the context of the execution of an order. These third-party recipients may include transport companies, individual or group shipment companies, internet and e-commerce service providers, app infrastructure and analytics providers, and customer service call centres with whom FITXCHANGE LTD cooperates and who are subject to the specific strict conditions of personal data processing agreed with FITXCHANGE LTD as the controller of the data. FITXCHANGE LTD requires its employees, its website maintainers, app managers as well as its third-party partners to take all necessary technical and organizational measures, including appropriate policies and procedures to prevent the disclosure of personal data of registered users-customers and that they process and possess and implement procedures to manage and process personal data in a lawful manner and protect them in accordance with the local data protection legislation.

Any additional processing or disclosure of personal data will be undertaken only where there is an appropriate lawful basis and the applicable transparency and data protection requirements have been met. This may include lawful processing necessary to provide the app and its workplace wellbeing features, as described in this policy. Therefore, in order to send the registered user commercial information and promotional messages from FITXCHANGE LTD, www.fitxchange.app or the fitness app, respectively, the registered user must have previously given their express consent. The purpose of such consent is to send commercial promotional messages of the Company and/or third party partners to the registered user, to provide special offers and discounts of www.fitxchange.app , to offer new or alternative products, or to communicate forms or other documents related or connected to www.fitxchange.app or the fitness app itself. Users are given the possibility to withdraw consent at any time and not to receive such communication by sending an e-mail to the Company ([email protected]).

FITXCHANGE LTD also informs the registered user/customer that it may process personal data for the conducting of surveys to improve its services to registered users/customers. In the context of this processing the Company may take necessary steps to promote relevant products and services in order to improve the management of its customer base and to promote its products and merchandise. In order to enable registered users/customers to receive personalized offers and updates based on the purchases they have made in the Company’s online store, they must give their consent to the analysis of their consumer behaviour (profiling), based solely on automated processing, and in particular the following data generated by the user-customer’s transactions (i) products purchased on www.fitxchange.app, (ii) frequency of visits to www.fitxchange.app or the mobile application, (iii) demographic data showing registration on the app or (iv) order history on www.fitxchange.app or fitness history on the mobile fitness platform application.

The purpose of this specific processing is to optimize the shopping experience of registered users-customers, to reward them personally, to communicate products and services tailored to the needs of the Company’s customer base, receiving from registered users-customers personalised offers and updates that directly concern them, as well as inviting them to participate, with or without reward, in surveys for the development of our website, the fitness application, for the evaluation of market trends and for the evaluation of products and services on the basis of the purchases they have made.

The registered user-customer is informed that their personal data may be processed by the Company even without their consent in case of fulfilling its obligations under the law, such as when the relevant data are requested by tax and banking authorities in the context of audits or by the competent supervisory and judicial authorities.

Where processing is based on consent, users may withdraw that consent at any time by contacting [email protected] or using any available account controls, without affecting the lawfulness of processing before withdrawal. Subject to applicable conditions and exceptions, users may request access to, rectification or erasure of their personal data, restriction of processing and data portability, and may object to processing based on legitimate interests. Requests will normally be answered within one month, subject to lawful extensions. Certain data may be retained where a separate lawful basis requires or permits retention.

Personal data will be retained only for as long as necessary for the purposes for which it was collected, taking account of the nature of the data, the period for which the user maintains an account, applicable legal obligations and the establishment, exercise or defence of legal claims. Retention periods or criteria for account, activity, health-related, employer reporting and transaction data will be maintained and made available as appropriate. Where processing is based on consent, withdrawal will be acted upon unless another lawful basis applies. Nevertheless, some necessary personal data concerning order transactions as well as information, consent and withdrawal of the member’s consent to the processing of their data will remain as information for the registered user-customer to ensure the proof of the lawfulness of the processing of data by the Company and the safeguarding of any future legal claims.

Users may direct privacy enquiries and rights requests to [email protected] or to any separately designated data protection contact published by the Company. Users also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus or another competent supervisory authority.

FITXCHANGE LTD declares that no other use of the personal data of the registered user will be made for any other purpose other than that mentioned in this policy without prior notification and, where required, prior consent.