SloCoach Privacy Policy

Effective as of 14 April 2016

Welcome to our Privacy Policy. This Privacy Policy helps you to make informed decisions about your relationship with us, so please read it carefully.

1 Introduction

Thanks for choosing SloCoach. This is our Privacy Policy. Before getting into the details, we’d like to highlight some of the key principles behind it. These principles are important to us because we know they’re important to you.

The Privacy Policy is here to do three things:

  1. Explain the way we use information that you share with us in order to build a great product and give you a great experience with it;
  2. Ensure that you understand what information we collect with your permission, and what we do — and do not do — with it;
  3. Hold us accountable for protecting your rights and your privacy under this policy.

All the information we collect is related to providing the SloCoach service and its features.

Broadly speaking, there are two categories of information we collect: 1) information that we must have in order for you to use the SloCoach app and/or website; and 2) information that we can use to provide additional features and improved experiences if you choose to share that information.

The first category includes:

The second category includes information that enables us to offer you additional features. We never receive any of the following information unless you expressly choose to share it with us. It’s as simple as that. Here are some examples:

The distinction between these two categories is important. Information in the first category is information you must provide in order to use SloCoach. When you agree to our Privacy Policy, you give us the right to collect this information and use it for the purposes described. Information in the second category is information we will only collect if you explicitly give us permission to do so in the future. For this second category of information, we will ask for your permission before first accessing it, we will describe how we will use it if you give us permission, we will only use the information for the purpose we described, and you will always have the ability to change your mind and revoke that permission. Acceptance of our Privacy Policy does not mean you have granted us permission to access or use information in the second category; we’re just explaining to you that one day we might ask you for that permission.

We will be clear with you about how and when we might share information.

In some contexts, we will share certain information. For example, like most services, if you sign up for SloCoach through a third party like Facebook or a mobile provider, we share some information with them and they share some information with us in order to enable your account. And we also share de-identified information with our music industry partners to help them understand how the content they license to us is performing, with marketing partners who help us with promotional efforts, and with advertisers that allow us to offer a free service. There also may be times when you want us to share information. For example, when you make playlists, you might want those playlists to be visible to your friends… and you might not. Similarly, you can ask us to share information (like your email address) with artists or record labels, or other partners who may want to directly send you news or promotional offers, but you can also revoke that permission at any time.

We hope this helps you to understand our privacy commitments to you. Now, the details await you below, but please remember that this Introduction is part of the Privacy Policy itself — it’s our promise to you. If you ever have any questions or concerns, then please let us know at info@slocoach.com.au.

Throughout this Privacy Policy we refer to the SloCoach Service or the Service. These terms are defined in our licence conditions (the “Licence Conditions”).

2 Key highlights of what you’re consenting to

By using or interacting with the Service, you are consenting to:

  1. the use of cookies and technologies;
  2. the transfer of your information outside of the country in which you live;
  3. the collection, use, sharing, and other processing of your information, including for advertising-related purposes (as described in the rest of this Privacy Policy, so please keep on reading!); and
  4. the public availability of your information and the controls over such information as described in Sharing Information.

In each case, you consent to the processing of data by the entities described in this Privacy Policy, including the SloCoach entity and any related bodies corporate, as data controller, indicated at the bottom of this document (collectively, “SloCoach”, “we”, “us”, “our”). In the Your Preferences section, we describe the controls and relevant settings associated with your SloCoach account. If you don't agree with the terms of this Privacy Policy, then please don't use the Service.

3 The information we collect

We may collect and store the following information—

3.1 Registration data

When you sign up for the Service, we may ask you for information such as your username, password, email address, date of birth, gender, address, postal code, and country. If you connect to the Service using credentials from a third party application (e.g., Facebook), you authorise us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your third party application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures, and networks.

You may also choose to voluntarily add other information to your profile, such as your mobile phone number and mobile service provider.

3.2 Usage, log data & cookies

When you use or interact with the Service, we may use a variety of technologies that collect information about how the Service is accessed and used. This information may include:

  1. information about your type of subscription and your interactions with the Service, such as sports played, your physical attributes, relevant health and medical data, other audiovisual content, other SloCoach users, third party applications, and advertising, products, and services which are offered, linked to, or made available on or through the Service;
  2. the details of the queries you make and the date and time of your request;
  3. content that you post to the Service including messages you send and/or receive via the Service;
  4. technical data, which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the SloCoach Service, unique device ID, device attributes, network connection type (e.g., WiFi, 4G, LTE) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and SloCoach application version.
  5. motion-generated or orientation-generated mobile sensor data (e.g., accelerometer or gyroscope).

You may integrate your SloCoach account with third party applications. If you do, we may receive similar information related to your interactions with the Service on the third party application, as well as information about your publicly available activity on the third party application. This includes, for example, your “Like” and posts on Facebook. We may use cookies and other technologies to collect this information; you can learn more about such use in the section titled Information about cookies and other technologies below.

3.3 Your mobile device

We may provide features that rely on the use of additional information on your mobile device or require access to certain services on your mobile device that will enhance your SloCoach experience but are not required to use the Service. (In other words, information that falls in the second category described in the Introduction to this Policy.) For example, we might allow you to upload photos or videos, connect with friends, or let you use voice commands to control the Service. Granting us access does not mean you are granting us unlimited access to that information or that we will access specific information without your permission. To the contrary, for each type of information listed in this section, before we access this information or these features of your mobile device, we will ask for your permission. If you provide such permission, we will collect the information for the specific purposes explained at the time we ask for your permission. You do not have to give us such permission in order to use SloCoach, and acceptance of this Privacy Policy does not mean you have granted us permission to access this information.

In particular:

3.4 Widget data

Other websites may integrate SloCoach widgets. When you visit a site with a SloCoach widget embedded, we may receive certain information, including information about the web page you visited. SloCoach and the widget can recognise you, and the widget may be used to show personalised content or advertising. We know when you interact with a widget, and websites containing the widgets may receive this information.

3.5 Payment data

If you sign up for a trial, purchase any of our paid subscriptions, pay for Services, or make other purchases through the Service, your credit or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by us and/or the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to provide the Service. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your card’s type, expiration date, and certain digits of your card number.

If you choose to pay by invoice, SloCoach may need to collect and store additional information, like your name, date of birth, and phone number, and provide it to payment processors we work with to issue invoices, to enable credit checks and to send you invoices.

BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORISE SLOCOACH TO USE AND SHARE WITH OTHER COMPANIES IN THE SLOCOACH GROUP, AS WELL AS CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE OF THE COUNTRY OF YOUR RESIDENCE (INCLUDING COUNTRIES WHICH DO NOT PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO SLOCOACH, EVEN IF SUCH INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION FOR THE PROVISION OF THE SLOCOACH SERVICE AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS UNDER SUCH BANK SECRECY LAWS WITH REGARD TO SLOCOACH, ANY COMPANY IN THE SLOCOACH GROUP, AND ANY TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH SLOCOACH.

3.6 Sweepstakes, contests & surveys

From time to time, we may offer you the opportunity to participate in promotions such as sweepstakes, contests, offers, and/or surveys (“Special Promotions”) through the Service. A Special Promotion may be governed by a privacy policy and/or terms and conditions that are additional to, or separate from, this Privacy Policy and the Licence conditions. If the provisions of the Special Promotion’s privacy policy or terms and conditions conflict with this Privacy Policy or the Licence conditions, those additional or separate provisions shall prevail. If you participate in a Special Promotion, we may ask you for certain information in addition to what is stated in this Privacy Policy, including personal information. That additional information may be combined with other account information and may be used and shared as described in this Privacy Policy.

3.7 SloCoach service providers and partners

We may also receive information about you from our service providers and partners, which we use to personalise your SloCoach experience, to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you. We also use this information as explained in the section Howe we use the information that we collect below.

4 How we use the information we collect

Consistent with the permissions you give us to collect the information, we may use the information we collect, including your personal information:

  1. to provide, personalise, and improve your experience with the Service and products, services, and advertising (including for third party products and services) made available on or outside the Service (including on other sites that you visit), for example by providing customised, personalised, or localised content, recommendations, features, and advertising on or outside of the Service;
  2. to ensure technical functionality of the Service, develop new products and services, and analyse your use of the Service, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Service;
  3. to communicate with you for Service-related or research purposes including via emails, notifications, text messages, or other messages, which you agree to receive;
  4. to communicate with you, either directly or through one of our partners, for marketing and promotional purposes via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your SloCoach account settings); in the section Your preferences below, we inform you of the controls you can use to opt out from receiving certain messages;
  5. to, if you explicitly provide us your permission, use your mobile phone number to send you informational, marketing and promotional text messages using an automatic dialing system; you are not required to provide consent as a condition of signing up for SloCoach’s services;
  6. to enable and promote the Service and other services or products, either within or outside the Service, including features and content of the Service and products and services made available through the Service;
  7. to process your payment or prevent or detect fraud;
  8. to enforce this Privacy Policy, the Licence conditions, and any other terms that you have agreed to, including to protect the rights, property, or safety of SloCoach, its users, or any other person, or the copyright-protected content of the Service;
  9. to provide you with features, information, advertising, or other content which is influenced by your location and your location in relation to other SloCoach users; and
  10. as otherwise stated in this Privacy Policy.

5 Sharing information

This section describes how the information collected or generated through your use of the SloCoach service may be shared by you or by us.

5.1 Sharing by you

5.1.1 Generally

The SloCoach Service is a social service that offers many ways to find, enjoy, and share content. We encourage you to take advantage of these social features with others on the Service. Your name and/or username, profile picture, who you follow, who follows you, and your SloCoach user profile will always be publicly available.

Please remember that certain information is always publicly available, which means that it can be accessed by third party applications. Based on your permissions, some additional information can be shared with third party applications and with others through third party applications. For example, you can use your settings to control whether your SloCoach activity is posted to Facebook. Similarly, you may consent to provide third party applications with access to your email address, subscription status, location, birthday, or similar information, upon their request.

We may use your public information to promote the Service and to help others find and follow you and/or your SloCoach content, including through Facebook and other third party applications and on websites that embed SloCoach widgets. Your information may be used to notify others, including within the Service, via email, and through Facebook and third party applications, about your use of the Service (e.g., that you have joined SloCoach or activity related to a SloCoach profile).

With your explicit permission, we may notify other users of your location. Likewise, with other SloCoach users’ explicit permission, we may notify you about their whereabouts. We may offer you the ability to share this information to create shared experiences.

Learn more about how to manage notifications, your publicly available information, and what you share with others in Your preferences below.

5.1.2 Third party applications

If you connect your SloCoach account to a third party application, SloCoach may automatically share your activity and activity-related stories with that service, including the content you consume. You understand and agree that that such information may be attributed to your account on the third party application and may be published on such service. Although this information may be automatically shared by default, we inform you of the controls that you can use to limit the sharing of this information in the section Your preferences below. The third party application may also provide similar controls.

If you log into a third party application with your SloCoach account, that third party application may have access to certain information such as your content saved, and activity. With your explicit permission, we may also share additional information such as your email address, subscription status, location, or birthdate with such third party applications.

SloCoach also enables you to share a particular item of content that you have created, on an individual basis, to third party applications, other third party services, other SloCoach users, and others. Please note that if you share content to a third party application or a third party service, it will be viewable by others within the SloCoach Service, regardless of your SloCoach account settings.

You understand and agree that a third party application’s use of information collected from you (or as authorised by you) is governed by the third party application’s privacy policies and your settings on the relevant service, and SloCoach’s use of such information is governed by this Privacy Policy and your SloCoach account settings.

5.2 Sharing by SloCoach

5.2.1 Marketing and advertising

We may share information with advertising partners in order to send you promotional communications about SloCoach or to show you more tailored content, including relevant advertising for products and services that may be of interest to you, and to understand how users interact with advertisements. The information we share is in a de-identified format (for example, through the use of hashing) that does not personally identify you.

Please see the section Information about cookies, other technologies and third party data collection below for information about the cookies and other technologies that we and third parties use to serve you more relevant ads and your options.

5.2.2 Service providers and others this Privacy Policy and applicable law. Where a third party processes user data on its own behalf, its processing is subject to its own Privacy Policy and applicable law.

5.2.3 Certain SloCoach partners

If you access the SloCoach Service through an offer that you received or purchased from a third party such as your mobile network operator, we may also share information with that third party about your use of the SloCoach Service, such as whether and to what extent you have used the offer, activated a SloCoach account, or actively used the Service.

5.2.4 Other sharing

In addition to the above, we may also share your information with third parties for these limited purposes:

6 Your preferences

We provide you with settings to allow you to choose which communications you receive from us, manage your public information, and set your sharing preferences. However, as explained in the section Sharing by you, certain information may always be publicly available to others and other information is made publicly available to others by default. And if you share information to a Third party application, that information is viewable on SloCoach, regardless of how you set your privacy settings.

Information that is publicly available may be used, re-shared, or linked to by others on the Service or across the web, so please use SloCoach carefully and be mindful of your settings. Remember that even if you remove an image or make it private, others who already subscribe to it or who otherwise have access to it (e.g., via a link) may still have access to it. Also keep in mind that images and other information added to your profile may include personal information, such as username, which could enable other persons to find you within the SloCoach Service or other services.

7 Transfer to other countries

SloCoach may transfer, process and store information about our users on servers located in a number of countries. Accordingly, SloCoach may share your information with other companies in the SloCoach group in order to carry out the activities specified in this Privacy Policy. SloCoach may also subcontract processing to, or share your information with, third parties located in countries other than your home country. Your personal information may therefore be subject to privacy laws that are different from those in your country of residence.

8 Links

We may display advertisements from third parties and other content that links to third party websites. We cannot control or be held responsible for third parties’ privacy practices and content. Please read their privacy policies to find out how they collect and process your personal information.

9 Security

We are committed to protecting our users’ information. Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and log out after having used the SloCoach Service. While we take data protection precautions, no security measures are completely secure, and we do not guarantee the security of user information.

10 Children

The SloCoach Service is not directed to children under the age of 13. (In some countries, stricter age limits may apply. We do not knowingly collect personal information from children under 13 or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, do not use the Service and do not provide any personal information to us. If you are a parent of a child under the Age Limit and become aware that your child has provided personal information to SloCoach, please contact us at info@slocoach.com.au and you may request exercise of your applicable access, rectification, cancellation, and/or objection rights.

11 Accessing and updating user information

You can view and amend much of the information we keep about you through your account and profile pages. If you have questions about your privacy on the Service, this privacy policy, or information we have about you, please contact us at info@slocoach.com.au. We will respond to your request within a reasonable period of time upon verification of your identity in accordance with local laws. We recommend you include documents that prove your identity and a clear and precise description of the information which you request access to.

12 Changes to the Privacy Policy

Occasionally we may, in our discretion, make changes to this Privacy Policy and other agreements. When we make material changes we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending you an email. In some cases, we will notify you in advance, and your continued use of the Service after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Service under the new version of the agreements, you may terminate the agreements by contacting us at info@slocoach.com.au.

13 Information about cookies, other technologies and third-party data collection

This section describes use of cookies and other technologies. For further information about how information may be shared by SloCoach, please see the section Sharing by SloCoach.

13.1 What are cookies and other technologies?

A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognise your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.

There are also technologies such as mobile device identifiers and SDK integrations to help companies recognise your device when you return to an app or otherwise use the a service.

13.2 How we use cookies and other technologies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them). We may use cookies for essential operations, performance analytics, functionality, targeting advertising, third party users and SloCoach ads.

We also use mobile device identifiers and the other technologies identified in Section 13.1 for the purposes articulated in this Privacy Policy, for example to recognise your device when you return to the SloCoach app or otherwise use the SloCoach Services.

13.3 Manage your cookie and other preferences

Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preferences.

Please note that if you choose to block cookies, doing so may impair the SloCoach Service or prevent certain elements of it from functioning.

On your mobile device, you may also have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.

Please note that even if you opt out using the mechanisms above, you may still receive advertisements when using the SloCoach Service.

You hereby consent to the use of the cookies and other technologies described above.

13.4 More information

For more information about the use of cookies and how to block them, or if you have any questions or comments about our use of cookies, please contact us at info@slocoach.com.au. Thank you for reading our Privacy Policy. We hope you enjoy SloCoach!

We may from time to time share your information with service providers to perform functions and process user data and help provide our Services, consistent with this Privacy Policy. Where a third party processes user data on our behalf (e.g., a hosting service provider), it is subject to security and confidentiality obligations consistent with