Privacy Policy

This Privacy Policy was last updated on 27 January 2016

SweatCo Ltd is a company incorporated in England & Wales (registration number 09242159) whose registered office is at c/o OHS Secretaries Limited, 9th Floor, 107 Cheapside, London, EC2V 6DN  (hereafter referred to as “SweatCo”“we” or “us” as the context may require).  SweatCo is committed to protecting your privacy in full compliance with applicable data protection and privacy laws. 

This Privacy Policy, together with our Terms of Use (http://sweatco.in/uk/tnc), applies to your use of the Sweatcoin mobile application (the “Sweatcoin App”), any website operated by SweatCo (including http://sweatco.in/) (the “SweatCo Website(s)”) and any services we provide that are accessible via any of them.  This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.  
 
By visiting any SweatCo Website(s) or by downloading, installing or using the Sweatcoin App, you accept this Privacy Policy and consent to the processing of your personal data as described herein.
 
In this Privacy Policy, the terms “data controller”, “personal data” and “process” shall have the meanings given in the Data Protection Act 1998 applicable in England and Wales (the “Act”). SweatCo is the data controller in respect of personal data processed under this Privacy Policy (our details are provided above.) 
 
INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

Information you give us: You may provide us with information about you in connection with your use of the Sweatcoin App or SweatCo Website(s), for example by filling in forms or using functionality on such Sweatcoin App or SweatCo Website(s) or by corresponding with us by email or otherwise contacting us.
 
Such information may include the following: 
·       the information you provide when you register to use the Sweatcoin App, which requires the submission by you to us of your name, mobile phone number, email address as well as usernames, passwords and the identification credentials that are used to authenticate you, enable you to use the Sweatcoin App and enable us to communicate with you.  
·       During the account registration process we may provide functionality allowing you to search for friends by using your Facebook credentials and where you elect to do this you will be asked to allow the Sweatcoin App to access certain information associated with your Facebook account such as your name, profile picture, gender, list of friends and other public information.  Provided you consent to this, such information will be processed by us in order to identify your Facebook friends that are users of Sweatcoin App and to allow you to invite your Facebook friends to install the Sweatcoin App. 
·       any data you upload to the Sweatcoin App in relation to your user profile or in connection with any listing on the Sweatcoin Marketplace (as defined in our Terms of Use). This may include biographical information, contact details and any photographs that you upload. 
·       any data you submit to us when you correspond with us or contact us in any manner. The information you provide to us will depend upon the circumstances, but may include your name, address, e-mail address and phone number and technical details of the device that you use to operate the Sweatcoin App.  
·       other information you provide to us in connection with your use of the Sweatcoin App and SweatCo Website(s), such as your consents, preferences and feedback, and technical and bug fixing information.
 
Information we collect about you and your devices: When you register as a user of the Sweatcoin App, use the Sweatcoin App or visit the SweatCo Website(s) we may collect the following information:

·       industry-standard log data about the device type, browser and operating system you are using and your IP address at the time of the creation of your user account. We may also collect the IP address associated with your device running the Sweatcoin App each time the Sweatcoin App syncs with our systems. 

·       technical information, including the type of mobile device you use, software version, details of your browser, unique device identifiers, mobile network information, your mobile operating system, and your time zone setting; 

·       information stored on your device, including contact lists (where you grant the Sweatcoin App access to such information);
·       analytics information relating to your use of the Sweatcoin App and/or SweatCo Website(s), including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access. 
 
Information about your location and movement:   In order for the Sweatcoin App to function properly it needs to monitor and verify the forms of eligible movement undertaken by users of the Sweatcoin App.  
 
When you opt in to allow the Sweatcoin App to track your step-count and GPS/Cell-ID location data using your phone’s in-built sensors, SweatCo will automatically collect information related to your movement and location. This information is stored against your individual user account. SweatCo will use this information to accurately attribute eligible movement and Sweatcoins to your account. 
 
You can turn location monitoring on and off using the settings of your operating system of your mobile device. Where you disable this functionality we will not be able to collect information relating to your step-count and GPS/Cell-ID location.  This would prevent the tracking and conversion of your movement into Sweatcoins.

 The Sweatcoin App starts collecting location and movement related data as soon as you have created your Sweatcoin account, installed the Sweatcoin App to your mobile device and enabled the Sweatcoin App to access the relevant data. The data collection will continue until you disable, using your mobile device’s operating system, the Sweatcoin App’s access to the GPS and activity data generated by your mobile device, or uninstall the Sweatcoin App.
 

Information we receive from other sources: We may work with third parties from time to time (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. This may include your purchase history from business partners who supply you with rewards made available on the Sweatcoin App.


COOKIES AND ANALYTICS

We use cookies to distinguish you from other users of the Sweatcoin App and SweatCo Website(s) and obtain certain information about your usage and behaviour. A cookie is a small file of letters and numbers that we put on your computer when you use the Sweatcoin App or SweatCo Website(s). This helps us to provide you with a good experience when you use the Sweatcoin App or browse the SweatCo Website(s) and also allows us to improve the Sweatcoin App and SweatCo Website(s). We will use both persistent cookies, which could remain on your device until their expiration (which, in some cases, is up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.
 
The types of cookies we may use include: 
 
·       Analytical/Tracking Cookies: These allow us to recognise and count the number of visitors to and to see how visitors use the SweatCo Website(s) and how users operate the Sweatcoin App, as well as to verify transactions initiated on the Sweatcoin App and completed on the SweatCo Website(s). This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. 
·       Advertising and Retargeting Cookies: These allow us to generate appropriate advertising directed to you on the SweatCo Website(s) as well as on the Sweatcoin App and other third party websites.
 
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.  You may block cookies used by websites by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be able to use all functionality of the SweatCo Website(s).  
 
We use a number of industry-standard data analytics tools, such as Google Analytics and Facebook Analytics. These collect certain information about you, such as your device’s IP address and browsing and usage behaviour, and are used to allow us to track and monitor the traffic visiting the Sweatcoin App and SweatCo Website(s).


USES MADE OF THE INFORMATION DESCRIBED IN THIS POLICY 
We may use your personal data to:
  • provide you with the Sweatcoin     App and identify you as Sweatcoin App user; 
  • populate your user account in     connection with the Sweatcoin App and support the operation of such     account;  
  • verify your physical     movement  and location and issue Sweatcoins     on the basis of this verified data; 
  • analyse the usage of, and     improve, the Sweatcoin App and the SweatCo Website(s); 
  • communicate with you, including,     without limitation, to inform you of updates to the Sweatcoin App, SweatCo     Website(s), and our Terms of Use and Privacy Policy; 
  • perform market and customer     research; 
  • market our services to you; 
  • correct errors and problems     with our services (including the Sweatcoin App and SweatCo Website(s)); 
  • prevent and investigate any     suspected fraud or other criminal activities;  
  • prepare aggregated data in     relation to users of the Sweatcoin App (for example, and without limitation,     the amount of steps completed by all users of the Sweatcoin App, or     particular user groups);   
  • create daily leaderboards of     users, comprising all users, or users meeting particular criteria, ranked     by the number of steps they have completed or other criteria; 
  • operate the Sweatcoin     Marketplace; 
  • investigate any disputes     between users or with you; and   
  • create aggregated data for     commercial purposes, provided that this does not identify you.
Notwithstanding anything to the contrary in this section, we will not use your data related to your levels of physical activity or your health (such as delivered by Apple’s HealthKit or Motion & Fitness APIs or Google’s GoogleFit APIs) for any purpose other than providing health, motion, and/or fitness services in connection with our application (e.g., not for serving advertising).


DISCLOSURE OF YOUR INFORMATION
Except as described in this Privacy Policy, we will not sell your personal data to any third party without your consent. 

We share your personal data with the parties indicated below and for the following reasons:

·       Third party service providers. We share your personal data with authorized third parties: (i) to process or manage your personal data for us so that we may provide the Sweatcoin App and SweatCo Website(s) (including third parties providing the information technology necessary to operate the Sweatcoin App and SweatCo Website(s), such as third party hosting providers) and (ii) to carry out market and customer research. 

·       Strategic partners. We may make available functionality allowing the Sweatcoin App to interact with third party applications that you use, which may include functionality allowing you to share and sync your personal data with such third party applications. Such sharing and syncing will always be initiated by you.  Where you initiate such a process, we will share your personal data with the third party operating the relevant application.  

·       Sweatcoin Marketplace participants:  We may provide users participating in the Sweatcoin Marketplace with aggregated statistics and reports based upon details of the use of the Sweatcoin Marketplace by you and other users. In addition, we or the vendor whose goods you have expressed an interest to purchase might follow-up with you for your feedback on transaction and satisfaction with your desired purchase.

·       Lawful requests. We may disclose your personal data if we are under a duty to disclose or share such data in order to comply with any legal or regulatory obligation or request.

·       Reorganization and mergers. We may disclose your personal data in the event that we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets) or if SweatCo or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

·       Protection of our interests and protection against fraud. We may disclose your data (i)  if this is reasonably required to enforce our Terms of Use or any other agreement we have entered into or to investigate potential breaches; or (ii) if this is required to protect the rights, property or safety of SweatCo, our customers, or others (including by exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction) and (iii) in accordance with applicable laws, to defend our interests or to prevent and combat fraud.

Certain of your personal data may also be shared with other users of the Sweatcoin App as part of the normal operation of the Sweatcoin App. For example, your profile picture and biographical information that you add is accessible to all users. In addition, the Sweatcoin App may publish your total verified steps (or other movement) during a particular period to other users from time to time.  Such details may be displayed in different ways including in rankings of particular user groups.   

For the avoidance of doubt, we will not sell or transfer for consideration your data related to your levels of physical activity or your health (such as delivered by Apple’s HealthKit, Motion & Fitness APIs or Google’s GoogleFit APIs) to a third party without your express consent, and then only for purposes of enabling the third party to provide health, motion, and/or fitness services.

HOW AND WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.  By submitting your personal data, you agree to this transfer, storing or processing. SweatCo will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Our hosting site is located in the United Kingdom. Our systems are firewall protected. We also use encryption techniques and authentication procedures to maintain the security of your personal data and prevent unauthorized access to your Sweatcoin account and our systems.  Authorised SweatCo personnel or authorised third parties who are granted access to personal data are required to keep such data confidential.  You are responsible for keeping your account login details confidential.  

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or from the Sweatcoin App and SweatCo Website(s) via the internet.  

DATA RETENTION

We will keep your information for a reasonable period of time to allow us to make use of it for the purposes described in this Privacy Policy, or as long as the law requires, and in accordance with our data retention policies.

USE OF AGGREGATED DATA

For benchmarking and comparison purposes, as well for research purposes in the health and wellness field, we may collect and analyse aggregated anonymous user data generated by the Sweatcoin App and your mobile device.  Such aggregated data will be anonymous and will not identify you.  We may sell or provide this data to third parties or publish it. 

DATA RELATING TO CHILDREN

We do not knowingly collect personal data of children under the age of 13 and will immediately take steps to delete any such data if any inadvertent collection of such data comes to our attention.  

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by emailing us at support@sweatco.in

If you would like to cancel your Sweatcoin Account, please contact us by using the feedback function or by emailing us at support@sweatco.in and we will take reasonable steps to permanently delete your personal data within a reasonable period and subject to our data retention policies.  Your unique, app-generated user ID (against which Sweatcoins are earned and stored), will be retained and continue to be processed in the event of account cancellation in order to allow the continued operation of the full functionality Sweatcoin App (including transaction histories) for other users.  

LINKS

The Sweatcoin App and SweatCo Website(s) may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

CHANGES TO PRIVACY POLICY

We reserve the right to change our Privacy Policy from time to time.  Any changes we may make to our Privacy Policy in the future will be made available on the SweatCo App and SweatCo Website(s), and may be emailed to our registered users if we so elect (though we do not undertake to do this in all cases). You should therefore check the Privacy Policy available on the SweatCo App and SweatCo Website(s) from time to time.  In the event of any change, by continuing to use the SweatCo App or SweatCo Website(s) you agree to the relevant change.  

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@sweatco.in

 Please use this email address if you wish to opt out from marketing messages issued by us.