Platysens Privacy Policy

Effective: May 25th, 2018

Who We Are

We are Platysens Limited (“Platysens”) and our mission to to help our customers (“Athletes”) improve their performance through the collection and analysis of their performance data. Our mission includes our offline activities, connected devices, events and extends to our online acitivity including applications, web platforms and services (which will be collectively referred to as “Services”).

Information We Collect
Platysens collects information to operate our business and provide you with sports and wellness related services. We collect both Personal Data and Other Information in support of these efforts.

“Personal Data” is information that can be used, directly or indirectly, alone or together with other information, to identify you as an individual Athlete. This may include your precise Location Data and your Performance Data.

“Other Information” is information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity. We collect and use this information to understand how you and our community as a whole use our Services and constantly enhance, innovate and build products and services to reflect the needs of Athletes.

Generally, we do not consider Other Information to be Personal Data. Regardless, if we link together Other Information in a way that renders it individually identifiable, we will treat the combined information as Personal Data.

We collect Personal Data in the following ways:

    • When you register with us, we collect registration and demographic details (.e.g., name, username and password, email address, year of birth, and location).
      When you set up an account, we will collect your name, username and password, email address, year of birth, and location (e.g., country). We may also collect your postal code, contact number and information about your mobile device. In addition, we may collect certain demographic information at registration to tailor our Services to your needs, such as age, gender and physical characteristics.
    • When you use or interact with our Services, we collect Personal Data such as Performance Data and Location Data.
      • Performance Data: We collect your Performance Data to help you track your fitness,  activity levels, goals and progress, to provide you with feedback (such as training and product recommendations) and to help us run our business.
        • We collect Performance Data in several ways:
          1. when you input the data manually into the Services,
          2. when you employ features in the Services that are designed to capture the data,
          3. when you leverage technologies that integrate/connect with our Services, such as certain mobile applications, wearables, or other fitness technologies (such as activity trackers, heart rate monitors, pedometers, and the like) that share Performance Data with our Services, and
          4. when we calculate additional information from Performance Data you have previously provided (such as when we analyze performance over time).
        • Here are some examples of Performance Data we collect:
          1. Information about your physical traits, such as height, weight, body measurements and age;
          2. Data about athletic performance, such as time spent doing an activity, speed, distance, and heart rate;
      • Location Data: We may collect precise location data as part of the functionality of our Services. For example, if you want to map your swimming route, we will collect your Location Data as you cycle along the route and produce a map for you. We collect Location Data through the Services so we can offer you certain location-based services (like route tracking described above), provide advertisements that are relevant to your geographic location, and conduct analytics to improve the Services.
        • We collect Location Data in several ways:
          1. through a device you have connected (for example, wirelessly) to our Services, and
          2. directly from the device on which you use our Services.
      • Other Information: We may collect Other Information about your use of our Services. This includes, for example, your device type, carrier provider, browser type, operating system, internet domain and host name, date and time of access as well as referring and onward URL, as well as transactional data about the activities you undertake and how you interact with the Services, such as what data is displayed, clicked on or shared, the click stream patterns, and the length of time spent on each site or page; and searches you may conduct on the Services.
    • When we provide you access to third-party products and services.
      If you are accessing third-party products and services that we have made available to you via the Services, we may collect your name, email address, city, fitness preferences, and more, in connection with your registration for and access to those products and services. We will only collect and share Personal Data with third parties with your permission.

How We Use Personal Data
Platysens uses the data we collect to operate our business, and provide our products and Services, improve existing products and services, develop new products and services, and to improve and personalize your experiences interacting with us. We also use your Personal Data to communicate with you.
We use the information we collect to:

1. Operate our business and provide our Services to Athletes, individuals and communities

We use the data we collect to provide the Services that we offer. This includes operating, maintaining, and providing you with all of the content and features of the Services. For example, tracking your fitness goals and processing your payment for purchases. We also use the data that we collect for our internal business operations. For example, we use data to better understand our business,  and to develop new products and Services to support your fitness, wellness, and nutritional goals. We may also use the data to track, for example, the total number of visitors to or users of the Services, the number of visitors to each page of the Services, and the domain names of our visitors’ Internet service providers to analyze our business operations and performance.

2. Personalize experiences on our Services, better understand our Athletes

We use the Personal Data we collect to personalize your experience with our Services. This allows us to present products and information tailored to you, your interests and location, and to provide you with specialized route and event content based on your location. Our use of Personal Data will also allow you to participate in social sharing on our Services, connect and communicate with other users of our Services, and to create and manage your account. We also use Personal Data to better understand our Athletes and the people who use our Services. This helps us to innovate, plan and design new products, services, features and functionality that our Athletes need and want.

3. Provide you with access to third-party products and services

We use the data we collect to provide third parties with the information necessary to enable those third parties’ fulfillment of the products or services that an Athlete has requested. We also use the data to better understand Athlete preferences and to enhance our Services. In addition, we may use the data within our Services to assist Athletes in meeting their wellness and fitness goals.

4. Support research and academic research

We and our business partners may use the Personal Data and Other Information we collect to conduct commercial or academic research on demographics, interests, and consumer preferences to gain insights about our Athletes, the products and services Athletes use and also to develop innovative products and services for our Athletes. This analysis may be leveraged and shared outside of Platysens. This research may be compiled and analyzed by Platysens, one of our business partners or a third-party on an aggregate or de-identified basis in a way that does not identify you personally.

5. Address security issues and to resolve disputes

We use the data we collect, including Personal Data in some cases, to protect the security of our Services, employees and users, to detect and prevent fraud, to resolve disputes and to enforce our agreements and contractual commitments.

6. Tailor our advertising and marketing

We use Personal Data and Other Information to assist us in our advertising and marketing campaigns, to provide you with information on the products and Services that we think are most relevant to you and to enable us to measure the success of our marketing activities.

7. Communicate with you and respond to your requests

After you have registered or created an account with us, you have a choice of receiving announcements via email about us, our products, Services, special events or promotions. If you consent to such messages, we may use your Personal Data and Other Information to communicate with you about the Platysens products or Services you have purchased or used and to notify you of other products, promotions and Services we think may be of interest to you. You can manage your communication preferences by registering for and logging into your account. We may use your Personal Data to respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.
Please note that irrespective of your email settings, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to products or Services you have purchased or use.

How We Disclose Personal Data
Platysens will only disclose your Personal Data with your knowledge and as stated in this Privacy Policy or as indicated at the time of collection. This includes disclosures that will enable us to fulfill our obligations to you, and allows us to manage our business operations. We will only share your Personal Data with third parties in certain limited instances, namely with your consent, or as is necessary to complete a transaction or provide a product, service, or feature that you have requested.

We may disclose your Personal Data as described in this Privacy Policy and in the following ways:

1. To Affiliates, Partners, Vendors, and Suppliers

We share Personal Data within our company. We do this to run our business more efficiently and to have a better understanding of our Athletes across all of our business lines. We also work with partners, vendors, distributors, and suppliers. These third parties may have access to or process your Personal Data, but only to the extent it is necessary for them to (1) provide their products and services to us, or (2) to provide you the products and services that you have requested. For example, we may use third-party providers to assist us with marketing and advertising our products and Services, delivering customer service and support (for example, when you have a question, complaint or technical issue with your account), and for e-commerce order fulfilment.

2. To Enable the Use of Our Services

Personal Data that is collected through the Services may be used or disclosed to third parties in order to enable us to provide Services. For example, the Platysens website may allow you to interface with a third-party website or application. In addition, with your knowledge and consent, our Services may gather and transfer information from other applications, functions and tools within your mobile device.

3. As We Grow and Change – Corporate Transactions and Reorganizations

If we should ever merge with another company, or if Platysens should decide to buy, sell, or reorganize some part or all of its business, we may disclose or transfer, to the extent permitted by law and in compliance with any applicable requirements to notify you, your Personal Data to prospective or actual purchasers or successor entities in connection with one of these transactions or reorganizations.

4. As Required by Law and Special Circumstances

We may be required to disclose your Personal Data if: (i) it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority, (ii) such a disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) it is necessary to protect our legal rights or property, or (iv) it is necessary to protect the legal rights or property or physical security of others, or for the prevention or detection of crime and such disclosure is lawful.

Information Security
Platysens is committed to protecting the security of your Personal Data. We use technical and organizational measures designed to protect your information against unauthorized access, theft, and loss. We also recommend that you take additional measures to protect yourself and your information, such as installing anti-virus software, closing browsers after use, keeping confidential your log-in credentials and passwords, and making sure that you regularly update software and apps you have downloaded to ensure you have enabled the latest security features on your devices.

Data Retention
Platysens will retain your Personal Data for as long as you maintain an Account or as needed to provide you the Services. We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How We Use Data Collection Tools and Online Advertising
Platysens uses cookies and other data collection tools like web beacons to collect data that help us personalize your use of our websites and mobile applications. We also work with a variety of advertisers, advertising networks, advertising servers, and analytics companies (“Ad Partners”) that use various technologies including cookies to collect data about your use of the Services (such as pages visited, ads viewed or clicked on) so that we and our Ad Partners deliver ads to you based on your interests and online activities.

1. Information about Cookies

“Cookies” are data files stored within your browser when you interact with a website. These data files allow the site to recall important information about your visit and help improve your experience. By using this technology, we are able to make it easier for visitors to register for accounts, order products, enter and participate in sweepstakes and contests, and offer other functionality on our sites, like showing you ads based on your interests or browsing history. For sites that permit online shopping, we use cookies to remember and process the items in your shopping cart.
We also use cookies to collect information about which device and browser you use to access our sites so we can optimize your access and continually improve functionality. We also keep aggregated statistics about the visitors to our sites to help us continually improve how we deliver our online content. For example, we can determine if more visitors prefer certain features or pages to others, which helps us keep our sites fresh and interesting to Athletes.

2. Types of Cookies We Use

We use several different types of cookies:
Required
Strictly necessary cookies: these are cookies that are required for the operation of our websites. Without them, for example, you would not be able to register or log in for any Services that we may offer.
Functional
Analytical/performance cookies: these cookies allow us to recognize and count the number of visitors and to see how visitors move around our websites. These helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily and do not encounter technical errors.
Functionality cookies: these are used to recognize you when you return to our websites. Usage of cookies of this character enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).
Advertising
Targeting cookies: these cookies record your visit to our websites, the pages you have visited and the links you have followed. Usage of cookies of this character helps us and our Ad Partners to deliver ads or messages that are relevant to you and your interests. We may also share this information with third parties for this purpose. For example, these cookies allow us to identify and send you messages about items you have left in your cart and make other purchasing recommendations.
Interaction cookies: because we are interested in your opinion about our brand and items, we use interaction cookies. These cookies allow us to communicate. For example, these cookies allow you to “like” us or recommend us on social media. These social media interaction cookies may collect information about your visit even though you do not interact with them.

3. How We Use Web Beacons

Some of our websites and Services such as e-mail updates may contain electronic images called “web beacons” (sometimes known as one pixel GIFs, clear GIFs or pixel tags). Web beacons allow us to count visitors who have viewed content on websites or pages. In promotional e-mail messages and newsletters, web beacons allow us to count how many subscribers have read them. They also allow us to develop statistical information about the activities and features that most interest our Athletes in order to provide more personalized content. We do not use web beacons to access your Personal Data without your consent.

4. We Allow Third-Party Cookies

We may allow third parties to use cookies and to advertise on our Services. We do not control the cookies of third parties. There are free programs you can download from reputable sources that allow you to set your preferences and block the vast majority of third-party cookies.

Managing Your Privacy Settings
We provide you several ways to manage your privacy settings:

1. Update your default settings for in-app data sharing

Platysens apps are designed for your wellness and fitness benefit. By default, all shareable Personal Data are set set as Private. Consent must be given to enable in-app data sharing to third party services or route sharing.

Note: When you share information from our Services externally with a third party service the information you post is governed by their privacy policy and settings.

2. Set your communication preferences

We respect your communication preferences and have created several ways for you to control how Platysens communicates with you:
Email Communication: You may stop receiving promotional email messages from us by following the unsubscribe instructions provided in any such message you receive.
You may also contact us through our support@platysens.com to indicate or update your communication preferences.

Children
Platysens Services are intended for general audiences and are not directed to children under 16. We do not knowingly collect Personal Data from children under 16. If you become aware that a child has provided us with Personal Data without parental consent, please contact us through support@platysens.com. If we become aware that a child under 16 has provided us with Personal Data without parental consent, we will take steps to remove the information and terminate the child’s account.

Country Specific Disclosures
1. Residents of the European Economic Area

We take steps to keep your Personal Data accurate and up to date. If you reside in the European Economic Area, you may request access to, modification, restriction and deletion of the Personal Data that Platysens has collected about you. To access your Personal Data, please contact us through our support@platysens.com or at the address listed below. Platysens will respond to reasonable requests as soon as practicable and in any event, within the time limits prescribed by law.

Data Breach
In the event of a data breach, we will notify the designated privacy authority no later than 72 hours of becoming aware of the breach.

Withdraw consent
You have the right to withdraw consent to this privacy policy.  To withdraw your consent, you may contact us through support@platysens.com specifying your full name, email address and date of withdrawal.  Upon successful processing, a confirmation email will be returned.

Rectify, Restrict, Limit and Delete
You have the right to rectify, restrict, limit or delete most of your information by using the mobile applications or web platforms.  If you are unable to do this with the default interface, please contact support@platysens.com for assistance. We will notify third parties processors who have access to your data of the deletion request.

Access and Portability
You can access your information by using the mobile application or web platform. Data will be provided in machine readable format within 10 working days and you have the right to transmit the data to another data controller. If you require additional access, please contact support@platysens.com

Right to Object
You have the right to object to our processing of your Personal Data, as permitted by law. After which, we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims

2. Residents of California, United States: Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third-party’s direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.
Under Section 1798.83, we currently do not share any Personal Data with third parties for their direct marketing purposes. If we do decide to share your Personal Data with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to our support@platysens.com, or in writing to:

Platysens Limited
Attention: Privacy Officer
Unit 225, Building 12W,
12 Science Park West Avenue,
Shatin, Hong Kong

It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes or for purposes of assisting us with our own marketing.
Additionally, if you are a registered user under the age of 18 and a resident of California, you may request removal of content you have posted to the Services. Requests can be made to our Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third-party we do not own or control may copy the posting and repost it elsewhere.

Third Parties We Don’t Own or Control
Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. We encourage you to read the privacy policies of each and every device, website, and service that you use.

List of Partners or Third Parties who may have access to your Personal Data

Online Store
Stripe https://stripe.com/hk/privacy
Paypal https://www.paypal.com/hk/webapps/mpp/ua/privacy-full
Shopify https://www.shopify.com/legal/privacy

Cloud Computing
AWS https://aws.amazon.com/privacy/

Training or Third Party Platforms (with consent only)
Strava https://www.strava.com/legal/privacy
Swim Smooth  https://www.swimsmooth.guru/privacy/
Swim.com https://www.swim.com/legal
Endomondo https://support.endomondo.com/hc/en-us/articles/201868857-Privacy
Training Peaks https://www.trainingpeaks.com/privacy.html
2Peaks https://2peak.com/2peak/terms.php

Helpdesk
Freshworks https://www.freshworks.com/privacy/

How to Contact Us
If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through our support@platysens.com or write to us at:

Platysens Limited
Attention: Privacy Officer
Unit 225, Building 12W
12 Science Park West Avenue
Shatin, Hong Kong

Privacy Policy Updates
We may update this Privacy Policy from time to time without prior notice. You can determine when this Policy was last revised by checking the Effective Date. We encourage you to periodically review this privacy policy to ensure you understand our privacy practices. If you have a registered account, we may notify you of any changes to our privacy policy via email and we may ask you to affirmatively acknowledge and consent to the changes the next time you use our Services.