This privacy statement applies to: 360Wellness app and website.

360Wellness is a software platform providing you with tools to improve your wellness, track your training, in order for us to provide you with guidance and recommendations to hire a coach to assist you improving your sport performances (the “Services”).

360Sport Pte Ltd attaches great importance to your privacy. Below is explained what personal data we collect, for what purposes, how we obtain the data, what your rights are and how you can exercise these rights.

1.DEFINITIONS

“App” means the 360Wellness App.

“Coaches” means an individual you have chosen on our App to coach or train you via our App.

“Personal data” means information that tells us something about you or that we can associate with you. You share personal data with us if you are a registered or unregistered user of our App, have contact with us. When you use our App, you share personal data with us.

“We”, “us”, “our”, “360Wellness” and “360Sport” means 360Sports Pte. Ltd., a Singapore company.

“User” or “users” means anyone who visits our website or use our app. A user may be unregistered or registered by creating an account on the App.

“You”, or “your”, means you, as a user of our App. You may be a registered or un-registered user or a visitor.

“Preferences” means the settings you select when you are a registered user of our app.




 

 

 

2. WHAT PERSONAL DATA DO WE PROCESS?

 
 

2.1 WHEN YOU ARE AN UNREGISTERED USER

The basic features of our App can be used without you needing to register.

As an unregistered user, we may collect with your consent (from your smartphone) your mobile identifier, location, language preference, time zone and your step count.

We may also collect with your consent (you need to key them in) your gender, sleep habits, feelings, recovery patterns, nutrition habits.

2.2 WHEN YOU ARE A REGISTERED USER

In order for you to benefit from additional features, we will ask you to create an account. If you create an account and sign in, we will gather and store your account information in order to render the Services.

To create an account, you need to provide an email address and a password.

You may choose to sign in using a social network such as Facebook or Google. The information shared by Facebook or Google with us depend on their privacy policies. We encourage you to refer to their privacy policies to learn more about this.

If you want to make the best of our Services, we may ask you to share additional personal data with us (e.g. a profile picture, language, time zone, gender, age, sport activities and preferences, location, heart rate, weight, walk, cycle or run speed, financial information used for payments through the Service, sleep patterns, nutrition habits, recovery patterns, feelings, calendar, etc.).

You may also want to associate a connected device with your account, such as a smart watch, or other wearable device. When enabled, we may collect certain information from the device or from your account associated with the device provider (e.g. your unique device identifier, account ID, location, step count, heart rate, cadence, and other information about you or your activities). You need to opt-in to the sharing of personal data from your connected device with us. If you do not opt-in, we will not be able to collect information from your connected device.

The more information you provide to us on the App or allow us to collect from your connected device, the more we will process and the more you will get from our Services. If you do not want to share these personal data with us, do not key them in our App and do not allow for your smart watch or wearable device to share them with us.

Your account will be associated with your preferences (e.g. language, base location etc.). Your preferences are securely associated with your account. When you sign in from a new device, your preferences are synchronized to that device and will be cleared when you sign out.

You can always update or remove the personal data you share with us on your profile settings page.

COOKIES POLICY

In addition, using our app and website triggers the collection of information about the kind of device or computer browser you are using and how you used the Service via cookies.

We make a limited use of cookies but they are necessary for us to provide you with our Services. Cookies are used to support social media plug-in features, specifically, to allow sign-in via social networks, such as Facebook or Google, and to support direct sharing to such social platforms from our Services.

We use local storage in our Services to cache settings and to maintain the state of your login. Cookies may be used as a fallback for caching in some browsers if local storage is not available.

The cookies running on our on App and website are:

Cookie’s name Usage Developed by Lifespan of the cookie
Google API
Facebook SDK
Geolocation API
Zoom SDK
Push notifications
Firebase
Sign in and log in
Sign in and log in
Geolocation of mobile phone
In-app conference calls
Send notifications
Send messages

Google
Facebook

.

Zoom

.

Firebase

 

You may disable cookies and local storage in your browser or device settings. However, this may render some of our Services unavailable or affect their performance.

 

3. WHAT WE USE YOUR PERSONAL DATA FOR AND THE LEGAL BASIS FOR US TO DO SO

Your personal data is only used to provide the Services and for the purposes mentioned in this Privacy statement. 

We do not sell your personal information to third parties.

3.1 PROVIDE SERVICES

We use the information we collect to deliver the Services to you.

We use your personal data to: The legal basis we use to process your personal data:
Allow you to obtain analysis of your sport performances Contractual relationship between us and you
Allow you to search and attend remote sport coaching and wellness classes Contractual relationship between us and you
Allow you to obtain personalised recommendations, advice and tips on your wellness Contractual relationship between us and you
Record your preferences Contractual relationship between us and you
Allow you to search for Coaches, if you have subscribed to this feature Contractual relationship between us and you
Allow you to interact with other users of the platform for user-to-user communications Your consent
Allow you to discover and connect with other users in nearby locations, if you have subscribed to this feature Your consent
Allow you to contact coaches via our platform in order for you to find the best coach for your training needs, if you have subscribed to this feature Contractual
Allow you to directly pay your coach via the platform, if you have decided to engage the services of a coach found via our platform Your consent
Allow you to share your sport performance on social media Your consent
Allow you to synchronise your calendar with your Coach’s calendar to plan coaching sessions. Your consent
Allow you to find events around you Contractual relationship between us and you

3.2 COMMUNICATION AND MARKETING

We use your personal data to: The legal basis we use to process your personal data:
Communicate with you for support and announcements (e.g. replying to your questions, account support maintenance, password reset, privacy or terms of use updates, etc.) Our legitimate interest
Send you push notifications, if you have allowed them on your device. Your consent
Display marketing information via the App Your consent

3.3 IMPROVEMENT AND, DEVELOPMENT OF FEATURES

We use your personal data to:  The legal basis we use to process your personal data:
Solve issues on our platform (e.g. trouble shoot and debug, etc.) and communicate with you regarding them Our legitimate interest
Generate de-identified reports from all our users in order for us to improve and develop our Services (e.g. data analysis, testing, research, etc.) Our legitimate interest
Generate statistics from all our users in order for us to conduct marketing campaigns Our legitimate interest

3.4 SAFETY AND SECURITY

We use your personal data to: The legal basis we use to process your personal data:
Promote safety and security of our App and website (e.g. investigating suspicious activity, breach of this privacy statement, breach of our terms of use, etc.) Our legitimate interest

 

4. WITH WHOM DO WE SHARE PERSONAL DATA

We do not sell your personal data.

In principle, we do not share personal data with other persons or organisations, unless this is necessary for the provision of our Services.

If you allow us to collect personal data from your connected device, we do so in accordance with applicable laws and have put in place the relevant agreements.

We also have put in place contractual arrangements with our services providers assisting us to provide you with our Services.

We may be required in some cases to share personal data with third parties on the grounds of a legal requirement. This applies, for example, to the police, the judiciary, supervisory authorities and the tax authorities.

We may share your personal data with affiliates under common control with us, which are required to comply with the terms of this Privacy Statement with respect to your personal data. If 360Sports is involved in a merger, securities offering, bankruptcy, reorganization, winding up or other similar transaction, we may share or transfer your information as part of that transaction.

Your nickname is visible to the other users of our App or on social media.

In your account profile setting page you can decide (opt-in) which of your personal data can be publicly shared with all the other users of our App and which personal data can be privately shared with your coach.

Please be very carefully with what you share and with whom you share it. In general, if you share something public with the other users, it becomes available for anyone to see.  Please also consider that if you share something publicly (to everyone or privately with another in our system) the receiver(s) can, for certain data, choose to reshare it with others and even share it outside of our App (e.g. when you send a message to a specific user, this user can download, screenshot, or reshare that content to others inside or outside of our App. Once information is made public, it can be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, offline media such as TV, and by apps, websites).

5. STORAGE PERIODS

In principle, we do not retain personal data longer than necessary for the purpose for which you have provided this personal data. We may deviate from this retention period if required by law.

We may retain information from accounts disabled for violations of our terms and conditions for at least a year to prevent repeat abuse or other terms violations.

If your account becomes inactive for a continuous period of 12 months, we will delete your account after having sent you an email informing you of the deletion and you have not logged into your account within 30 days of our email.

If you choose to delete your Account (by clicking on your Profile, then Support, then Logout), your personal data in the App becomes immediately inaccessible. However, it may take up to 30 days for all your personal data to be deleted from our backup.

6. SECURITY

We take the protection of your personal data seriously and therefore takes appropriate measures to protect your personal data against misuse, loss, unauthorized access, unwanted disclosure and unauthorized alteration.

We therefore ensure that only employees who need to have access to your personal data can access it. In addition, all our employees have signed a confidentiality agreement. This declaration of confidentiality also applies if they no longer work for 360Sport Pte Ltd.

Furthermore, we register all data incidents and handle them carefully. We will report data incidents to the Singapore Personal data protection Commission and to you if we are required to do so by applicable laws.

If you feel that your personal data is not properly secured and/or that there are indications of misuse, please contact us at dpo@360wellness.com

 

 

 

7. VIEW, MODIFY OR DELETE YOUR DATA

Since we process your personal data, you have the right to access, rectify or delete your personal data. You also have the possibility to port your personal data, restrict the processing and object to the processing of your personal data.

We do not use automated decision making or profiling (an automated analysis of your personal circumstances) to make decision which produce legal effect or other significant effect to you.

You can send your request for inspection, correction or removal to dpo@360wellness.com. We will want to be sure that the request has actually been made by you, therefore we will contact you about this. We may ask for evidence that the request comes from you. Should we ask for this, we would give you an instruction on how you can safely provide us with the relevant information. This is to protect your privacy.

If you do not have a computer or do not want to send an e-mail, you can also send a request by post. In any case, do not forget to include your contact details.

You can send a request to:

DPO @ 360Sports
160 Robinson Road
#14-04 Singapore Business Federation Centre
#09-33 Urban Vista
Singapore 068914

360Sport Pte Ltd will respond to your request as soon as possible, but no later than four weeks after receipt of your request.

 

8. QUESTIONS ABOUT PRIVACY?

This privacy statement was made in March 2021. We may change this privacy statement.

After reading our privacy statement, do you still have questions about how we handle your personal data? Then you can send an e-mail to dpo@360wellness.com.

We hope of course that we can answer your privacy questions properly. If you are not satisfied with our response, you can submit a complaint about the processing of your personal data to the Singapore Personal data protection Commission.

Latest update if this privacy statement: May 2020