Last modified: 10th May 2021
- Information about us
- Use of the Subscription Plan
- Information We Collect
- How We Use Information We Collect
- How we Share Information we Collect
- International Transfer of Information
- Cookies and Similar Technologies
- How to Access & Control Your Personal Data
1. Information about us
You have the right to make a complaint at any time to the Data Protection Commissioner’s Office (DPC), the Irish supervisory authority for data protection issues (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your concerns before you approach the DPC, so please contact us in the first instance.
2. Use of the Subscription Plan
Our Subscription Plan allows any company or individual that uses it to create trainer and business profiles, exercises, workouts, workout programs, training nutrition plans, meal plans and other content. The Subscription Plan can also be used to store, process and analyze the exercise and fitness data of their users. The information added to the Subscription Plan, either by website visitors or app users providing their information or when a Subscription Plan user adds the information, is stored and managed on our service providers’ servers. This information is then used to contact visitors about their interest in the company’s goods or services and invite them to interact with the company, but also to plan their fitness activity, support them during their program, track their progress and provide them with feedback.
Our customers use the Subscription Plan to create trainer and business profiles, exercises, workouts, workout programs, training nutrition plans, meal plans and other content, and to share that information with their users, while tracking their progress.
RYPT acknowledges that you have the right to access your Personal Information, as described below. Our customers control and are responsible for correcting, deleting or updating information they have collected from you using the Subscription Plan. If requested to remove data we will respond within a reasonable time frame. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage. Our agreements with our customers prohibit them from using the Subscription Plan to collect, manage, or process Sensitive Information, as described below. We are not responsible for our customers’ use of information they collect through the Subscription Plan.
RYPT collects information under the direction of its customers, and has no direct relationship with the individuals whose Personal Information it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that uses our Subscription Plan, please contact the customer that you interact with directly. We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
Sensitive Information – this refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.
3. Information We Collect
a. When You Visit our Website
You are free to explore the Site without providing any Personal Information about yourself. When you visit the Site or register for the Subscription Plan, we request that you provide Personal Information about yourself, and we collect Navigational Information.
b. When You Use our Apps
We use mobile analytics software to allow us to better understand the functionality of our Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Site, when you use our Apps we may also collect your city location, device model and version, device identifier (or “UDID”), OS version, and your Subscription Plan credentials.
We send push notifications from time to time in order to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
We may link information we store within the analytics software to Personal Information you submit within the App. We do this to improve services we offer you and improve our marketing, analytics and site functionality.
c. Personal Information
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, business name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Website, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter, and Google, or publicly available information that we acquire from service providers.
Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below.
We collect and process payment information from you when you subscribe to the Subscription Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.
d. Log Files
When you use our website, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by RYPT for the operation of the Subscription Plan, to maintain quality of the Subscription Plan, and to provide general statistics regarding use of the RYPT Site. For these purposes, we link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
e. Information About Children
The Site is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us here, so that we may delete the information.
4. How We Use Information We Collect
We will never sell your Personal Information to any third party.b. Use of Personal Information
- improve your browsing experience by personalizing the Website and to improve the Subscription Plan;
- send information or content to you which we think may be of interest to you by email, or other means and send you marketing communications relating to our business;
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- provide other companies with statistical information about our users – but this information will not be used to identify any individual user;
- meet legal requirements
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
We use the information collected through our Subscription Plan by our customers for the following purposes:
- to provide the Subscription Plan (which may include the detection, prevention and resolution of security and technical issues);
- to respond to customer support requests; and,
- otherwise to fulfill the obligations under the Customer Terms of Service.
c. Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/customer located in the European Economic Area (“EEA”), Flamenco IL Holdings Limited is the data controller of your personal information. RYPT’s Data Protection Officer can be contacted at email@example.com.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
d. Use of Navigational Information
We use Navigational Information to operate and improve the Site and the Subscription Plan. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about RYPT.
e. Customer Testimonials and Comments
We post customer testimonials and comments on our Site, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
f. Use of Credit Card Information
If you give us credit card information, we use it solely to collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
g. Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
h. Social Media Features
i. Third Party Links
j. Public Forums
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Site if you so request, as described in “Opting Out and Unsubscribing” below.
k. Retention of Personal Information
How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymise your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Plan, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.
If you provide information to our customers as part of their use of the Subscription Plan, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Subscription Plan, then we will provide the customer with access to all information stored for the customer by the Subscription Plan, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Plan.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, or products, such as when you last opened an email from us or ceased using your RYPT account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
5. How we Share Information we Collect
a. Service Providers
We may employ other companies and people to provide services to visitors to our Site and our Subscription Plan customers, and may need to share your information with them to provide information, products or services to you. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
c. Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by RYPT on the Website and the Subscription Plan. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
d. Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
6. International Transfer of Information
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us here if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Cookies and Similar Technologies
8. How to Access & Control Your Personal Data
a. Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your personal information.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information.
To exercise any of these rights, please contact us here or by mail to Flamenco IL Holdings Limited, 31 Tivoli Terrace East, Dun Laoghaire, Co. Dublin, A96 EK63, Ireland, Attn: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable time frame and notify you of the action we have taken.
b. Anti-Spam Policy
Our Acceptable Use Terms, available at https://www.rypt.app/customer-terms-of-use, Section 2 (d), applies to our customers and, among other things, prohibits use of the Subscription Plan to send unsolicited communications in violation of applicable laws. We require all of our customers to agree to adhere to the Acceptable Use Terms at all times, and any violations of the Acceptable Use Terms by a customer can result in immediate suspension or termination of the Subscription Plan.
c. To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences. Customers cannot opt-out of receiving transactional emails related to their account with us or the Subscription Plan.
d. To Unsubscribe from Our Customers’ Communications
Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers’ marketing communications by contacting them directly.
Copyright 2019 RYPT. All rights reserved.
Data Protection Officer (DPO) – Daniel O’Beirne
Contact us here.
Flamenco IL Holdings Limited, Dublin, Ireland.