We, the team of Inspiration Labs OÜ (16189790), based at the address Lõõtsa tn 5 Lasnamäe linnaosa, Tallinn Harju maakond 11415 („I'M Inspiration”) email address: [email protected] („Email Address”), process your personal data when you use our app („App”) or website („Website” and, together with the Apps, „Products”). The processing of your personal data takes place in compliance with the General Data Protection Regulation („GDPR“).
Controller. The controller of data processing is I'M Inspiration. You can contact us via email under the Email Address.
WHICH DATA WE COLLECT AND PROCESS
In General. I'M Inspiration processes personal data that you as a user of the Products make available to us, for example by using our Products, and that others provide to us („Data”).
Data You Provide to Us.
Mandatory Information: You have to provide us with certain information in order to register with us:
first and last name;
Optional Information: Certain information is optional during registration and can also be added or deleted later on by you.
Health & Fitness Activity Information
personal goals: e.g. yearly running goal;
training plan information: e.g. start date, training plan, associated fitness activities;
event participation: e.g. event name, time, location;
equipment information: e.g. watch information (brand, model).
Payment and Subscription Information. We use payment providers (e.g. PayU) to process payments. Although we do not store any credit card information ourselves, we store a payment ID number that is given out by the respective provider and can be allocated to a person by that payment provider, as well as duration of your subscription, price, currency, VAT (based on country info), and payment provider.
Google Analytics for Mobile
General. For Apps on iOS and Android we use Google’s Google Analytics for Mobile (for more information see here ). User data is transmitted in an anonymized form to Google. Our Apps use identification for mobile devices, including the Google Advertising ID (“GAID”) and the ID for Advertising for iOS (“IDFA”), as well as technologies similar to cookies for the use execution of the Analytics for mobile service.
Purpose. UWe use Google Analytics to analyze and constantly improve the use of our Products. Through the statistics we are able to improve our services and make them more interesting for users. In those special cases in which personal data is transmitted to the USA, Google is certified via EU-US privacy shield. The basis for the processing of Data are our legitimate interests.
Google DoubleClick for Publishers
For Apps on iOS and Android we use Facebook Analytics (for more information see here ). This allows us to us to track and analyze which marketing channels or sources, in connection with Facebook, are producing the best results for directing users to download the Products and to help us understand how our users are using our app. For this purpose, Facebook Analytics processes mobile identifiers such as the IDFA, GAID or similar mobile identifiers. For more information on Facebook Analytics, see here. The basis for the processing of Data are our legitimate interests.
Cookies and Similar Technologies.
What Are Cookies. The Website uses 'cookies' – small text files that are placed on your computer, mobile device and/or stored by the browser. The basis for the processing of Data via cookies are our legitimate interests.
Device and Location Information.
When you visit or leave our Products, we receive:
the URL of both the site you came from and the one you go to next, as well as date and time stamp and time zone;
IP address, access status/HTTP status code;
transmitted data volume;
proxy server, operating system, web browser (including language and version of the browser software) and add-ons;
device identifier and features;
ISP or your mobile carrier;
GPS information or other phone-related location data (e.g. via WiFi or Bluetooth), after your explicit opt-in.
WHY WE PROCESS DATA (“PURPOSES”)
Operating the Products. We process your Data to be able to provide you with a seamless user experience when using the Products.
Providing Services. To operate the Products and provide the services, including to:
authenticate your access to an account;
track and display your health and fitness activities;
show your training progress and statistics.
Business Needs. We process your Data to manage our business needs.
Performance. We process Data to monitor, analyse and improve the use of our Products, as well as protect the security or integrity of the Products, and their performance and functionality. For example, we analyze user behaviour and perform research about the way you use our Products.
Research and Development. We process Data, including public feedback, to conduct research for the further development of our Products, in order to provide you and others with a better, more intuitive and personalized experience, and drive user growth and engagement in our Products.
Advertising. We target and measure the performance of ads to registered users and visitors directly or through DFP (see 3.4 above) using the following data, whether separately or combined:
Marketing General. We process Data to deliver (tailored) marketing materials about I'M Inspiration products and online services to you.
Email/Push Message Marketing. With your explicit consent we will send you marketing emails or push messages with information on fitness and health-related topics. We will ask you to confirm your email address before you receive any marketing emails. We would like to inform you that we assess your user behavior when reading the emails with the help of so-called web beacons or tracking pixels. The information created by this is then linked to the information collected in 3.6, your email address, and an individual ID. With this merged information, we can create a user profile to personalize our marketing emails / push messages. We collect data on when you read our emails, or which links you click, and combine this with your actions in the Product. We store and use your Data for the purpose of email marketing or marketing on the Website by I'M Inspiration. You can revoke your consent to the marketing emails and push messages at any time, by clicking the link at the end of the email or changing your privacy settings concerning push messages. We store the tracking information as long as you are subscribed to our marketing emails.
Retargeting. NYou might see marketing messages (ads) on the platforms listed below, if you give us your explicit consent to share your advertising identifier (IDFA, GAID) with those platforms. In addition, other users who have similar characteristics to you on those platforms could see marketing messages on those platforms as well (i.e. Facebook Lookalike audience). An opt-out is possible at any time in your privacy settings. It may take a few days after the opt-out until you are removed from all audiences.
List of other platforms: Facebook, Instagram, Google, Twitter, Snapchat, MyTarget and Pinterest.
Compliance and Enforcement.
Compliance. We process your Data to comply with our obligations and in compliance with all applicable laws and regulations.
SHARING OF PERSONAL DATA
We share Data with third parties,
if this is necessary, for the Purposes,
due to a request from a national authority,
due to a court ruling,
if required by law,
if necessary to investigate and defend ourselves against any third-party claims or allegations,
o exercise or protect the rights and safety of I'M Inspiration, our members, personnel, or
if you have (explicitly) consented beforehand.
We attempt to notify you about legal demands for your Data when we think it is appropriate, unless prohibited by law or court order, or when the request is an emergency. We may dispute such demands when we believe that the requests are overbroad, vague or lack proper authority. Special categories of personal data will never be shared with advertisers or similar agencies.
Service Providers and Other Third Party Services.
Service Providers. We share your information to others, who help us provide and improve our Products (e.g. maintenance, analysis, audit, payments, fraud detection, marketing and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf, and are obligated not to disclose or use it for other purposes. We use processors such as Google, Facebook or Zendesk, Inc..
HOW LONG WE STORE DATA
Storage Period. We store your Data as long as you are a registered user of the Products. Beyond that, we only store Data, if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.
Account Deletion. If you decide to delete your account, all data we have about you will be deleted, including keys used for registration via Google/Facebook/Apple ID. To delete an account, you have to send us an e-mail with a request to delete the account to the following address: [email protected]
Any Data required for I'M Inspiration’s performance of contractual obligations or compliance with statutory retention obligations shall not be deleted, but minimized to the necessary extent.
A deletion request does not affect Data, if the storage is legally necessary, for example for accounting purposes.
WHICH RIGHTS YOU HAVE
Exercise your Rights. To exercise your rights defined in sections 7.2 to 7.8, please send a request via email to the Email Address or via mail to our postal address.
Revocation of Consent. You can revoke your consent – in those cases where consent for processing is necessary – for future data processing at any time. However, this does not affect the lawfulness of Data processing based on the consent before the revocation. In certain cases, we may continue to process your information after you have withdrawn consent, if we have another legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
Right of Access. You have the right to obtain (i) confirmation as to whether or not your Data is being processed by us and, if so, (ii) more specific information on the Data. The more specific information concerns, among other things, processing purposes, categories of Data, potential recipients, or the duration of storage.
Right to Rectification. You have the right to obtain the rectification of inaccurate Data concerning you from us. In case the Data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification. Please note that (i) you can rectify much of your information in the settings and (ii) it is not technically possible for us to rectify all kinds of data in our Product.
Right to Erasure. You have the right to delete Data we store about you. Should you decide to do so, please go to your account settings on the Website and delete your account there. If you are unable to do this, please contact us via the Email Address. As a safety measure, we will send you an email in order for you to confirm this deletion. We will delete your Data after this confirmation. Please note that your phone may still have Data stored on it after deletion of your account.
Right to Restriction of Processing. You have the right to obtain a restriction of processing of your Data from us in the following cases:
you make an inquiry pursuant para. 7.4, if you so request;
you are of the opinion that the processing of your Data is unlawful, but are opposed to an erasure of Data;
you still require the Data for the establishment, exercise or defense of legal claims; or
you have objected to the processing pursuant para. 7.8.
Right to Data Portability. You have the right to (i) receive a copy of your Data in a structured, commonly used and machine-readable format and (ii) transmit those Data to another controller without hindrance from us. You can download a copy of your Data in your account settings on the Website.
Right to Object. You have the right to object at any time to the processing of Data for which our legitimate interests are the legal basis, including profiling based on those provisions. You also have the right to object to processing of Data for direct marketing purposes.
Right to File a Complaint. You have the right to file a complaint with your local supervisory authority, if you think that the processing of Data infringes applicable law.
FURTHER IMPORTANT INFORMATION
Legal Bases. Data protection laws regulate that we are only allowed to collect and process your Data, if we have lawful bases for processing. The lawfulness of processing of Data stems from:
your (explicit) consent in cases where you have given (explicit) consent to the processing;
the necessity for the performance of your user contract, e.g. where Data is needed for a satisfactory use of the Product; or
Our legitimate interests include protecting you, I'M Inspiration, or others from security threats or fraud, complying with all applicable laws, managing and improving our business (e.g. customer service, reporting) including possible corporate transactions (e.g. M&A), enabling users to share their and connect via their fitness experiences, and express all fitness and health-related opinions.
Security Measures. We are committed to protecting your Data and implement appropriate technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage. Those security measures are constantly revised to comply with the latest technological developments.
Material Changes. If we make material changes to it, we will provide notice directly in our Products, or by other means (e.g. via email), to offer you the opportunity to review the changes before they become effective. Material changes could, for example, include further tracking, profiling, and analytics services. Should your consent be necessary, we will ask for it before the changes become effective. If you object to any changes, you may need to close your account as it might not function properly.