Privacy Policy
Last Updated: May 4, 2023
The Privacy Policy provided by Bowery Digital LLC including its subsidiaries and affiliates (collectively, “We,” “Our,” “Us” or “Stretch Club”) is based on Our respect for the privacy of You, as Our visitors or “Members” (as defined below). Our visitors and Members are collectively referred to as “Users,” “You” or “Your.” We are committed to the responsible handling and protection of Your personal information.
This Privacy Policy governs the manner in which We collect, use, maintain, and disclose information collected from Users of the Stretch Club App and all of Our Services (as defined below) and such Users’ online interactions through the Services. Additional information for individuals in the EEA, UK, and Switzerland, as well as for Users who reside in California, Colorado, Connecticut, Utah or Virginia, can be found in separate sections of this Privacy Policy.
This Privacy Policy does not apply to any third-party websites or social media platforms, which may provide information or offer products and services that Stretch Club makes available through the Services. To understand how any third party (including Apple and Google) treats your information, you should contact such third party or read its privacy policy and any other applicable terms.
By visiting Our website (currently located at )www.bowery-digital.com (“Website”), downloading and/or registering to use Our mobile app (“Stretch Club App”), providing “Personal Information” (defined below) to Us, or accessing or using Our “Content” (as defined in Our “Terms of Use”) or “Services” (defined below), You have agreed to be subject to this Privacy Policy, as well as Our Terms of Use.
The term “Services” collectively refers to Our Content and/or Services as provided through Our Stretch Club App, Website, Technology, Other Applications and any other Stretch Club App online platforms, such as Our Facebook or Instagram pages.
All capitalized terms not defined in this Privacy Policy are defined in the Terms of Use.
Please to read this entire Privacy Policy BEFORE using any of Our Services.
DO NOT USE ANY OF OUR SERVICES IF YOU ARE UNWILLING OR INELIGIBLE TO ACCEPT THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.
You may access or use Our Services ONLY IF You are 13 years of age or older or any higher minimum age under applicable laws in the jurisdiction in which you reside, and ONLY IN compliance with Our Terms of Use.
1. HOW YOU ARE SUBJECT TO THIS PRIVACY POLICY
By using Our Services, submitting information to Us, or purchasing any of Our other products or services, You consent to being governed by this Privacy Policy, and You consent to the collection, storage, use, and disclosure of such information in accordance with this Privacy Policy.
2. PERSONAL INFORMATION WE COLLECT
We consider “Personal Information” to be information that identifies an individual (like a name or email address) or that relates to an identifiable individual (like an IP address). Stretch Club collects, uses, and stores Your Personal Information when you sign up for Our email newsletters, register to become a Member, participate in interactive features of the Stretch Club App (like answering a survey We send out or giving Us feedback), request customer support, communicate with Us through Other Third-Party Resources, purchase or use other Stretch Club products or services, or otherwise communicate with Us.
Emails
When You create an account on the Stretch Club App, You provide Stretch Club with the following Personal Information: Your name, email address and password, however, Your password is encrypted so We never see or have access to it. By creating an account and opting in, We may also add You to Our email marketing list, but You will always be able to opt out. (See the “Email Marketing” section below.)
Stretch Club App Membership
When You download the Stretch Club App and become a “Free Member” (a member using the free version of the Stretch Club App) or “Paid Member” (a member using the paid version of the Stretch Club App), (Free Members and Paid Members collectively referred to as “Members”), You may be required to create an account in order to gain access to certain Services available through the Stretch Club App, all as further defined in Our Terms of Use.
We will collect from You, as a Member, certain Personal Information including:
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Email address
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First name
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Usage data
Usage Data
Usage Data or information generated through Your use of the Stretch Club App may include activities such as exercises You selected, information You selected through the Stretch Club App, or details of Your exercise activity at a particular time, on a particular day or over a period of time.
We carry out this processing for the purposes of providing recommendations for certain exercises based on Our inferences about Your preferences and practices. We do not use your Usage Data for identification purposes, but may use such data as anonymous or aggregated information (as described below).
Third-Party Sources
We may collect Personal Information from “Other Third-Party Sources,” such as social media networks, public information sources, and Our third-party partners that offer co-branded services or products through Stretch Club. More specifically, if You create or log into Your account through a social media service, We may have access to certain information from that account, such as Your name and other account information, in accordance with the authorization procedures set by that social media service. We may also obtain information about You from publicly available sources, marketing and advertising partners, consumer research platforms, and/or business contact databases.
3. PERSONAL INFORMATION COLLECTED WHEN YOU MAKE PURCHASES
Our Third Party Payment Processors
We do not collect or process credit or debit card data for Your purchase of any Stretch Club products or services. Apple and Google collect such data with respect to in-app purchases made through the Apple or Google app stores. In addition to Apple and Google, We use un-affiliated third parties to provide payment processing services that enable You to purchase products and services within Our Services, including paying for Your use of the Stretch Club App (Apple, Google and all such third parties individually and collectively referred to as “Payment Processor(s)”).
It is important that You review the terms of use and privacy policy of any Payment Processors prior to using their services.
Payment Processors will utilize Your financial information, such as Your bank account numbers or credit card numbers in order to process Your payments of such purchases. By utilizing Our Services, You agree that You are bound by the applicable Payment Processor’s terms and policies with respect to the protection, storage, or other utilization of Your financial information and any other information they collect from You.
We have no control over, and are not responsible for, any Payment Processor’s use of any of Your Personal Information collected through such payment processing service. Any such information that You provide to the applicable Payment Processor will be subject to that Payment Processor’s privacy policy, rather than Our Privacy Policy.
Our use of a particular Payment Processor is not an endorsement of that Payment Processor, and We make no warranties or representations as to how such processors utilize and safeguard Your financial information. We do not receive or store any of Your financial information as part of Your transactions with such Payment Processors.
You should review the privacy policies and terms of all Payment Processors You use.
4. HOW WE USE OR SHARE YOUR PERSONAL INFORMATION
We and Our “Third-Party Service Providers” (which means contractors and consultants We directly hire to help Us provide Services, but excludes all Payment Processors, Other Third-Party Sources, email marketing providers, and third-party hosting services companies,), upon Our instruction and authorization, may use Your Personal Information to:
● Provide the Stretch Club App and Our Services for Your use.
o Set up and administer Your account when You become a Member.
o Manage Your account and send administrative information to You, such as information regarding the Services, fees (if applicable), security alerts, technical notices, confirmations, and other support or administrative messages and possibly changes to Our terms, conditions and policies.
o Use Your information to facilitate payment processing related to Your use of the Services (see section on Third Party Payment Processors).
o Complete and fulfill Your purchases of Our products or services.
o Maintain Our Services to You, including providing You with customer service or support, such as responding to Your inquiries and fulfilling Your requests.
o Maintain log data utilizing Your information in order to track Your progress or activity during Your use of the Services.
● Analyze, improve or enhance Our Services to You.
o Store mobile data locally on Your device to provide You with access to the Services when utilizing the Stretch Club App without access to an internet connection.
o Personalize Your experience of the Services by presenting content, products and offers tailored to You.
o Use Your geolocation in order to provide You with recommendations for relevant Content and related services in Your geographical area.
o Use and/or store Your information from Third-Party Services or Devices (as defined below) that You connect to Our Service (e.g., heart rate monitor or a “Fitbit”).
● Send You informational or educational communications related to Your use of the Stretch Club products and services that you signed up for or purchased (including the Stretch Club App) that We believe may help or enhance the activities You undertake when using such Stretch Club products and services, including the Stretch Club App.
● Send You marketing communications about Stretch Club products and services that We believe may be of interest to You, subject to any choices You have expressed with respect to such communications.
● Request Your participation in any surveys and to administer such surveys. We may, if we decide to set up a survey, use the results of such surveys to understand user engagement, as well as for marketing purposes.
● Serve Stretch Club advertisements with third parties, such as Facebook, to the extent that You have consented to or have been provided with notice of, and an opportunity to opt-out of, such practices under applicable law.
● Aggregate generic, non-personally identifiable information from all Users of Our Services to: (1) understand how You use Our Content and Services; and (2) share this aggregate data or related statistics with third parties if We deem useful to promote Us or Our products and services.
● For Our business and operations purposes, such as internal data analysis, audits, monitoring and protection of security and integrity of the data and systems supporting or operating Our Services; prevention of unauthorized intrusions, developing new products and services, enhancing, improving or modifying Our Services, identifying usage trends, determining the effectiveness of Our promotional campaigns, and operating and expanding Our business activities including buying or selling any business or assets.
Our Third-Party Service Providers are not permitted to share or use Your Personal Information that We make available to them for any purpose other than to provide services to Us in order for Us to operate Our Services.
We reserve the right to use, retain or disclose any information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud; and if such action We believe is necessary or appropriate: (a) to conform to the requirements of applicable law which may include laws outside Your state or country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside Your state or country of residence; (c) to protect and defend the legal rights or property of Stretch Club, Our Users or other third parties; (d) enforce Our Terms of Use; or (e) in an emergency, to protect the health, safety or privacy of Our Users, other persons or the general public.
We also reserve the right to disclose any information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
5. WHEN YOU SHOULD NOT SHARE PERSONAL INFORMATION WITH US
Do not send Us, and do not disclose, any Personal Information or any other financial or other sensitive information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) in any email correspondence or through messaging services (e.g., online chats) with Us.
6. HIPAA DISCLAIMER
The Stretch Club App and Our Services (including any informational or educational communications as described above) are not a federal Health Insurance Portability and Accountability (“HIPAA”) compliant Service. As such, You are solely responsible for compliance with any state or federal law, which may govern the security or privacy of medical or other sensitive health-related data. Our Service is not designed to be a secure storage solution for Your private health data, and by using the Stretch Club App or Our Services, You acknowledge and agree that You will not utilize the Stretch Club App or Our Services for any such purposes. We disclaim any representation or warranty that We are HIPAA compliant.
In addition, You acknowledge and agree that You will not provide and We are not collecting information which would be deemed to be Protected Health Information (“PHI”) under HIPAA regulations. PHI is individually identifiable health information that must relate to: (1) the past, present, or future physical or mental health, or condition of an individual; (2) provision of health care to an individual; or (3) payment for the provision of health care to an individual. If the information identifies or provides a reasonable basis to believe it can be used to identify an individual, it is considered individually identifiable health information.
7. WHAT OTHER INFORMATION WE COLLECT AND USE
“Other Information” is any information (excluding Personal Information) that, in itself, does not reveal an individual’s specific identity and does not directly relate to an identifiable individual, such as:
● Browser and device information.
● Information collected through cookies, pixel tags and other technologies.
● Demographic and other statistical information.
● Personal Information that is de-identified, pseudonymized or aggregated.
We and Our Third-Party Service Providers (but excluding any Payment Processors, Other Third-Party Sources, email marketing providers, and third party hosting companies), upon Our instruction and authorization, may collect Other Information concerning You in a variety of ways, including through the use of cookies and similar technologies, to accomplish certain tasks, such as confirming that Our Services are functioning properly, storing and managing user preferences, delivering targeted advertising, enabling content, and tracking and gathering analytic and usage data.
As part of this process, we may from time to time include, compile, or aggregate some of your Personal Information in certain data analyses, reports, insights or observations, or other interpretations of financial or investment trends for both internal and external purposes. When including, compiling, or aggregating personal information for such purposes, we make sure that the information is anonymized such that it does not include any personally identifiable information. We may share such anonymized information in the form of research reports, blog posts or findings may be shared with external publishers or published by Us on fitness or nutrition-related topics of interest.
We maintain and use de-identified data without attempting to re-identify it, except if permitted by applicable law, such as to determine whether Our de-identification processes satisfy legal requirements.
Analytics Tools
We use third-party analytics tools, including “Google Analytics,” “Adjust” and “Amplitude” (such tools collectively referred to as “Analytics Tools”) to monitor and analyze the use of Our Services and collect such usage information. We use the information we get from these Analytics Tools to improve Our Services.
The Analytics Tools collect information about, for example, how often visitors go to Our Website, what pages they visit when they do so, and what other sites they used prior to coming to this Website, how Members use the Stretch Club App, and what Content they access when they do so. These Analytics Tools may also collect the IP address assigned to You on the date You visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the Website), but not Your name or other personally identifiable information.
The Analytics Tools’ ability to use and share information about Your use of Our Services is governed by the applicable third party’s terms of use and privacy policies and require such third parties to give You the choice to opt-out of such monitoring of Your online activities.
8. WHAT OTHER TECHNOLOGIES AFFECT YOUR PRIVACY AND USE OF OUR SERVICES
The following are ways that We may collect information from You about Your use of Our Services. Please note that Our Payment Processors, Other Third-Party Sources, email marketing providers, and third party hosting companies may use these methods as well, but their uses are governed by their own, respective privacy policies.
Cookies and Pixels
A cookie is a small data/text file that is stored on a computer, mobile phone or other device and is used to identify the user or device and to collect information and access the internet. Pixels are small code blocks on a website that allows for another server to measure viewing of a webpage and are often used in connection with cookies.
We may use cookies, pixels and similar technologies to customize and improve Your experience with Our Services, or to analyze trends, administer and track Users’ movements within Our Services, and gather demographic information about Our User base as a whole.
You can manage website cookies in Your browser settings, and You always have the choice to change these settings by accepting, rejecting, or deleting cookies. All browser settings are slightly different, so to manage cookies, You should refer to the relevant settings within Your browser.
If You choose to change Your settings, You may find that certain functions and features may not work as intended for Our Services, or the use of Our Services might be more cumbersome and less accessible.
Log Files
We may gather certain information automatically and store it in log files. This information includes the internet protocol (IP) address, browser type, internet service provider (ISP), and clickstream data. We do this to improve Our Services, marketing, analytics or site functionality, and to authenticate Users.
Do Not Track Signals
Some browsers or other tools include “do not track” features which, when turned on, send a signal to websites You visit indicating You do not wish to be tracked across websites over time. At this time, Stretch Club does not respond to these types of “do not track” signals.
Social Media Features
Our Services may include social media features such as the Facebook or Twitter “follow” button, widgets such as the “share” or “like” buttons, or interactive mini programs (collectively, “Social Media Features”). These Social Media Features may collect Your IP address, browser type, and may set a cookie to enable the Social Media Features to function properly. All such Social Media Features are hosted either by a third party or directly on or within Our Services. Please note that Your interactions with such Social Media Features are governed by the privacy policy of the company providing such Social Media Feature.
9. THIRD PARTY SERVICES, DEVICES AND LINKS
Our Services may contain links to and may be used by You in conjunction with third party websites, apps, services, devices and tools, and other information and advertising, none of which are affiliated with, or controlled, managed or endorsed by Us in any way (collectively, “Third Party Services/Devices”).
By linking any Third Party Services/Devices with Your account through Our Services, You represent and warrant that such Third Party Services/Devices account is Your own; that You are authorized to access and link such Third Party Services/Devices account; and You expressly authorize Us to utilize, implement, and, if applicable, share any information or data received from Your Third Party Services/Devices. You may unlink Third Party Services/Devices at any time, but may experience, as a result, a more limited interaction with Our Services.
Stretch Club is not responsible for the privacy practices, collection, use or disclosure of information, or the content of such websites or for the privacy and security policies and practices of all such third parties.
You will remain bound by the terms of use and privacy policy of Your Third Party Services/Devices; therefore, You should review the privacy policies applicable to all such Third Party Services/Devices.
10. HOSTING SERVICES PROVIDER AND DATA TRANSFERS
We may use and rely on third-party hosting services providers to host Our Services pursuant to such service providers’ standard business practices and their terms and conditions, all of which are non-negotiable and apply to all of their customers, including Stretch Club. These service providers have informed Us or the general public that they apply security measures they consider adequate for the protection of information within their systems, or they have a general reputation for applying such measures.
In addition, Our Services are hosted on these service providers’ servers which may be located outside the country in which You reside, including but not limited to the United States (“U.S.”). This means that the data protection and privacy regulations may in the U.S., or elsewhere, not offer the same level of protection as in the country in which You reside, or as in other parts of the world. Further, if You do not reside in the U.S., then Your Personal Information and Other Information may be transferred out of Your country of residence and to the U.S. or other parts of the world, and such information will be processed and stored in the U.S. or other parts of the world.
Further, the policies and practices described in this Privacy Policy do not apply to Our third-party hosting services providers, who have their own established data protection policies and procedures. We therefore make no warranty or claim regarding the privacy, confidentiality, integrity and security of any information and data stored or retained by such providers.
By using or accessing the Stretch Club App or Services in any way, You consent to the transfer, storage and processing of information that We collect from You as described in this Privacy Policy.
If You do not want your Personal Information to be transferred, stored or processed outside of the country in which You reside, You should not provide Us with Your Personal Information or access or use Our Services.
11. PROMOTIONAL AND NON-PROMOTIONAL EMAILS
We may use Your Personal Data to contact You (either through Stretch Club or third-party email marketing providers) with newsletters, marketing or promotional materials, or informational, educational or non-promotional information (as described above), 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 instructions provided in any email We send or by contacting Us as indicated below.
12. ADVERTISING
We may place advertising within the Stretch Club App, on Our Website or on Our Services, which contains links to the third-party websites of Our partners, advertisers, sponsors, or other third parties. We accept no responsibility for the practices of such third-party sites with respect to their privacy policies, and You should consult these third parties’ policies prior to use. Advertising delivered to or made available through Our Service may be provided by advertising partners, who may set cookies to deliver targeted advertising.
13. HOW USER DATA IS PROCESSED AND STORED
We may transfer Your Information and process it outside Your state or country of residence, wherever Stretch Club and its Third-Party Service Providers operate.
We retain the Personal Information You provide while Your account is in existence or as needed to provide You with Our Services or operate Our business. We may retain Your personal information even after You have closed Your account if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, comply with applicable laws, contractual obligations or industry standards, provide customer support, resolve disputes between Users, prevent fraud and abuse, or enforce this Privacy Policy and Our Terms of Use. When We no longer need Personal Information for all such operational, business and compliance purposes, We will delete or destroy it in accordance with Our security policies and procedures. In some circumstances, We may anonymize Your Personal Information (so that it can no longer be associated with You) in which case We may use this information indefinitely without further notice to You.
Please note that Our Payment Processors, Other Third-Party Sources, email marketing providers, and third-party hosting companies may have different data processing and retention policies and procedures, so please refer to the applicable privacy policies for such information.
14. HOW WE SECURE AND PROTECT YOUR PERSONAL INFORMATION
Stretch Club takes data security seriously, and We use appropriate technologies and procedures to protect Personal Information within Our company’s control and in accordance with industry standards. Our information security policies and procedures are closely aligned with industry standards and are reviewed regularly and updated as reasonably necessary. We use technical, administrative and physical safeguards to help protect against unauthorized access, destruction, loss, alteration, misuse or disclosure of Personal Information.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. While We believe our security procedures are commercially reasonable, We cannot ensure or warrant the security of any information that You transmit to Us, or that We transmit to You, or guarantee that it will be free from unauthorized access by third parties.
If You have reason to believe that Your interaction with Us is no longer secure, please immediately notify and contact Us in accordance with Section 20 (“How to Contact Us”) below.
15. YOUR OPT-OUT RIGHTS
As part of Your use of Our Services (when applicable), You are responsible for maintaining and updating Your Personal Information with current, accurate and complete information. You may view, update or edit the Personal Information You have provided to Us by logging in to Your account and following the appropriate instructions. You can also request that We help You make such changes to Your Personal Information by contacting Us in accordance with Section 20 (“How to Contact Us”) below.
You may opt-out from receiving marketing communications about Stretch Club products and services, or informational, educational or other non-promotional emails (as described above) related to Your use of the Stretch Club products and services that You signed up for or purchased, or other periodic emails from Us by contacting Us in accordance with Section 20 (“How to Contact Us”) below.
We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from Us, We may, if You are a Member, still send You important administrative or transactional messages, from which You cannot opt-out.
16. NO CHILDREN UNDER 13 SHOULD USE OUR SERVICES
Our Services are intended specifically for adults and children ages 13 and older or other age as required by applicable laws in the jurisdiction in which the User resides. Stretch Club does not knowingly collect Personal Information about children under 13 years old or other minimum age under applicable laws.
17. NOTICE TO PARENTS AND GUARDIANS
All parents and guardians are responsible for monitoring and supervising his/her/their child’s use of the Service. If You, as a parent or guardian, have a child using the Service without your express consent, and such child is under age 13 (if located within the U.S.), or is using the Service in violation of any other applicable laws, then please contact Us immediately so that We can disable Your child’s access.
If You wish to review Your child’s information (whether Your child is under or over 13 years old) collected through Stretch Club or other third parties identified in this Privacy Policy, or wish to have such collected information be modified or deleted, You may contact Us and We will work with You to address Your questions after We have verified You and Your request as described in Section 20 (“How to Contact Us”) below.
If We become aware that a child has provided Us with information in violation of applicable law, We will terminate the child’s account and delete all such information, unless We have a legal obligation to keep it.
18. FOR USERS RESIDING IN CA, CO, CT, UT, VA AND CERTAIN COUTRIES IN EUROPE
Below are certain state-specific or country-specific privacy laws that will apply when You use the Stretch Club Services. If any term in this Privacy Policy conflicts with the same term in such laws that apply to You, then the term in such applicable law will take precedence.
If You reside in California, please see the CALIFORNIA PRIVACY NOTICE section below for other rights under California law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Colorado, please see the COLORADO PRIVACY NOTICE section below for other rights under Colorado law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Connecticut, please see the CONNECTICUT PRIVACY NOTICE section below for other rights under Connecticut law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Utah, please see the UTAH PRIVACY NOTICE section below for other rights under Utah law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Virginia, please see the VIRGINIA PRIVACY NOTICE section below for other rights under Virginia law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in the European Economic Area, United Kingdom or Switzerland, please see the GDPR PRIVACY NOTICE section below for other rights under the GDPR (defined below) related to Our use of Your Personal Information when You use the Stretch Club Services.
19. CHANGES TO THIS PRIVACY POLICY
Stretch Club reserves the right to change this Privacy Policy in its sole discretion at any time. Any changes will become effective when We post the revised Privacy Policy within Our Services. Your use of the Services following any such changes means that You accepted the revised Privacy Policy.
20. HOW TO CONTACT US
We want to be clear about Our privacy practices so that You can make informed choice about the use of Your information. If You have any questions or complaints about Our privacy practices or this Privacy Policy, or wish to make a “data rights” request under the privacy law that applies to You, please contact Us.
As solely an online company, We communicate with You and all of Our customers via email, so please contact Us at hi@stretchclub.io.
Verifiable Consumer Request
Depending on the kind of request You send Us, We may, in Our sole discretion, determine that Your request must be verified. In such cases, We will require You to: (a) provide sufficient information that allows Us to reasonably verify You are: (i) the person about whom We collected Personal Information or an authorized representative, or (ii) the parent or guardian of the subject child (as described in Section 17); and (b) describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We will only respond to Your request or provide You with the requested Personal Information if We can (in Our sole discretion) verify Your identity or authority to make such request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Authorizing an Agent
To authorize an agent to make a request (as permitted in this Privacy Policy) on Your behalf, please provide Us with written authorization signed by You and Your authorized agent, and We will contact You with further steps required to verify Your and Your authorized agent’s identities.
No Sensitive Data
Because email communications and any other electronic form of communication are not always secure, please do not include any credit card or any other sensitive information (aka “sensitive data”) in Your emails to Us.
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CALIFORNIA PRIVACY NOTICE
YOUR PRIVACY RIGHTS UNDER THE CCPA IF YOU LIVE IN CALIFORNIA
If You are a California resident using the Services, You may exercise the following rights (regarding Your personal information) under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”).
1. INFORMATION WE MAY COLLECT FROM YOU
Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or User’s device, whether collected online or offline (“personal information”). In particular, the Services have collected the following categories of personal information from Users within the last twelve (12) months:
Last Updated: May 4, 2023
The Privacy Policy provided by Bowery Digital LLC including its subsidiaries and affiliates (collectively, “We,” “Our,” “Us” or “Stretch Club”) is based on Our respect for the privacy of You, as Our visitors or “Members” (as defined below). Our visitors and Members are collectively referred to as “Users,” “You” or “Your.” We are committed to the responsible handling and protection of Your personal information.
This Privacy Policy governs the manner in which We collect, use, maintain, and disclose information collected from Users of the Stretch Club App and all of Our Services (as defined below) and such Users’ online interactions through the Services. Additional information for individuals in the EEA, UK, and Switzerland, as well as for Users who reside in California, Colorado, Connecticut, Utah or Virginia, can be found in separate sections of this Privacy Policy.
This Privacy Policy does not apply to any third-party websites or social media platforms, which may provide information or offer products and services that Stretch Club makes available through the Services. To understand how any third party (including Apple and Google) treats your information, you should contact such third party or read its privacy policy and any other applicable terms.
By visiting Our website (currently located at )www.bowery-digital.com (“Website”), downloading and/or registering to use Our mobile app (“Stretch Club App”), providing “Personal Information” (defined below) to Us, or accessing or using Our “Content” (as defined in Our “Terms of Use”) or “Services” (defined below), You have agreed to be subject to this Privacy Policy, as well as Our Terms of Use.
The term “Services” collectively refers to Our Content and/or Services as provided through Our Stretch Club App, Website, Technology, Other Applications and any other Stretch Club App online platforms, such as Our Facebook or Instagram pages.
All capitalized terms not defined in this Privacy Policy are defined in the Terms of Use.
Please to read this entire Privacy Policy BEFORE using any of Our Services.
DO NOT USE ANY OF OUR SERVICES IF YOU ARE UNWILLING OR INELIGIBLE TO ACCEPT THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.
You may access or use Our Services ONLY IF You are 13 years of age or older or any higher minimum age under applicable laws in the jurisdiction in which you reside, and ONLY IN compliance with Our Terms of Use.
1. HOW YOU ARE SUBJECT TO THIS PRIVACY POLICY
By using Our Services, submitting information to Us, or purchasing any of Our other products or services, You consent to being governed by this Privacy Policy, and You consent to the collection, storage, use, and disclosure of such information in accordance with this Privacy Policy.
2. PERSONAL INFORMATION WE COLLECT
We consider “Personal Information” to be information that identifies an individual (like a name or email address) or that relates to an identifiable individual (like an IP address). Stretch Club collects, uses, and stores Your Personal Information when you sign up for Our email newsletters, register to become a Member, participate in interactive features of the Stretch Club App (like answering a survey We send out or giving Us feedback), request customer support, communicate with Us through Other Third-Party Resources, purchase or use other Stretch Club products or services, or otherwise communicate with Us.
Emails
When You create an account on the Stretch Club App, You provide Stretch Club with the following Personal Information: Your name, email address and password, however, Your password is encrypted so We never see or have access to it. By creating an account and opting in, We may also add You to Our email marketing list, but You will always be able to opt out. (See the “Email Marketing” section below.)
Stretch Club App Membership
When You download the Stretch Club App and become a “Free Member” (a member using the free version of the Stretch Club App) or “Paid Member” (a member using the paid version of the Stretch Club App), (Free Members and Paid Members collectively referred to as “Members”), You may be required to create an account in order to gain access to certain Services available through the Stretch Club App, all as further defined in Our Terms of Use.
We will collect from You, as a Member, certain Personal Information including:
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Email address
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First name
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Usage data
Usage Data
Usage Data or information generated through Your use of the Stretch Club App may include activities such as exercises You selected, information You selected through the Stretch Club App, or details of Your exercise activity at a particular time, on a particular day or over a period of time.
We carry out this processing for the purposes of providing recommendations for certain exercises based on Our inferences about Your preferences and practices. We do not use your Usage Data for identification purposes, but may use such data as anonymous or aggregated information (as described below).
Third-Party Sources
We may collect Personal Information from “Other Third-Party Sources,” such as social media networks, public information sources, and Our third-party partners that offer co-branded services or products through Stretch Club. More specifically, if You create or log into Your account through a social media service, We may have access to certain information from that account, such as Your name and other account information, in accordance with the authorization procedures set by that social media service. We may also obtain information about You from publicly available sources, marketing and advertising partners, consumer research platforms, and/or business contact databases.
3. PERSONAL INFORMATION COLLECTED WHEN YOU MAKE PURCHASES
Our Third Party Payment Processors
We do not collect or process credit or debit card data for Your purchase of any Stretch Club products or services. Apple and Google collect such data with respect to in-app purchases made through the Apple or Google app stores. In addition to Apple and Google, We use un-affiliated third parties to provide payment processing services that enable You to purchase products and services within Our Services, including paying for Your use of the Stretch Club App (Apple, Google and all such third parties individually and collectively referred to as “Payment Processor(s)”).
It is important that You review the terms of use and privacy policy of any Payment Processors prior to using their services.
Payment Processors will utilize Your financial information, such as Your bank account numbers or credit card numbers in order to process Your payments of such purchases. By utilizing Our Services, You agree that You are bound by the applicable Payment Processor’s terms and policies with respect to the protection, storage, or other utilization of Your financial information and any other information they collect from You.
We have no control over, and are not responsible for, any Payment Processor’s use of any of Your Personal Information collected through such payment processing service. Any such information that You provide to the applicable Payment Processor will be subject to that Payment Processor’s privacy policy, rather than Our Privacy Policy.
Our use of a particular Payment Processor is not an endorsement of that Payment Processor, and We make no warranties or representations as to how such processors utilize and safeguard Your financial information. We do not receive or store any of Your financial information as part of Your transactions with such Payment Processors.
You should review the privacy policies and terms of all Payment Processors You use.
4. HOW WE USE OR SHARE YOUR PERSONAL INFORMATION
We and Our “Third-Party Service Providers” (which means contractors and consultants We directly hire to help Us provide Services, but excludes all Payment Processors, Other Third-Party Sources, email marketing providers, and third-party hosting services companies,), upon Our instruction and authorization, may use Your Personal Information to:
● Provide the Stretch Club App and Our Services for Your use.
o Set up and administer Your account when You become a Member.
o Manage Your account and send administrative information to You, such as information regarding the Services, fees (if applicable), security alerts, technical notices, confirmations, and other support or administrative messages and possibly changes to Our terms, conditions and policies.
o Use Your information to facilitate payment processing related to Your use of the Services (see section on Third Party Payment Processors).
o Complete and fulfill Your purchases of Our products or services.
o Maintain Our Services to You, including providing You with customer service or support, such as responding to Your inquiries and fulfilling Your requests.
o Maintain log data utilizing Your information in order to track Your progress or activity during Your use of the Services.
● Analyze, improve or enhance Our Services to You.
o Store mobile data locally on Your device to provide You with access to the Services when utilizing the Stretch Club App without access to an internet connection.
o Personalize Your experience of the Services by presenting content, products and offers tailored to You.
o Use Your geolocation in order to provide You with recommendations for relevant Content and related services in Your geographical area.
o Use and/or store Your information from Third-Party Services or Devices (as defined below) that You connect to Our Service (e.g., heart rate monitor or a “Fitbit”).
● Send You informational or educational communications related to Your use of the Stretch Club products and services that you signed up for or purchased (including the Stretch Club App) that We believe may help or enhance the activities You undertake when using such Stretch Club products and services, including the Stretch Club App.
● Send You marketing communications about Stretch Club products and services that We believe may be of interest to You, subject to any choices You have expressed with respect to such communications.
● Request Your participation in any surveys and to administer such surveys. We may, if we decide to set up a survey, use the results of such surveys to understand user engagement, as well as for marketing purposes.
● Serve Stretch Club advertisements with third parties, such as Facebook, to the extent that You have consented to or have been provided with notice of, and an opportunity to opt-out of, such practices under applicable law.
● Aggregate generic, non-personally identifiable information from all Users of Our Services to: (1) understand how You use Our Content and Services; and (2) share this aggregate data or related statistics with third parties if We deem useful to promote Us or Our products and services.
● For Our business and operations purposes, such as internal data analysis, audits, monitoring and protection of security and integrity of the data and systems supporting or operating Our Services; prevention of unauthorized intrusions, developing new products and services, enhancing, improving or modifying Our Services, identifying usage trends, determining the effectiveness of Our promotional campaigns, and operating and expanding Our business activities including buying or selling any business or assets.
Our Third-Party Service Providers are not permitted to share or use Your Personal Information that We make available to them for any purpose other than to provide services to Us in order for Us to operate Our Services.
We reserve the right to use, retain or disclose any information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud; and if such action We believe is necessary or appropriate: (a) to conform to the requirements of applicable law which may include laws outside Your state or country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside Your state or country of residence; (c) to protect and defend the legal rights or property of Stretch Club, Our Users or other third parties; (d) enforce Our Terms of Use; or (e) in an emergency, to protect the health, safety or privacy of Our Users, other persons or the general public.
We also reserve the right to disclose any information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
5. WHEN YOU SHOULD NOT SHARE PERSONAL INFORMATION WITH US
Do not send Us, and do not disclose, any Personal Information or any other financial or other sensitive information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) in any email correspondence or through messaging services (e.g., online chats) with Us.
6. HIPAA DISCLAIMER
The Stretch Club App and Our Services (including any informational or educational communications as described above) are not a federal Health Insurance Portability and Accountability (“HIPAA”) compliant Service. As such, You are solely responsible for compliance with any state or federal law, which may govern the security or privacy of medical or other sensitive health-related data. Our Service is not designed to be a secure storage solution for Your private health data, and by using the Stretch Club App or Our Services, You acknowledge and agree that You will not utilize the Stretch Club App or Our Services for any such purposes. We disclaim any representation or warranty that We are HIPAA compliant.
In addition, You acknowledge and agree that You will not provide and We are not collecting information which would be deemed to be Protected Health Information (“PHI”) under HIPAA regulations. PHI is individually identifiable health information that must relate to: (1) the past, present, or future physical or mental health, or condition of an individual; (2) provision of health care to an individual; or (3) payment for the provision of health care to an individual. If the information identifies or provides a reasonable basis to believe it can be used to identify an individual, it is considered individually identifiable health information.
7. WHAT OTHER INFORMATION WE COLLECT AND USE
“Other Information” is any information (excluding Personal Information) that, in itself, does not reveal an individual’s specific identity and does not directly relate to an identifiable individual, such as:
● Browser and device information.
● Information collected through cookies, pixel tags and other technologies.
● Demographic and other statistical information.
● Personal Information that is de-identified, pseudonymized or aggregated.
We and Our Third-Party Service Providers (but excluding any Payment Processors, Other Third-Party Sources, email marketing providers, and third party hosting companies), upon Our instruction and authorization, may collect Other Information concerning You in a variety of ways, including through the use of cookies and similar technologies, to accomplish certain tasks, such as confirming that Our Services are functioning properly, storing and managing user preferences, delivering targeted advertising, enabling content, and tracking and gathering analytic and usage data.
As part of this process, we may from time to time include, compile, or aggregate some of your Personal Information in certain data analyses, reports, insights or observations, or other interpretations of financial or investment trends for both internal and external purposes. When including, compiling, or aggregating personal information for such purposes, we make sure that the information is anonymized such that it does not include any personally identifiable information. We may share such anonymized information in the form of research reports, blog posts or findings may be shared with external publishers or published by Us on fitness or nutrition-related topics of interest.
We maintain and use de-identified data without attempting to re-identify it, except if permitted by applicable law, such as to determine whether Our de-identification processes satisfy legal requirements.
Analytics Tools
We use third-party analytics tools, including “Google Analytics,” “Adjust” and “Amplitude” (such tools collectively referred to as “Analytics Tools”) to monitor and analyze the use of Our Services and collect such usage information. We use the information we get from these Analytics Tools to improve Our Services.
The Analytics Tools collect information about, for example, how often visitors go to Our Website, what pages they visit when they do so, and what other sites they used prior to coming to this Website, how Members use the Stretch Club App, and what Content they access when they do so. These Analytics Tools may also collect the IP address assigned to You on the date You visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the Website), but not Your name or other personally identifiable information.
The Analytics Tools’ ability to use and share information about Your use of Our Services is governed by the applicable third party’s terms of use and privacy policies and require such third parties to give You the choice to opt-out of such monitoring of Your online activities.
8. WHAT OTHER TECHNOLOGIES AFFECT YOUR PRIVACY AND USE OF OUR SERVICES
The following are ways that We may collect information from You about Your use of Our Services. Please note that Our Payment Processors, Other Third-Party Sources, email marketing providers, and third party hosting companies may use these methods as well, but their uses are governed by their own, respective privacy policies.
Cookies and Pixels
A cookie is a small data/text file that is stored on a computer, mobile phone or other device and is used to identify the user or device and to collect information and access the internet. Pixels are small code blocks on a website that allows for another server to measure viewing of a webpage and are often used in connection with cookies.
We may use cookies, pixels and similar technologies to customize and improve Your experience with Our Services, or to analyze trends, administer and track Users’ movements within Our Services, and gather demographic information about Our User base as a whole.
You can manage website cookies in Your browser settings, and You always have the choice to change these settings by accepting, rejecting, or deleting cookies. All browser settings are slightly different, so to manage cookies, You should refer to the relevant settings within Your browser.
If You choose to change Your settings, You may find that certain functions and features may not work as intended for Our Services, or the use of Our Services might be more cumbersome and less accessible.
Log Files
We may gather certain information automatically and store it in log files. This information includes the internet protocol (IP) address, browser type, internet service provider (ISP), and clickstream data. We do this to improve Our Services, marketing, analytics or site functionality, and to authenticate Users.
Do Not Track Signals
Some browsers or other tools include “do not track” features which, when turned on, send a signal to websites You visit indicating You do not wish to be tracked across websites over time. At this time, Stretch Club does not respond to these types of “do not track” signals.
Social Media Features
Our Services may include social media features such as the Facebook or Twitter “follow” button, widgets such as the “share” or “like” buttons, or interactive mini programs (collectively, “Social Media Features”). These Social Media Features may collect Your IP address, browser type, and may set a cookie to enable the Social Media Features to function properly. All such Social Media Features are hosted either by a third party or directly on or within Our Services. Please note that Your interactions with such Social Media Features are governed by the privacy policy of the company providing such Social Media Feature.
9. THIRD PARTY SERVICES, DEVICES AND LINKS
Our Services may contain links to and may be used by You in conjunction with third party websites, apps, services, devices and tools, and other information and advertising, none of which are affiliated with, or controlled, managed or endorsed by Us in any way (collectively, “Third Party Services/Devices”).
By linking any Third Party Services/Devices with Your account through Our Services, You represent and warrant that such Third Party Services/Devices account is Your own; that You are authorized to access and link such Third Party Services/Devices account; and You expressly authorize Us to utilize, implement, and, if applicable, share any information or data received from Your Third Party Services/Devices. You may unlink Third Party Services/Devices at any time, but may experience, as a result, a more limited interaction with Our Services.
Stretch Club is not responsible for the privacy practices, collection, use or disclosure of information, or the content of such websites or for the privacy and security policies and practices of all such third parties.
You will remain bound by the terms of use and privacy policy of Your Third Party Services/Devices; therefore, You should review the privacy policies applicable to all such Third Party Services/Devices.
10. HOSTING SERVICES PROVIDER AND DATA TRANSFERS
We may use and rely on third-party hosting services providers to host Our Services pursuant to such service providers’ standard business practices and their terms and conditions, all of which are non-negotiable and apply to all of their customers, including Stretch Club. These service providers have informed Us or the general public that they apply security measures they consider adequate for the protection of information within their systems, or they have a general reputation for applying such measures.
In addition, Our Services are hosted on these service providers’ servers which may be located outside the country in which You reside, including but not limited to the United States (“U.S.”). This means that the data protection and privacy regulations may in the U.S., or elsewhere, not offer the same level of protection as in the country in which You reside, or as in other parts of the world. Further, if You do not reside in the U.S., then Your Personal Information and Other Information may be transferred out of Your country of residence and to the U.S. or other parts of the world, and such information will be processed and stored in the U.S. or other parts of the world.
Further, the policies and practices described in this Privacy Policy do not apply to Our third-party hosting services providers, who have their own established data protection policies and procedures. We therefore make no warranty or claim regarding the privacy, confidentiality, integrity and security of any information and data stored or retained by such providers.
By using or accessing the Stretch Club App or Services in any way, You consent to the transfer, storage and processing of information that We collect from You as described in this Privacy Policy.
If You do not want your Personal Information to be transferred, stored or processed outside of the country in which You reside, You should not provide Us with Your Personal Information or access or use Our Services.
11. PROMOTIONAL AND NON-PROMOTIONAL EMAILS
We may use Your Personal Data to contact You (either through Stretch Club or third-party email marketing providers) with newsletters, marketing or promotional materials, or informational, educational or non-promotional information (as described above), 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 instructions provided in any email We send or by contacting Us as indicated below.
12. ADVERTISING
We may place advertising within the Stretch Club App, on Our Website or on Our Services, which contains links to the third-party websites of Our partners, advertisers, sponsors, or other third parties. We accept no responsibility for the practices of such third-party sites with respect to their privacy policies, and You should consult these third parties’ policies prior to use. Advertising delivered to or made available through Our Service may be provided by advertising partners, who may set cookies to deliver targeted advertising.
13. HOW USER DATA IS PROCESSED AND STORED
We may transfer Your Information and process it outside Your state or country of residence, wherever Stretch Club and its Third-Party Service Providers operate.
We retain the Personal Information You provide while Your account is in existence or as needed to provide You with Our Services or operate Our business. We may retain Your personal information even after You have closed Your account if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, comply with applicable laws, contractual obligations or industry standards, provide customer support, resolve disputes between Users, prevent fraud and abuse, or enforce this Privacy Policy and Our Terms of Use. When We no longer need Personal Information for all such operational, business and compliance purposes, We will delete or destroy it in accordance with Our security policies and procedures. In some circumstances, We may anonymize Your Personal Information (so that it can no longer be associated with You) in which case We may use this information indefinitely without further notice to You.
Please note that Our Payment Processors, Other Third-Party Sources, email marketing providers, and third-party hosting companies may have different data processing and retention policies and procedures, so please refer to the applicable privacy policies for such information.
14. HOW WE SECURE AND PROTECT YOUR PERSONAL INFORMATION
Stretch Club takes data security seriously, and We use appropriate technologies and procedures to protect Personal Information within Our company’s control and in accordance with industry standards. Our information security policies and procedures are closely aligned with industry standards and are reviewed regularly and updated as reasonably necessary. We use technical, administrative and physical safeguards to help protect against unauthorized access, destruction, loss, alteration, misuse or disclosure of Personal Information.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. While We believe our security procedures are commercially reasonable, We cannot ensure or warrant the security of any information that You transmit to Us, or that We transmit to You, or guarantee that it will be free from unauthorized access by third parties.
If You have reason to believe that Your interaction with Us is no longer secure, please immediately notify and contact Us in accordance with Section 20 (“How to Contact Us”) below.
15. YOUR OPT-OUT RIGHTS
As part of Your use of Our Services (when applicable), You are responsible for maintaining and updating Your Personal Information with current, accurate and complete information. You may view, update or edit the Personal Information You have provided to Us by logging in to Your account and following the appropriate instructions. You can also request that We help You make such changes to Your Personal Information by contacting Us in accordance with Section 20 (“How to Contact Us”) below.
You may opt-out from receiving marketing communications about Stretch Club products and services, or informational, educational or other non-promotional emails (as described above) related to Your use of the Stretch Club products and services that You signed up for or purchased, or other periodic emails from Us by contacting Us in accordance with Section 20 (“How to Contact Us”) below.
We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from Us, We may, if You are a Member, still send You important administrative or transactional messages, from which You cannot opt-out.
16. NO CHILDREN UNDER 13 SHOULD USE OUR SERVICES
Our Services are intended specifically for adults and children ages 13 and older or other age as required by applicable laws in the jurisdiction in which the User resides. Stretch Club does not knowingly collect Personal Information about children under 13 years old or other minimum age under applicable laws.
17. NOTICE TO PARENTS AND GUARDIANS
All parents and guardians are responsible for monitoring and supervising his/her/their child’s use of the Service. If You, as a parent or guardian, have a child using the Service without your express consent, and such child is under age 13 (if located within the U.S.), or is using the Service in violation of any other applicable laws, then please contact Us immediately so that We can disable Your child’s access.
If You wish to review Your child’s information (whether Your child is under or over 13 years old) collected through Stretch Club or other third parties identified in this Privacy Policy, or wish to have such collected information be modified or deleted, You may contact Us and We will work with You to address Your questions after We have verified You and Your request as described in Section 20 (“How to Contact Us”) below.
If We become aware that a child has provided Us with information in violation of applicable law, We will terminate the child’s account and delete all such information, unless We have a legal obligation to keep it.
18. FOR USERS RESIDING IN CA, CO, CT, UT, VA AND CERTAIN COUTRIES IN EUROPE
Below are certain state-specific or country-specific privacy laws that will apply when You use the Stretch Club Services. If any term in this Privacy Policy conflicts with the same term in such laws that apply to You, then the term in such applicable law will take precedence.
If You reside in California, please see the CALIFORNIA PRIVACY NOTICE section below for other rights under California law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Colorado, please see the COLORADO PRIVACY NOTICE section below for other rights under Colorado law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Connecticut, please see the CONNECTICUT PRIVACY NOTICE section below for other rights under Connecticut law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Utah, please see the UTAH PRIVACY NOTICE section below for other rights under Utah law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in Virginia, please see the VIRGINIA PRIVACY NOTICE section below for other rights under Virginia law related to Our use of Your Personal Information when You use the Stretch Club Services.
If You reside in the European Economic Area, United Kingdom or Switzerland, please see the GDPR PRIVACY NOTICE section below for other rights under the GDPR (defined below) related to Our use of Your Personal Information when You use the Stretch Club Services.
19. CHANGES TO THIS PRIVACY POLICY
Stretch Club reserves the right to change this Privacy Policy in its sole discretion at any time. Any changes will become effective when We post the revised Privacy Policy within Our Services. Your use of the Services following any such changes means that You accepted the revised Privacy Policy.
20. HOW TO CONTACT US
We want to be clear about Our privacy practices so that You can make informed choice about the use of Your information. If You have any questions or complaints about Our privacy practices or this Privacy Policy, or wish to make a “data rights” request under the privacy law that applies to You, please contact Us.
As solely an online company, We communicate with You and all of Our customers via email, so please contact Us at hi@stretchclub.io.
Verifiable Consumer Request
Depending on the kind of request You send Us, We may, in Our sole discretion, determine that Your request must be verified. In such cases, We will require You to: (a) provide sufficient information that allows Us to reasonably verify You are: (i) the person about whom We collected Personal Information or an authorized representative, or (ii) the parent or guardian of the subject child (as described in Section 17); and (b) describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We will only respond to Your request or provide You with the requested Personal Information if We can (in Our sole discretion) verify Your identity or authority to make such request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Authorizing an Agent
To authorize an agent to make a request (as permitted in this Privacy Policy) on Your behalf, please provide Us with written authorization signed by You and Your authorized agent, and We will contact You with further steps required to verify Your and Your authorized agent’s identities.
No Sensitive Data
Because email communications and any other electronic form of communication are not always secure, please do not include any credit card or any other sensitive information (aka “sensitive data”) in Your emails to Us.
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CALIFORNIA PRIVACY NOTICE
YOUR PRIVACY RIGHTS UNDER THE CCPA IF YOU LIVE IN CALIFORNIA
If You are a California resident using the Services, You may exercise the following rights (regarding Your personal information) under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”).
1. INFORMATION WE MAY COLLECT FROM YOU
Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or User’s device, whether collected online or offline (“personal information”). In particular, the Services have collected the following categories of personal information from Users within the last twelve (12) months:
