Privacy Policy
Effective Date: 20-NOV-2023
This Privacy Policy explains how we collect, use, disclose, and protect your personal information in connection with your use of our Fitness Application called ‘Genodyne’ in accordance with: (i) the ADGM Data Protection Regulations 2021; and (ii) the applicable federal laws of the United Arab Emirates (together the Data Protection Legislation).
Your privacy is important to us, and we are committed to protecting your personal information.
It is important that you read and understand 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 and what your rights are under the Data Protection Legislation.
By using our Fitness Application, you consent to the practices described in this Privacy Policy.
A. Data Protection Principles
We will comply with Data Protection Legislation. This says that the personal information we hold about you must be:
a. Used lawfully, fairly and in a transparent way.
b. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
c. Relevant to the purposes we have told you about and limited only to those purposes.
d. Accurate and kept up to date.
e. Kept only as long as necessary for the purposes we have told you about.
f. Kept securely.
B. Information We Collect
Personal data, or personal information, means 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).
There are certain types of more sensitive personal data which require a higher level of protection, such as genetic and biometric data and information about a person’s health.
We will collect, store, and use the following categories of personal information about you:
- Account Information: Personal information – such as your name, gender, date of birth, weight, height and other information you choose to provide.
- Wellness Data: Workout history, heart rate, heart rate variability, sleep duration, blood oxygen saturation levels, Steps, calories, resting heart rate, in future stress information, details about physical activities and other wellness and/or health related information that you provide or that is generated during your use of the Fitness Application.
- Usage Information: We may collect information about how you use the Fitness Application, such as your activity, usage patterns, and the content you access.
- Band Information: We collect information about the band that you use to access the Fitness Application, including device model, firmware version, and unique device identifiers.
We collect the above personal information when you request for an account creation on the Fitness Application and when you install, access and/or use the Fitness Application on your smart phone device.
By installing, accessing and/or using the Fitness Application you hereby consent that we may collect, store and use the above categories of personal information about you.
C. How We Use Your Information
We may use your personal information for various purposes, including:
- Providing and Improving the Fitness Application: To deliver, maintain, and improve the Fitness Application, including personalizing your experience.
- Content Creation: We aim to deliver fresh content and product features, enhance and tailor our services (including analysing and reporting on trends, sleep patterns, exertion levels, and recovery), and establish thought leadership in the realm of human performance.
- Communication: To respond to your inquiries and provide customer support.
- Analytics: To analyse usage patterns and trends to enhance the Fitness Application’s functionality and performance.
- Legal Compliance: To comply with legal obligations, such as responding to legal requests and preventing fraudulent activity.
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.
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.
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.
D. Sharing Your Information
We may have to share your data with third parties, including third party service providers and other entities within our group. For example:
- Legal Obligations: We may disclose your information in response to legal requests, court orders, or government regulations. We may also need to share your personal information with a regulator or to otherwise comply with the law.
- Third Parties: Where it is necessary to allow us to carry out and perform the activities detailed in this Privacy Policy, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
- Business Transfers: In the event of a merger, acquisition, or sale of all or part of our assets, your information may be transferred to the acquiring entity.
“Third Parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.
E. Security
We take reasonable measures to protect your information from unauthorized access and disclosure. However, no data transmission or storage is completely secure, and we cannot guarantee absolute security.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. 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.
F. Data Retention
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, 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 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.
G. Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- 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 (see below).
- 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 transfer of your personal information to another party.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
H. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on our website or through the Fitness Application.