1. CATEGORIES OF PERSONAL DATA WE COLLECT

   We collect data you give us voluntarily (for example, when you choose your problem areas or send us an email). We also may receive data about you from third parties (for example, when you sign in via Facebook). Finally, we collect data automatically (for example, your IP address).

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   1. Data you give us

      You provide us information about yourself when you register for and/or use the Service. For example: name, data on physical characteristics (including height, weight, problematic areas of your body), fitness activity data, food preferences (vegetarian/not vegetarian/gluten-free/lactose-free), email address.

      You do not have to give this data to us. You will be able to use the Service even if you do not give this data to us. However, in such case we may not be able to personalize the Service or contact you.

   2. Data provided by third parties

      When you decide to log in using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID. Unless you opt out on the Facebook Login screen, we will also collect other data, such as email address.

      For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the App on their Apps and Websites page.

   3. Data we collect automatically

      1. Data about how you found us

         We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).

      2. Device and Location data.

         We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

      3. Usage data

         We record how you interact with our Service. For example, we log your taps on certain areas of the interface, the features, and content you interact with, workouts you do, the time and duration of your workouts, how often you use the App, how long you are in the app, your training program progress, and your subscription orders. We also record the ads in our App with which you interact (and the Internet links to which those adds lead).

      4. Advertising IDs

         We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

2. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

   We process your personal data:

   1. To provide our Service

      This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

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      To host personal data and enable our App to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.

      To monitor infrastructure and the App’s performance, we use Crashlytics, which is a monitoring service provided by Google. Here’s its Data Collection Policy

      We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase.

   2. To customize your experience

      We process your personal data, such as physical characteristics and food preferences, to adjust the content of the Service and make offers tailored to your personal preferences. As a result of such processing, you get access, for example, to a nutrition plan containing only vegetarian products or a customized meal plan offer (in the in-App chat) tailored for achieving your goals.

   3. To manage your account and provide you with customer support

      We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

   4. To communicate with you regarding your use of our Service

      We communicate with you, for example, by push notifications, via in-App chat. These may include reminders and motivational messages encouraging you to follow your training and nutrition plan, or other information about the App. As a result, you may, for example, receive a push notification every day at a particular time reminding you to work out. To opt out of receiving push notifications, you need to change the settings on your device.

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      The services that we use for this purposes may collect data concerning the date and time when the message was viewed by our App’s users, as well as when they interacted with it, such as by clicking on links included in the message.

      Intercom provides us with message and customer service tools, which enable us to communicate with you within the App. When you chat with us via in-App chat, your information is automatically transferred to Intercom. The transfer is required to enable us to identify (if you shared any name related data with us) and to communicate with you in the in-App chat. Thus, Intercom uses these data to provide and fulfill its services (as set forth in their terms of service). Intercom is EU-US Privacy Shield certified. Read more about Intercom’s approach to privacy in its Privacy Policy.

      To communicate with you we also use Firebase Cloud Messaging and Firebase Notifications, which are message sending services provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our App across platforms such as Android and iOS. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send encouraging messages to users who have recently finished a training program. Google's privacy policy.

      We use Apple Push Notification service (“APNs”), that is a notifications service provided by Apple. APNs allows us to send information to iOS devices. Apple's privacy policy.

   5. To research and analyze your use of the Service

      This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the App and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and training plans of the App our users like more, what categories of users use our App. As a consequence, we often decide how to improve the App based on the results obtained from this processing. For example, if we discover that users more often engage in workouts designated for legs, we may develop and introduce a new workout for this area into the App.

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      To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy policy. Opt Out.

      We use Facebook Analytics, which is a service is provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our app, how often users make purchases, the average weight and height of our users, how many users chose a particular problem area of their body, and other interactions. Privacy policy.

      We also use Amplitude that is an analytics service that we use to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), unique identifiers (such as IDFA). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features should we focus on (for example, if we see that most of the users focus on leg workouts, we may develop more these). Amplitude is EU-US Privacy Shield certified. Amplitude provides more information on how they process data in its Privacy Policy.

      To track and analyze behavior of our App’s users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users). Privacy Policy and Privacy and Security in Firebase.

      We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information. Google’s Privacy Policy.

      To perform standard product analysis, we also use Fabric Answers, which is an analytics service provided by Crashlytics, a business division of Google. Data Processing and Security Terms. Privacy information..

   6. To send you marketing communications

      We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our products, such as for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.

      We may also show you advertisements in our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.

   7. To personalize our ads

      We and our partners, including Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products, for example, in your Facebook’s feed.

      How to opt out or influence personalized advertising

      iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.

      Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).

      To learn even more about how to affect advertising choices on various devices, please look at the information available here.

      In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
      • Network Advertising Initiative – http://optout.networkadvertising.org/
      • Digital Advertising Alliance – http://optout.aboutads.info/
      • Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
      • Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
      • DAA AppChoices page – http://www.aboutads.info/appchoices

      See more

      We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

      We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

      Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

      Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows to us to tailor the ads in way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have purchased a subscription). Some other examples of events that may be used for tailoring ads include, in particular, installing our App, finishing a workout program. Google allows its user to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

      We also use Snapchat Advertising Platform together with Snapchat Audience Based Match, which is an ad delivery service provided by Snapchat that can link the activity of some users of our App with the Snapchat advertising network and show some of our ads to them. As a result, you may see more of ads on Snapchat in case you use our App. Snapchat allows you to Opt Out of their audience based ads. Privacy Policy.

   8. To enforce our Terms and Conditions of Use and to prevent and combat fraud

      We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).

   9. To comply with legal obligations

      We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

   In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

   We process your personal data under the following legal bases:

   1. your consent;
   2. to perform our contract with you;

      Under this legal basis we:
      • Provide our Service (in accordance with our Terms and Conditions of Use)
      • Customize your experience
      • Manage your account and provide you with customer support

   3. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

      We rely on legitimate interests:
      • to communicate with you regarding your use of our Service
      This includes, for example, sending you push notifications reminding you to exercise at appropriate times. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you of following your training and nutrition plan, which may lead you to a better and healthier lifestyle.
      
      • to research and analyze your use of the Service
      Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).
      
      • to send you marketing communications
      The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.
      
      • to personalize our ads
      The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
      
      • to enforce our Terms and Conditions of Use and to prevent and combat fraud
      Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.

4. WITH WHOM WE SHARE YOUR PERSONAL DATA

   We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:

   1. Service providers

      We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:
      • marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Snapchat)
      • data analytics providers (Facebook, Google, Appsflyer, Firebase, Crashlytics, Amplitude, Fabric)
      • cloud storage providers (Amazon)
      • communication services providers (Intercom)

   2. Apple Health Kit or Google Fit (together the “Health App”)

      We share data about your activity with Health App applications installed on your device, provided you gave express permission on your device. Before you decide to share your data with the Health App, we encourage you to review their privacy policy, as your data will be subject to those policies. For more information on the Apple HealthKit, please see http://www.apple.com/ios/health/, and on the Google Fit, please see https://www.google.com/fit/.

   3. Law enforcement agencies and other public authorities

      We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

   4. Third parties as part of a merger or acquisition

      As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

   To be in control of your personal data, you have the following rights:

   Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided to us in the profile section of the App.

   You may also request a copy of your personal data collected during your use of the App at support@betterme.tips. If you have connected your Facebook account to our App or used your email for registration in our App, section “Manage personal data” in the App's settings will be available to you. You may select “Request data” there and receive a download link on your email (please note that the link typically expires over a few days). By clicking on the link, you will download a ZIP archive in a .zip file format; the archive will contain .json files that can be easily opened with a common text editor (for example, Notepad).

   Deleting your personal data. You can request erasure of your personal data by sending us an email at support@betterme.tips. If you have connected your Facebook account or used your email for registration in our App or entered your name in the App, section “Manage personal data” in the App's settings will be available to you. You may select “Remove data” there and we will delete the personal data collected from you.

   When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

   Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by requesting its erasure as described above or sending a request at support@betterme.tips.

   Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above:
   The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
   The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above (or send respective request at support@betterme.tips). The data will be made available to you in the .json file format.

6. AGE LIMITATION

   We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at support@betterme.tips.

7. INTERNATIONAL DATA TRANSFERS

   BetterMe does business globally. We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

   In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Privacy Shield Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).

8. CHANGES TO THIS PRIVACY POLICY

   We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

9. CALIFORNIA PRIVACY RIGHTS

   California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

   To obtain this information from us, please send an email message to support@betterme.tips which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

   Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

10. DATA RETENTION

    We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

11. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

    Except as otherwise stipulated in this Privacy Policy, this App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

12. PERSONAL DATA CONTROLLER

    BetterMe Limited, a company registered in the Republic of Cyprus (with registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus) will be the controller of your personal data.

13. CONTACT US

    You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@betterme.tips.

Effective as of: 17 May 2019