New Health Media LLC (hereinafter “company”, “we”, “us”, or “our”) is the owner of Train Back. We are committed to protecting your personal information (personal data as defined by the law) and your right to privacy. If you have any questions or concerns about our policy, or our practices with regard to your personal information, please contact us at firstname.lastname@example.org.
1. INFORMATION THAT IS COLLECTED
Information collected automatically
Some information – such as IP address and/or operating system and device characteristics – is collected automatically when you use Train Back.
We automatically collect certain information when you use or navigate Train Back. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes. Generally, such information is non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as personal data.
Information provided by you
If you wish to complete account creation, you are required or may provide some information, such as your email and name. You are also welcome to provide more data to offer you better performance of the App such as age, gender, goals as to the usage of the App, pain area, pain duration, activities you are able to exercise, your feelings about proposed exercises, your photo of the profile etc. Such information will be treated as personal data.
Non-personal data in combination with personal data will also be treated as personal data. If the information is provided by you without login into the account of the App and providing an email address, such information is treated as non-personal data.
We do not check and we are not responsible for the accuracy of the information provided by you. If we detect the placement of forbidden information in a profile, we may, at our sole discretion, delete such information and/or prohibit the user from accessing the App.
2. PURPOSE OF THE USE OF YOUR INFORMATION
We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you and/or our partner, compliance with our legal obligations, and/or your consent.
We use personal information collected via Train Back for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process with your Consent.
- To enable the services of Train Back to you.
- To provide related customer service and care. It includes responding to your questions, complaints, or comments and sending surveys (with your consent) and processing survey responses.
- To send administrative information to you for Legal Reasons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For Analytics and other Business Purposes. We may use your information for other Business Purposes, such as analytics, data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, services, marketing and your experience.
Detailed information on the processing of Personal Data for Analytics
Analytics enables us to monitor and analyze web traffic and can be used to keep track of your behavior. We use Google Analytics (Google Inc.) to collect personal data and execute our analytics.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of our Sites, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Place of data processing: United States.
To Opt Out Google Analytics – visit the following link https://tools.google.com/dlpage/gaoptout?hl=en.
3. RIGHT TO SHARE YOUR DATA
We only share personal data with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
Non-personal data, de-identified personal information and aggregated user statistics can be shared at our discretion.
We only share and disclose your personal data in the following situations:
- Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Partners, Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party stores, service providers, retail networks, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples of such sharing include: data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the App, which will enable them to collect data about how you interact with the App over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
- We do not share, sell, rent or trade any of your personal information with third parties for their promotional purposes.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- With your Consent. We may disclose your personal information for any other purpose with your consent.
4. COOKIES AND OTHER TRACKING TECHNOLOGIES
Most browsers are initially set up to accept HTTP cookies. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, and how to disable existing cookies. Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore it is recommended that you do not disable cookies.
5. INTERNATIONAL TRANSFER
The personal data is stored at our servers that are owned by our partner – SG Hosting Inc, 901 N Pitt Street, Suite 325, Alexandria, 22314 VA, USA.
The Data is processed at our operating offices and in any other place where the parties involved in the processing are located. Only authorized employees of Train Back have access to your personal data. Your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the countries of their residence.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the App, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such as the European Union (European Economic Area), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In EU (EEA) you have certain rights under applicable data protection laws. This policy complies with GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). Therefore, if you are resident of the EU (EEA) you have the right
(i) to request access and obtain a copy of your personal information:
(ii) to request rectification or erasure;
(iii) to restrict the processing of your personal information; and
(iv) if applicable, to data portability.
In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact information provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal data, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Go to your Profile information page (https://app.trainback.com/information);
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations or comply with legal requirements.
Opting out of email marketing
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
- Contact us using the contact information provided.
10. DO WE MAKE UPDATES TO THIS POLICY?
Yes, we will update this policy as necessary to stay compliant with relevant laws.
11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by post to:
New Health Media LLC
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request at email@example.com. We will respond to your request within 30 days.
Last Updated: 19th July 2019