AZEOO PERSONAL DATA PROTECTION POLICY

Last update: Juin 2022

The purpose of the present Personal Data Protection Policy is to define the conditions under which the company AZEOO (“AZEOO”, “we”, “us”) ensure the processing of the personal data of the Users of the mobile and web applications (hereinafter referred to together as the “AZEOO Services”);
By using the AZEOO Services, you understand and accept that the AZEOO Services relate to sports programs and workouts, sports and nutritional advice and history, the publication of content, in particular photos, morphological and physiological data, objectives, workouts carried out, comments and other data on social networks and with the AZEOO Community (the “User Content”). This means that other Users can search for and see the User Content that you publish on the AZEOO Services, in accordance with this Personal Data Protection Policy and the AZEOO General Terms of Use (“GTU”).
This Personal Data Protection Policy applies to all Users Athletes,
Coaches, Clubs, natural persons, legal entities, and more generally to
any other person who accesses the AZEOO Services (the “Users”,
“you”)
The use of AZEOO Services by the User implies their consent to the
present Personal Data Protection Policy.

1. Purposes

The purpose of data processing is to make available to Users (Individuals or professionals, Athletes, Clubs and Coaches) by AZEOO, through its mobile applications (Android or Apple versions), the various free and paid functionalities dedicated to sports training and nutrition gathered under the name “AZEOO Services”. The AZEOO application also constitutes a social network allowing each User to publish to all or part of the other Users, all for part of his activity appearing on the AZEOO application.

The data processing allows AZEOO:

To provide Users with secure access to the AZEOO application allowing them to manage an Athlete, Coach or Club Profile (User Profile) and to log in to the various programs (sports training), via their Facebook account or directly on the AZEOO application
To monitor the sporting activity and the performance and nutrition of Users
To provide virtual badges according to the athlete’s sporting activity
To set up a social network allowing Users to exchange by public messages and comments
To locate the User in order to determine the nearest gyms
To interact with Users via connected equipment (watches, bracelets, fitness equipment consoles) subject to their accounting, interoperability with AZEOO Services
To inform Users about AZEOO’s news, and in particular to offer products or services that may or may not be charged
To send by email proposals for services according to the objective mentioned by the user
To improve the services offered by AZEOO.

1.1. Legal basis

The legal basis for the processing of personal data varies according to its nature; some data is collected on a legal contractual basis. Others are collected to meet legal security requirements. Finally, some is collected because you have given us your consent to do so.

2. Processed data

Type of processing carried out: collection, recording, organisation, storage, adaptation, modification, extraction, consultation, use, communication by broadcast transmission or any other form of provision available, comparison or interconnection, blocking, erasure or destruction.

2.1. Categories of data processed

The data processed are on the one hand the User Content, i.e. the information that the User himself will add to access the AZEOO services and when using the AZEOO services (1) and on the other hand the information automatically recorded by the AZEOO application during the use of the AZEOO Services (2).

Identification data of the user, customer or his representative as a natural person including surname, first name, date of birth and gender (1)
Personal details such as email, phone, social network profile and your country of residence (1)
Your physical level (1)
Your objectives for using the AZEOO application (1)
The gym(s) in which you are registered (1)
AZEOO service connection information (2): we collect connection information
on AZEOO applications, information relating to your use of this online service,
including the browser used, dates and times, connection time and frequency,
connection IP address [… to be completed if necessary]
Geolocation information (2): we may collect information about your
geographical location, if you give your consent for this
Photos sent by users (1)
Texts transmitted by users (including messages, publications and comments)
(1)
Sports activity data (1 or 2)
Nutritional data (1) (including foods that the user does not want to eat)
Morphological data (1)
Physiological data (1) (e. g. heart rate).

Activity data is the data used to improve fitness and health management. This data complies with our GDPR and is not used for commercial purposes in any way.

AZEOO uses Google Fit from Google and HealthKit from Apple which provide a central location for storing health and fitness data on the users Android or Apple phone, the data is used if and only if the user agrees, validates their consent.

These sensor apps allow the AZEOO app to communicate with Google Fit and HealthKit to access the following information readings:

The user’s weight
The user’s height
The activities performed by the user (by activity: date, duration, type of activity and calories burned)

This functional element can be deactivated at any time and therefore prevent the reading of the above mentioned information. Under no circumstances should the User provide AZEOO with sensitive data and in particular data related to his/her health within the framework of AZEOO Services.

Under no circumstances may the User provide AZEOO with sensitive data and in particular data related to his health within the framework of the AZEOO Services.

2.2. Data source

This information is collected from users of the AZEOO application or partner gyms.

2.3. Mandatory nature of data collection

The collection of data is mandatory if it is necessary for access to the AZEOO

Services and for the execution of the monitoring carried out by the AZEOO

application. Collection is optional if it involves the consent of the users.

2.4. Automated decision making

The processing involves automated decision-making, the underlying logic of which is as follows: offering customers and users free or paid goods or services and presenting advertisements visible from the application, the proposals and advertisements being based on the use made by users or customers of the AZEOO mobile application and their personal data.

3. Persons concerned

The data processing concerns Users and Customer representatives, i.e. natural persons using the AZEOO application, whether for their personal use or in the context of their salaried or self-employed professional activity.

4. Data Recipients

4.1. Categories of recipients

AZEOO undertakes not to transmit your personal data in any form whatsoever to third parties for a purpose that is not provided for by this Personal Data Protection Policy and that does not appear on the list of the following recipients:

Authorized employees and corporate officers of AZEOO AZEOO’s service providers for the organisation and execution of AZEOO Services and the
establishment of contacts with partner gyms
Our partner gyms
Other Users or Clients
Persons operating Partner Applications, i. e. mobile applications, operated
by third parties, interoperable with the AZEOO Services
The Host for the sole purpose of executing the hosting contract
The possible successor of AZEOO, in the event of transmission by AZEOO to
this successor of all or part of its business assets, including the activity of
operating the AZEOO application
To any third party, upon an injunction from a court or an administrative or
supervisory authority.

Any information or content (User Content or other) that you voluntarily disclose for publication on the AZEOO Services becomes accessible to other Users.Any information or content (User Content or other) that you voluntarily disclose for

publication on the AZEOO Services becomes accessible to other Users.

4.2. Data transfers outside the EU

No data transfers outside the European Union are carried out, except within the framework of the organisation of the hosting of our data, which is carried out on the territory of the United States. In the future, this hosting may also be carried out in whole or in part in Europe or Asia.

5. Data retention time

The data are kept for the entire duration of the Agreement between the customer or user on the one hand, and AZEOO on the other hand, and for a period of 5 years from the closure of AZEOO’s accounts following the termination of the said Agreement. Beyond that, AZEOO will only keep electronic invoices for customers until the end of a period of 10 years from the end of the accounting period following the date of issue of the invoice.

6. Security

AZEOO constantly protects your information.

AZEOO implements all necessary security measures to protect your data against unauthorized access, modification, disclosure or destruction.

These measures include the following:

Secure access to the AZEOO application via a customer/user account or telephone number with password
Encryption of your data in order to guarantee its confidentiality in the context of transfers
Limit the collection of data to that which is strictly useful
No use of the data collected for purposes other than those for which they were collected
Keeping personal data for a limited and proportionate period of time
No transfer of these data to third parties other than those referred to above
Use of a digital data hosting provider (the “Host”) that has made reliable commitments to comply with personal data protection regulations, including the following:
- Security of the Host’s network,
- Physical security of the facilities,
- Access rights control measures for the Host’s and its subcontractors’ employees;
- Process for regularly testing and evaluating the effectiveness
  of the technical and organizational measures implemented by the Host
- Personal data processing, solely for the purpose of the proper performance of the services (no other possible use).
- No transfer of AZEOO data outside countries recognised by the European Commission as having a sufficient level of protection
- To inform the Data Controller of any use of subcontractors who may process his personal data
- To implement high security standards in order to provide a high level of security for its services
- To notify the Data Controller as soon as possible in the event of a breach of its data
- The means to ensure the constant confidentiality, integrity, availability and resilience of the Processing systems and services
- The means of restoring the availability of and access to the Data within appropriate time limits in the event of a physical or technical incident
- A procedure to regularly test, analyse and evaluate the effectiveness of technical and organisational measures to ensure the security of the processing
Unless the User expresses a wish to the contrary in the context of AZEOO Services, access to personal information is strictly reserved for employees, company representatives and subcontractors of AZEOO, who need to access it in order to process it on behalf of AZEOO. Any person having access to it is subject to strict confidentiality obligations and may be subject to disciplinary sanctions up to and including dismissal or cancellation of the service contract in the case of breach of these obligations.

7. Your rights to your personal data

You can access and obtain a copy of your personal data, oppose the processing of this data, have them rectified or deleted. You also have a right to limit the processing of your data.

Each user can rectify or delete the data himself via the AZEOO application.

You can find out more about the CNIL website and in particular via the following link: Understanding your Data Privacy rights.

7.1. Exercise your rights

The AZEOO Data Protection Officer is your contact person for any request to exercise your rights on this processing.

To contact the person in charge by email:contact@azeoo.com
To contact the person in charge by mail :

Le responsable à la protection des données

AZEOO

23 Rue Crépet 69007 Lyon – France BP 12 – 34935 LYON cedex 2, FRANCE

7.2.Claim (complaint) with the CNIL

If, after contacting us, you consider that your rights on your data are not respected, you can send a complaint to the CNIL via the following link: complaint

8. Modifications to the Data Protection Policy

AZEOO reserves the right to modify or update this Privacy Policy at any time,provided that it remains in compliance with current privacy regulations.

In this event, AZEOO will notify Users of these changes by e-mail and by message displayed on the AZEOO Services before they take effect.

By continuing to use the AZEOO Services after any modification of this Privacy Policy and having been informed of these modifications, you signify your acceptance of these modifications.