Polku Privacy Policy

LAST UPDATED [November 22, 2016]

1. Introduction

Sportsetter (incl. Polku), Inc. (“we, “us) is committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of and any other documents referred to in it) applies to www.polkuapp.com and Polku mobile application(s) (the “Service”) and sets out the basis on which any personal data we collect from you, or that you provide to us, will be handled by us. In this Privacy Policy, the term "personal data" means information that relates to an identified or identifiable natural person.

We know that you, the user of the Service, are concerned about how we use and disclose personal data. We are dedicated to openness regarding the ways in which we use and disclose personal data, and we are committed to complying with data protection and privacy laws that apply to us. Importantly, we want to give you control over personal data that we process about you when you use the Service.

We wish to remind you that this Privacy Policy applies to personal data that we process when you use the Service. It does not apply to any links to third parties' websites and/or services that you may encounter when you use the Service. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

Please be aware that if you utilize the social media functionalities of the Service and/or follow other users of the Service, the other users who follow you or who you have followed will be able to see certain personal data you have submitted to the Service, including for instance the names of other users you follow in the Service, the events you are going to be attending which also discloses information on the Partner Services that you are going to utilize and any commonalities in the reviews and ratings you and other users have submitted to the Service. Therefore, please be careful when sharing personal data about you generally in the Service and with other users of the Service.

BY USING THE SERVICE, YOU ACCEPT THE PRIVACY PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

2. The Data We Collect

In this Section 2 we describe the personal data we collect.

(i) Personal Data You Provide to Us

We may collect the following information from our users that may, in certain circumstances, alone or in connection with other data, constitute personal data:

  • Name
  • E-mail address
  • Date of birth
  • Gender
  • Street address (provided that you give this information)
  • Phone number (provided that you give this information)
  • Profession (provided that you give this information)
  • Zip code and country
  • Payment history (we do not, however, collect credit card numbers)
  • Fitness preferences, such as preferred types of activities and preferred areas
  • Your fitness activities and Partner locations visited
  • Experiences and user reviews relating to the Partner Services provided by third-party Partners
  • Any other personal data you may wish to share with us on generally in the Service

If you use a third party service, such as Facebook Connect, for signing into the Service, we may collect personal data, such as your user ID, name, and e-mail address, that are available in your public profile with the third party service you use for signing into the Service. The Service also includes a “Find People to Follow” feature which enables you to find other users of the Service that you have as Facebook friends.

Moreover, if you contact us, a record of this correspondence may be kept.

(ii) Data Collected Automatically

When you use the Service, we automatically collect data that may in certain circumstances constitute personal data:

  • Technologies such as but without limitation cookies, beacons,pixels, tags and scripts are used by us. These technologies are used to analyze trends, administer the Service, enable features on the Service, track users’ movements around the Service and to gather demographic information about our users. We use technology created by third parties to enable such technological features.
  • We may place a "cookie" on the hard drive of the device that you use to access the Service. Cookies are text files that are saved on the hard drive of your device by means of your browser, enabling us to recognize your browser for purposes such as saving your preferences and directing relevant content to you. Most of the currently available browsers give you the option of managing cookies by, for example, disabling them entirely, accepting them individually, and deleting saved cookies from your hard drive. We would like to remind you that if you completely disable cookies on your browser, you might not be able to use some features of the Service.
  • Device data: We collect information on the device you use to access the Service. This device data may include, without limitation, IDFA and other unique device identifiers, device tokens, device manufacturer and type, information about the operating system of your device, the name of your carrier / internet service provider, connection type, device language, IMEI number, and the Internet Protocol (IP) address from which you access the Service. The logging technology used in the Service may automatically collect the URL of the site from which you came and the site to which you are going when you leave the Service.
  • Usage data: We may collect usage data on your use of the Service, including without limitation information on how long the Service is used per session, which Service screens are opened and for how long are they used and which buttons the user taps in the Polku application.
  • We may collect , use and share location data , including the real-time geographic location of your device, in connection with your use of the Service, for example using satellite, cell phone tower or WiFi signals. We use the location data to provide location-based services and content to you. You acknowledge and agree to the processing of location data in connection with your use of the Service.
  • Google Analytics: Google Analytics is an element of the Service. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the website, the Internet Protocol address, and the type of operating system used in the devices used to access the Service. By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.
  • Other Analytics Service Providers: In addition to Google Analytics, as an element of the Service we may also use other third party data analytics service providers, such as Localytics (www.localytics.com) which help us analyze and improve our Service. The data collected by data analytics service providers enables us to understand usage patterns of the Service. We may permit these service providers to use cookies and other technologies to perform their services for us. Usage information and personal data are stored by such service providers and are subject to their privacy policies. The current list of data analytics service providers we use in connection with the Service can be requested from us at any time by contacting us at info@polkuapp.com.

3. The Purposes for Which We Use the Data

We use the data we collect for the following purposes:

Personal data you provide to the service:

We may use the personal data you provide to the Service for the following purposes:

  • To set up and maintain your registration with the Service;
  • To communicate with you;
  • To provide features available in the Service;
  • To develop, improve, and protect the Service;
  • To process any transactions, you may enter into in the Service;
  • For direct marketing and market research in accordance with applicable law;
  • To prevent and investigate fraud and other misuses; and
  • To protect our rights and/or our property.

Data collected automatically:

We may use the data collected automatically for the following purposes:

  • To manage the Service;
  • To provide features available in the Service;
  • To personalize the Service;
  • To develop, improve, and protect the Service;
  • For market research;
  • To audit and analyze the Service; and
  • To ensure the technical functionality and security of the Service.

4. How We Disclose Data

The data collected in the Service may be disclosed in the following manner:

a) Personal data you provide to the Service:

We may disclose personal data you provide to the Service with the following categories of third parties:

  • To the Partners that we cooperate with who provide you with the Partner Services, in compliance with applicable laws;
  • To our advertising partners in compliance with applicable laws;
  • To service providers, such as payment processors, which enable us to provide the Service to you;
  • To public authorities, such as law enforcement, if we are legally required to so or if we need to protect our rights or the rights of third parties; and
  • To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

b) Data collected automatically:

The data collected automatically in the Service may be disclosed to the following categories of third parties:

  • To the Partners that we cooperate with who provide you with the Partner Services, in compliance with applicable laws;
  • To our advertising partners in compliance with applicable laws;
  • To service providers, such as data analysis companies;
  • To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual users.

5. Your Rights

You have the following rights with respect to the personal data we hold about you:

  • The right to know what data we hold about you: If you have registered with the Service, the easiest way to review the personal data you have provided to the Service is to access your profile. On your profile page you can also make changes to the personal data we hold about you. If you have additional questions regarding the personal data we hold about you, please contact us at info@polkuapp.com. We seek to swiftly respond to your inquiry. We may charge a small processing fee if less than twelve (12) months has passed since your last inquiry relating to personal data we hold about you.
  • The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, deleted, or updated. The easiest way to correct, delete, or update the personal data you have provided to the Service is to access your profile and enter the necessary changes there. If you have additional questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at info@polkuapp.com.
  • The right to opt out of receiving electronic direct marketing communications from us: All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at info@polkuapp.com.

6. Data Security

The security of personal data is important to us. We take reasonable measures to protect personal data about you from unauthorized access or against loss, misuse or alteration by third parties. Despite these efforts to store personal data collected in and through the Service in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.

The credit card data collection uses a 256-bit SSL-encrypted payment form and the data will be forwarded to Braintree payment platform in SSL-encrypted form. No credit card data will be stored in our own systems.

7. Children’s Privacy

The Service may only be used by users who are eighteen (18) years of age or older. Therefore, we do not intend to collect any personal data from children under thirteen (13) years of age. If you are under 13, please do not use the Service and do not send any information about yourself to us.

8. International Transfers of Personal Data

Some elements of the Service may be hosted on servers located in countries outside your own country and in particular outside the European Union. The laws applicable to the protection of personal data in such countries may be different from those applicable in your home country. By using the Service, you consent to personal data about you being transferred outside your own country. In particular, if you are located within the European Union, you consent to your personal data being transferred outside of the European Union.

9. Changes to the Privacy Policy

From time to time we may change this Privacy Policy. You can tell when changes have been made to the Privacy Policy by referring to the "Last Updated" legend on top of this page. If we materially change the ways in which we use and disclose personal data, we will post a notice in the Service and send an e-mail to our registered users. Your continued use of the Service following any changes to this Privacy Policy constitutes your acceptance of any such changes made.

10. Questions or Concerns?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Service, or the protection of the personal data we hold about you, please contact us at info@polkuapp.com. We seek to swiftly resolve any concerns you may have.