PRIVACY POLICY

Contents

1. Introduction
2. About this Policy
3. Your rights and your preferences: Giving you choice and control
4. Why and how do we use your personal data?
5. What personal data do we collect and how and when do we collect it?
6. Sharing your personal data
7. Data retention and deletion
8. Transfer to other countries
9. Links
10. Keeping your data safe
11. Children
12. Changes to this Privacy Policy
13. How to contact us

1. Introduction

At Wearable X, we want to give you the best possible experience to ensure that you enjoy our products and services today, tomorrow, and in the future. To do this we need to collect some of your personal data, so we can deliver an exceptional and personalized products and services specifically for you. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently list and describe the personal data that is collected or generated (processed) when you use Wearable X’s products, websites (“Sites”) and mobile applications (“Apps”). The terms governing your use of our services are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”).

We also want to explain how your personal data is used, shared and protected, what choices you have relating to your personal data and how you can contact us.

2. About this policy

This Policy sets out the essential details relating to your personal data relationship with Wearable X Inc. From time to time, we may develop new or offer additional products and services. If the introduction of these new or additional products and services result in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional products and services, they will be subject to this Policy.

The aim of this Policy is to:

EXPLAIN your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

ENSURE that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;

CLARIFY the way we use the personal data that you share with us in order to give you a great experience when you are using our products and services;

We hope this helps you to understand our privacy commitments to you. If you do not agree with the content of this Policy, then please remember it is your choice whether you want to use our products and services.

3. Your rights and your preferences: Giving you choice and control

You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:

RIGHT OF ACCESS - the right to be informed of and request access to the personal data we process about you;

RIGHT OF RECTIFICATION - the right to request that we amend or update your personal data where it is inaccurate or incomplete;

RIGHT TO ERASURE - the right to request that we delete your personal data;

RIGHT TO RESTRICT - the right to request that we temporarily or permanently stop processing all or some of your personal data;

RIGHT TO OBJECT -
the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
the right to object to your personal data being processed for direct marketing purposes;

RIGHT TO DATA PORTABILITY - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service;

RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

If you want to exercise these rights or have any questions regarding privacy, please contact us at any time using the email address below. We will respond to your request within a reasonable period of time upon verification of your identity. In order to improve ease on your privacy settings, we may integrate features to our products, sites and apps that will allow you to take care of your privacy settings yourself.

4. Why and how do we use your personal data?

We use your personal data in the following ways:

TO PROVIDE THE FEATURES OF THE PRODUCTS, SITES, APPS AND SERVICES YOU REQUEST

When you use our Sites and Apps, we will use your personal data to provide the requested product or service. For example, if you make a purchase on wearablex.com or participate in an event or promotion, we will use the contact information you give us to communicate with you about the purchase, event or promotion. If you contact our consumer services, we will use information about you, such as delivery or payment information, or the product you have purchased to help you resolve a problem or question.

If you use our Apps to track your fitness activity (e.g. your yoga time) or physical characteristics (e.g. your yoga level), we will collect this personal data and store it so that you can review it in the App. Your fitness activity data may include data you enter about your activity or data collected by your device during your activity such as location data and movement data. We may use this activity data to calculate further information about your activity, such as distance run, or calories burned, so that the calculated information can be provided to you as part of the functionality of the App.

In many cases, to use particular features within our Sites and Apps you may need to provide us with additional data or additional consent to use particular data in a certain way. For example, to be able to store your yoga time in the Apple Health App, you need to connect our Apps to the Apple Health App. Similarly, to share content with your friends or on social media, you may be required to provide your contact list or your social media account credentials to sign in.

TO COMMUNICATE INFORMATION ABOUT OUR PRODUCTS, SERVICES, EVENTS AND FOR OTHER PROMOTIONAL PURPOSES

When you consent, we will send you marketing communications and news concerning Wearable X’s products, services, events and other promotions. You can opt-out at any time after you have given your consent.

If you are an existing customer of Wearable X (for example, if you have placed an order with us), we may use the contact details you provided to send you marketing communications about similar/new Wearable X products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us as well as information from other Wearable X products or services - such as your use of Wearable X’s Sites and Apps or your participation in Wearable X events - to personalize communications on products and services that may be interesting for you.

TO OPERATE, IMPROVE AND MAINTAIN OUR BUSINESS, PRODUCTS AND SERVICES

We use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits and other internal functions. We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our products, Sites and Apps.

TO PROTECT OUR OR OTHERS' RIGHTS, PROPERTY OR SAFETY

We may also use your personal data about how you use our products, Sites and Apps to prevent or detect fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests or applicable law.

FOR GENERAL RESEARCH AND ANALYSIS PURPOSES

We use data about how our visitors use our Sites, Apps and services to understand customer behavior or preferences. For example, we may use information about how visitors to wearablex.com search for and find products to better understand the best ways to organize and present product offerings.

USE (PROCESSING) OF WORKOUT INFO

As discussed above, Wearable X collects data about your fitness activity or your physical characteristics to provide our products, Apps and services. Because of the personal nature of this data, we strive to provide you with clear information about how this info will be used. As this data may be considered sensitive in certain jurisdictions, we take appropriate measures in protecting and using this data and, where required by applicable law or under Wearable X’s internal policies, will obtain your consent for use of this data.

OTHER PURPOSES

We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

LEGAL GROUNDS

To process your personal data, we rely on certain legal grounds, depending on how you interact with our Sites and Apps.

When you purchase Wearable X products from our Sites and Apps, we need your personal data to fulfill our contract with you. For example, we need your payment and contact details to deliver your order.

When you use our Apps, we rely on your consent for processing and for certain limited purposes to fulfill our contract with you (for example, for in-App purchases).

We also rely on other legal grounds, such as our legitimate interests as a business, to comply with a legal obligation, or to protect your vital interests.

5. What personal data do we collect and how and when do we collect it?

INFORMATION YOU CHOOSE TO GIVE US

When you interact with our products and services, we collect the information that you choose to share with us. For example, if you set up an account in our app, we need to collect a few important details about you, such as: a unique username, a password, an email address, a phone number, a photo and your date of birth.

To be able give you the best experience with our products and services we may also ask you for some personal details including gender, hometown, age, weight, height or level of yoga. For the same matter, we may collect fitness activity data provided by you or generated through our products, Sites or Apps, for example time, duration, location or personal preferences like your favourite yoga teacher or preferred vibration strength.

Other services, such as commerce products, may also require you to provide us with a debit or credit card number and its associated account information like your billing address.

When you contact customer support or communicate with us in any other way, we’ll collect whatever information you volunteer.

INFORMATION WE GET WHEN YOU USE OUR PRODUCTS AND SERVICES

When you use our products and services, we collect information about which of those products and services you have used and how you have used them. We might know, for instance, which yoga poses you did and which pose was detected by the algorithm in our app. Here is a fuller explanation of the types of information we collect when you use our services:

USAGE INFORMATION. We collect information about your activity through our products and services. For example, we may collect information about:

How you interact with our products and services, such as the time of day when you use our products, Sites and Apps.
The content you share with your friends or on social media

DEVICE INFORMATION. We collect information from and about the devices you use. For example, we collect:

Information about your hardware and software, such as the hardware model, operating system version, device memory, advertising identifiers, unique application identifiers, unique device identifiers, browser type, language, battery level, and time zone;
Information from device sensors, such as the accelerometers inside our Nadi X pants, but also from your phone as well as its gyroscopes, compasses, microphones
Information about your wireless and mobile network connections, such as mobile phone number, service provider, and signal strength.
Device Phonebook. If you want to share content with friends, we may—with your permission—collect information from your device’s phonebook.
Location Information. When you use our products and services we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.

INFORMATION COLLECTED BY COOKIES AND OTHER TECHNOLOGIES. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with services we offer through one of our partners, such as advertising and commerce features. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services.

LOG INFORMATION. We also collect log information when you use our website. That information includes, among other things:

Details about how you’ve used our services.
Device information, such as your web browser type and language.
Access times.
Pages viewed.
IP address.
Identifiers associated with cookies or other technologies that may uniquely identify your device or browser.
Pages you visited before or after navigating to our website.

INFORMATION WE COLLECT FROM THIRD PARTIES

We may collect information that other users provide about you when they use our products, Sites and Apps. For example, if another user allows us to collect information from their device phonebook—and you’re one of that user’s contacts—we may combine the information we collect from that user’s phonebook with other information we have collected about you.

We may also obtain information from our affiliates and third parties.

6. Sharing your personal data

WEARABLE X'S SHARING

Wearable X might share your personal data with:

Third party applications or service providers processing personal data on our behalf, for example to process third party content, credit cards and payments, shipping and deliveries, host, manage and service our data, distribute emails, research and analysis, manage brand and product promotions as well as administering certain services and features. When using third party applications and service providers we enter into agreements that require them to implement appropriate technical and organizational measures to protect your personal data.

Other third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law; (ii) prevent illegal uses of our products, Sites and Apps or violations of our products’, Sites’ and the Apps’ Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).

To any other third party where you have provided your consent.

We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

YOUR SHARING

When you use certain social features on our Sites or Apps, you can create a public profile that may include information such as your screen name, profile picture and hometown. You can also share content with your friends or the public, including information about your Wearable X activity. We will continuously introduce and improve tools for managing Wearable X’s social sharing in order to make control of information you make available through Wearable X’s social features easier for you.

THIRD-PARTY CONTENT AND INTEGRATIONS

Our services may also contain third-party links and search results, include third-party integrations, or offer a co-branded or third-party-branded service, such as yoga videos from other App or content providers. Through these links, third-party integrations, and co-branded or third-party-branded products and services, you may be providing information (including personal information) directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. We encourage you to review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through our services.

7. Data retention and deletion

We keep your personal data only as long as necessary to provide you with our services and for legitimate and essential business purposes, such as maintaining the performance of our products, sites and apps, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. In general, this means that we will keep your personal data for as long as you keep your Wearable X account. For personal data related to product purchases, we retain this longer to comply with legal obligations, for example tax and sales laws or for warranty purposes. If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:

If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;

Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law;

Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

8. Transfer to other countries

We share your personal data globally within our company offices in order to carry out the activities specified in this Policy. This includes the following countries: Australia, Canada, Switzerland, United Kingdom and the United States of America. We may also subcontract processing to, or share your personal data with third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.

Personal data collected within the European Union or Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances we shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

9. Links

We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving Wearable X’s sites or apps and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

Also, our Sites and Apps may allow you to interact with other digital products and services. For example, our apps may offer the feature to integrate with third-party devices for activity tracking, social networks, music streaming services and other digital services.

If you choose to connect your account with a third-party device or account, your privacy rights on third-party platforms will be governed by their respective policies. For example, if you choose to share your yoga activity on third-party social media platforms, the policies of those platforms govern the data that resides there.

10. Keeping your data safe

We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used our sites and apps.

11. Children

Wearable X is intended for users who are 18 years of age and older. If you are under the age of 18, you are not permitted to submit any personal information to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Wearable X, please contact us, and you may request exercise of your applicable rights detailed above.

If we learn that we have collected the personal data of a child under age limit, we will take reasonable steps to delete the personal data. This may require us to delete the account for that child.

12. Changes to this Privacy Policy

Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Sites and Apps or via email. If we materially change the way in which we process your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our privacy policy and keep yourself informed of our practices. This privacy policy was last modified in May 2018.

13 How to contact us

Thank you for reading our Privacy Policy. If you have any questions about this Policy or want to exercise the rights described above, please contact us by using the following email address:

hello@wearablex.com