Privacy policy

 1. INTRODUCTION

 At Train.Red B.V. (“Train.Red,” “us,” “we,” or “our”), we're dedicated to enhancing fitness experiences while prioritizing your privacy. Our aim is for this level of commitment to become the standard across all wearable device companies. Your privacy is of utmost importance to us, and we want to ensure you fully understand how we handle, collect, and share Personal Data, as well as the precautions we take to keep it secure.

This Privacy Policy applies to Personal Data collected from members and consumers who engage with Train.Red or utilize our services. This includes interactions on our website, social media, mobile app usage, Train.Red Strap, or other Train.Red devices (collectively referred to as the “Services”). Please note that this policy does not cover practices of companies outside our ownership or control, and we do not bear responsibility for the policies or actions of third parties. Furthermore, we do not oversee or endorse information, products, or services offered by such third parties through our Services.

 For individuals in the European Economic Area, the United Kingdom, and Switzerland (collectively referred to as “Europe” or “European”), additional information is provided below.

Train.Red B.V. reaffirms its commitment to complying with Dutch data protection laws, specifically the AVG and General Data Protection Regulation (GDPR) concerning the Netherlands. This Privacy Policy is designed to align with the principles and requirements outlined in these regulations to ensure the safeguarding of your personal information.

 

 2. HOW WE COLLECT PERSONAL DATA

We collect Personal Data through various means:

  • Information directly provided by you, such as when you complete your profile.
  • Data from Train.Red devices or other connected wearables through the Train.Red APP.
  • Automated methods like Cookies, web beacons, and similar technologies used during your usage of our services.
  • Information from clients and partners like employers, insurers, coaches, or teams that engage with our Services.
  • Insights from marketing partners involved in joint activities or assisting in promotional services, providing data on how you interact with our Services.
  • Data from social media and third-party platforms if you engage with our content or link accounts to your Train.Red profile.
  • Additional information from data providers, such as information services or data licensors, to supplement your existing information.

 

3. PERSONAL DATA WE COLLECT

We may collect various types of Personal Data, including:

  • Contact information: such as names, email addresses, mailing addresses, and phone numbers.Profile data: including usernames, passwords, and self-provided information within your Train.Red profile.

  • Communications: encompassing exchanged emails, interactions on web or mobile apps, queries, or feedback.

  • Fitness-related data: covering aspects like muscle oxygen levels, heart rate, temperature, activity, strain, recovery, submitted physiological profile (height, weight, body and fitness level), and submitted preferences. This information is used to personalize your experience within our Services.

  • Payment and transactional data: necessary for completing orders. Please note that we do not have access to payment card numbers as they are handled by our payment processors.

  • Marketing preferences and engagement details.

  • Device information: including operating systems, device models, browsers, IP addresses, unique identifiers, language settings, and location data.

  • Geolocation data: comprising GPS information, IP addresses, and exercise-related movement data with your explicit consent.

  • Details of online activity: such as pages viewed, time spent, navigation paths, access times, and specific activities on screens or pages.


4. COOKIES

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance, whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name

Function

_ab

Used in connection with access to admin.

_secure_session_id

Used in connection with navigation through a storefront.

cart

Used in connection with shopping cart.

cart_sig

Used in connection with checkout.

cart_ts

Used in connection with checkout.

checkout_token

Used in connection with checkout.

secret

Used in connection with checkout.

secure_customer_sig

Used in connection with customer login.

storefront_digest

Used in connection with customer login.

_shopify_u

Used to facilitate updating customer account information.

Reporting and Analytics

Name

Function

_tracking_consent

Tracking preferences.

_landing_page

Track landing pages

_orig_referrer

Track landing pages

_s

Shopify analytics.

_shopify_s

Shopify analytics.

_shopify_sa_p

Shopify analytics relating to marketing & referrals.

_shopify_sa_t

Shopify analytics relating to marketing & referrals.

_shopify_y

Shopify analytics.

_y

Shopify analytics.

 

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

 

5. HOW WE USE PERSONAL DATA

We process Personal Data to facilitate, enhance, understand, and personalize our Services, utilizing it for various objectives:

Service Provision: This involves:

  • Developing, refining, and customizing the Services and our business, including testing, research, analysis, and product advancement.
  • Addressing the purpose for which you provided the information, responding to queries, and fulfilling requests.
  • Communicating with you about Service announcements, updates, or offerings.
  • Providing support and assistance for the Services.
  • Managing and maintaining your account or user profiles.
  • Customizing website content and communications based on your preferences.
  • Handling orders, memberships, or other transactions.

Research and Development: We generate and utilize Aggregated Data, De-identified Data, or other anonymous data derived from the Personal Data we collect, including Wellness Data. This helps us analyze Service effectiveness, introduce new features, and understand the general behaviors and characteristics of Service users. Anonymous Wellness Data supports research efforts, assisting us and our research partners in exploring significant questions about human performance, ultimately enhancing member experiences through innovative insights, fresh content, and product features.

Direct Marketing and Advertising: We may use data from the Personal Data we collect, including Wellness Data and specific browsing data from our website, to send targeted offers, marketing messages, or advertise the Services or other Train.Red product offerings.

Interest-Based Advertising: Collaborating with advertising partners, including third-party advertising and social media companies, we may use Cookies and similar technologies to track your interactions across the web, our communications, and other online services. This information may be used to display online advertisements. Our practices align with the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising. For more details and choices about interest-based ads, please refer to the section titled “Online tracking opt-outs.”

 Compliance and Protection: This includes:

  • Protecting against fraudulent, illegal, or harmful actions and maintaining the safety, security, and integrity of our Services.
  • Complying with legal or contractual obligations, resolving disputes, and enforcing our Terms of Use and Terms of Sale.
  • Auditing internal processes to ensure compliance with legal and contractual requirements and internal policies.
  • Safeguarding our rights, your rights, safety, privacy, or property (including legal claims).
  • Responding to law enforcement requests and complying with applicable law, court orders, or governmental regulations.

 

 6. HOW WE DISCLOSE PERSONAL DATA

Your Personal Data may be shared with:

Service providers: These include payment processors, vendors advertising Train.Red Services or other Train.Red products, security consultants, fraud prevention experts, hosting and technology providers, analytics firms, and contracted personnel who provide services to us or on our behalf.

Advertising partners: They may collect information through Cookies and automated technologies from our website for the purposes mentioned earlier related to interest-based advertising. Importantly, we do not share your Wellness Data with advertising partners.

Professional advisors: Such as legal, auditing, banking, and insurance entities, as necessary for the provision of their professional services to us.

 Authorities and others: This includes law enforcement, government authorities, and private entities when deemed necessary or appropriate in compliance with the law or legal procedures. 

Business transferees: This involves potential acquirers and relevant participants in business transactions related to corporate divestiture, mergers, acquisitions, sales, reorganizations, or dispositions of our business or assets. This may include affiliates or equity interests in Train.Red or our affiliates, including scenarios involving bankruptcy or similar proceedings.

 

7. HOW YOU MIGHT DISCLOSE PERSONAL DATA THROUGH TRAIN.RED

Based on your Service usage, you might share Personal Data in the following ways:

Other Service users: Features like Train.Red Live or Train.Red Teams allow the exchange of information and content among users. By default, users can be searched by others. 

Third-party social media platforms or linked accounts: When choosing to link your Train.Red account with these services or posting content via Train.Red Live.

Public visibility: Personal Data made visible to other Service users through features like Train.Red Live or Train.Red Teams could become publicly available and accessible to anyone.

 Managing entities: If your Service usage is managed by a coach, team, or affiliated entity, your account information and Personal Data might be shared with them based on your consent. By providing consent, you allow the managing entity control over the shared information and content, unless specifically overridden by specific Service features.

Corporate wellness programs: If using Train.Red Services through an employer's or organizational wellness program, we may share your information with that entity, typically in the form of Aggregated Data, subject to your consent.

 

8. YOUR CONTROL OPTIONS

Access, Modify, or Delete Information:

When logged into your Train.Red account, you can access and, in some cases, edit or delete specific provided information like your name, username, password, email, mailing address, and profile details. To request access, update, or delete your account and its data, go to the “Data Management” section in the Train.Red app and follow the prompts to delete your account. We may retain an unchanged copy of this information in our records as required by law or for legitimate business purposes. Please note that some non-personal data (such as Aggregated or De-identified Data) may still be retained for analysis or reporting purposes after deletion. Verification might be required to authorize account deletion.

 

Push Notifications and Device Permissions:

Upon logging into your account, you can access, edit, or delete certain provided information like your name, username, password, email, mailing address, and profile details. Updates made may be retained as an unrevised copy in our records. To access or delete your account and its data, contact support via email or use the “Data Management” feature within the Train.RedAPP. Verification might be required for authorization. Certain Personal Data, Aggregated Data, or De-identified Data may be retained even after updating or deleting your data.

 

Geolocation Data:

You can enable or disable Train.Red's collection of geolocation data by managing location services on your mobile device. Opting out of this data collection may limit certain Service functionalities and features.

 

Sports Data:

You can stop the collection of additional data by disconnecting your Train.Red device from your mobile device.

 

Do Not Track:

Presently, the Services do not support “Do Not Track” requests or similar signals sent by certain Internet browsers. To learn more about “Do Not Track,” visit http://www.allaboutdnt.com.

 

 9. THIRD-PARTY SITES AND SERVICES

Within our Services, you might come across links to websites and various online services operated by Third Parties. Moreover, our content might be embedded into web pages or other online services not directly affiliated with us. Please note that the presence of these links and integrations does not imply our endorsement or association with any Third Party.

We do not have control over mobile applications, websites, or online services provided by Third Parties, and we are not responsible for their actions. You can learn more about how these Third Parties handle and share your Personal Data, including with Train.Red, by reviewing their privacy policies and utilizing any privacy options they offer. It's important to understand and manage your data with these Third Parties accordingly.

 

10. DATA SECURITY AND RETENTION OF PERSONAL DATA

To ensure the protection of the Personal Data we collect, we implement diverse physical, technical, organizational, and administrative security measures. While we make every effort to safeguard the privacy of your account and other retained Personal Data, it's important to recognize that no security measure is foolproof, and we cannot guarantee absolute security for your Personal Data.
The user data is stored in Firebase, Train.Red uses Cloud Firestore and Cloud Storage for Firebase as well as Firebase Crashlytics and Firebase Authentication. Encryption in Firebase plays a crucial role in safeguarding user privacy by securing data both in transit and at rest, controlling access through robust security rules, and ensuring compliance with data protection regulations.

Train.Red retains Personal Data for a duration that is reasonably necessary to fulfill the purposes outlined in this Privacy Policy. This retention period is determined by business needs or as required by law, such as for tax, legal, or accounting reasons. We adhere to the longer duration between these requirements.

 

11. PERSONAL DATA OF MINORS

 If you do not meet the age required to consent to data sharing according to the laws in your jurisdiction, we kindly request that you refrain from attempting to register for our Services or providing any Personal Data about yourself to us. In the event that we inadvertently collect Personal Data from a minor below the age of consent as per jurisdictional requirements, we will promptly delete that information. If you believe that a minor below the age of consent, as determined by the laws in your jurisdiction, has provided us with Personal Data, please contact us at info@train.red.

12. CHANGES

We might periodically update this Privacy Policy to align with changes in our practices or legal requirements. Any substantial changes will be communicated to you by posting the updated Privacy Policy on our website or through other suitable communication channels. We recommend reviewing this Privacy Policy from time to time to stay informed about any updates

13. CONTACT

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Train.Red B.V.

Einsteinweg 13
6662 PW Elst (GLD)
The Netherlands
Phone: +31611758374
Email: info@train.red
Website: Train.Red

 

This Privacy Policy was last updated on November 17, 2023.

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here.

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