Zing Coach App Privacy Policy
Introduction
This Privacy Policy explains how Zing Coach, Inc. (further will be referred as “we” or “us”) collects, stores, uses and protects your Personal Data in connection with usage of our website https://zing.coach/ and our application Zing Coach™ (together referred to as the “Services”). This policy also explains your personal data protection rights, and we are happy to help you exercise them. We value your privacy and do our best to ensure its security.
1. What data we collect and why
When you use our Services, we may collect the following data:
| Data category | Collection means | Purpose of collection and processing | Legal basis for collection and processing |
|---|---|---|---|
| Device information (hardware model; device type; unique device identifiers; operating system information; IP address, platform etc.) | Collected automatically | We use such information while analyzing error reports and performing error correction | Art. 6.1 (b) – we perform our contractual obligations |
| Your name and e-mail | You provide it to us | We use such information as part of our onboarding to personalize your experience | Art. 6.1 (b) – we perform our contractual obligations |
| Your name and e-mail | You provide it to us | We use such information to process your requests / comments | Art. 6.1 (f) – we have a legitimate interest to process these data |
| Date of birth | You provide it to us | Since our application is not intended for children under 13 (under 16 in the EU), we use it to comply with our policy | Art. 6.1 (b) – we perform our contractual obligations |
| Date of birth | You provide it to us | We use it for the personalization of your workouts and for our internal analytics | Art. 6.1 (f) – we have a legitimate interest to process these data |
| Health and wellbeing data (weight; height; other information about your health; well-being; and related activities) | You provide it to us | We use it to provide you with our Services | Art. 6.1 (a) – we receive your consent |
All the above data are collectively referred to in this Privacy Policy as “Personal Data”.
2. How long we retain your Personal Data
We retain your Personal Data for as long as your account is active or for as long as it is necessary for the purposes of its collection and processing, unless we are required to retain your Personal Data for a longer period due to applicable legislation requirements, any ongoing dispute resolution or in order to enforce our agreements.
If you choose to delete the application, deactivate your account, we retain your Personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
3. What are your data protection rights?
We want to make sure that you are fully aware of all your data protection rights and they ways you can exercise them. You are entitled to the following:
3.1 The right to access. You can ask us for a confirmation that we process your Personal Data with the information related to its processing.
3.2 The right to data portability. You can request that we provide you with your Personal Data in a structured and portable format. Apart from that, you can ask us to transmit those data to another controller directly, where technically feasible.
3.3 The right to correction. You can ask us to correct your Personal Data if you believe that it might be inaccurate.
3.4 The right to erasure. You may ask us to erase your Personal Data upon your withdrawal of the consent to processing if you believe that such processing is unlawful. You may also ask us to erase your Personal Data in some other cases indicated in art. 17.1 of the GDPR. Please note that erasure of your Personal Data may affect your use of our Services.
3.5 The right to restrict processing. You can request a restriction of your Personal Data processing if you contest the accuracy of your Personal Data.
3.6 The right to object to processing. You can object to the processing of your Personal Data that is processed under certain legal bases - for example, the data that we process under the legitimate interest basis.
3.7 The right to lodge a complaint with your local data protection supervisor. You can do so in case you believe that our activities are not compliant with the applicable data protection regulations. However, if you have such concerns about our data protection activities, we would kindly ask you to first contact us at support@zing.coach and we will do our best to ensure proper handling of your Personal Data.
If you wish to exercise any of the rights 3.1 – 3.6 above, please contact us at support@zing.coach and describe your request in the plain language. If you make a request, we have 30 calendar days to make respective actions in connection with your request. In case we need any more time to help you exercise any of your rights, we will let you know.
In case your request is vague or unclear, we may engage into a conversation with you in order to better understand your request. We may also refuse manifestly unfounded and excessive requests.
We can ask you to prove your identity while exercising your data protection rights. This is made to ensure that you are indeed entitled to receive certain information and that no rights of third parties are violated by your request.
4. Security measures
We take the protection of your Personal Data very seriously and take all reasonable and appropriate measures to protect them from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Among others, we utilize the following information security measures to protect your Personal Data:
a. Encryption of your Personal Data in transit and in rest;
b. Systematic vulnerability scanning and penetration testing;
c. Protection of data integrity;
d. Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the application. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the Services, or that your information won’t be intercepted while being transmitted to us. In case your Personal Data got compromised due to a security breach, we will act promptly to identify the cause and take all reasonable steps to remedy the breach. We will inform you of the incident, if necessary, in connection with the applicable legislation.
If you want to report a security incident related to our Services, please contact us at support@zing.coach.
5. Children’s privacy
We are committed to protecting the privacy of children. We do not knowingly collect Personal Data of any person under the age of 13 (of 16 years old for the residents of the European Union). If you are aware of anyone under 13 (or 16 years old for the residents of the European Union) using the Services, please contact us at support@zing.coach and we will take required steps to delete such information and (or) delete the account.
6. Sharing of your Personal Data
We may use external service providers to process your Personal Data on our behalf. When we do so, we have appropriate agreements in place to protect such data. In the case of international transfers, we always make sure that additional safeguard mechanisms are in place (for example, by adding Standard Contractual Clauses).
Currently we share your Personal Data with the following service providers:
- Infrastructure & security – AWS (Amazon Web Services, Inc.) – based in the USA.Link to the privacy policy: AWS privacy policy
- Analytical tools – Firebase – based in the USA. Link to the privacy policy: Firebase privacy policy
- Analytical tools – Palta Brain (Palta Software Ltd) – based in Cyprus.
7. Changes to our privacy policy
We review our policies regularly to reflect any changes in our collection, processing, sharing or retention procedures as well as any regulatory changes. You can always find the up-to-date version of our Privacy Policy on our website with the indication of the last update date.
Contact Us
Zing Coach, Inc.
Address: 1209 Orange Street, Wilmington, County of New Castle, DE 19801, USA
Email: support@zing.coach
You can also contact our EU representative:
DPOEU LTD
Address: Office 902, Oval, Krinou 3, Ayios Athanasios, 4103, Limassol, Cyprus
Email: info@dpoeu.eu
