Privacy policy - Extreme Training

This Privacy Policy describes our policies and procedures regarding the collection, use, and disclosure of your data when you use our service, as well as your privacy rights.

We use your personal data to provide and improve our service. By using our service, you agree to the collection and use of your personal data in accordance with this Privacy Policy.

Definitions and Interpretation of Terms

Interpretation
The following definitions apply regardless of whether the terms are used in singular, dual, or plural form.

Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• You refers to the individual who accesses or uses the service, or the company or other legal entity on whose behalf such individual is accessing or using the service. “You” may also, under the GDPR (General Data Protection Regulation), refer to the data subject or user, as you are the individual using the service.

• Company (referred to in this Privacy Policy as “the Company”, “we”, “us”, or “our”) means Extreme Corporation d.o.o., Sermin 75k, SI6000 Koper. Under the GDPR, the Company is the data controller.

• Application means the software named EXTREME TRAINING provided by the Company and downloaded onto any electronic device.

• Affiliate means any entity that controls, is controlled by, or is under common control with the Company, where “control” means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other governing authority.

• Account means a unique account created for you to access our service or parts of our service.

• Service refers to the application.

• Country means Slovenia.

• Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the service, provide the service on the Company’s behalf, perform service-related functions, or assist the Company in analyzing how the service is used. Under GDPR, Service Providers are considered data processors.

• Third-party Social Media Service means any website or social network platform through which a user can log in or create an account to use the service.

• Facebook Fan Page means the public profile named EXTREME TRAINING by Vida Macura, created by the Company on Facebook and available at https://www.facebook.com/ExtremeTrainingByVidaMacura/

• Personal Data means any information relating to an identified or identifiable individual. Under GDPR, Personal Data includes any information relating to you, such as name, identification number, location data, online identifiers, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity. Under the CCPA (California Consumer Privacy Act), Personal Data includes any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you.

• Device means any device that can access the service, such as computers, mobile phones, or tablets.

• Usage Data means data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).

• Data Controller under GDPR means the Company as the legal entity that alone or jointly determines the purposes and means of processing personal data.

• Do Not Track (DNT) is a concept promoted by US regulatory authorities, particularly the Federal Trade Commission (FTC), to allow internet users to control the tracking of their online activities across websites.

• Business under the CCPA means the legal entity that collects consumers’ personal data and determines the purposes and means of processing such data, or on whose behalf such data is collected and which alone or jointly determines the purposes and means of processing personal data of California residents.

• Consumer under the CCPA means a natural person who is a California resident. A resident includes (1) any individual present in the United States for purposes other than temporary or transitory, and (2) any individual domiciled in the United States who is outside the United States for temporary or transitory purposes.

• Sale under the CCPA means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal data to another business or third party for monetary or other valuable consideration.

Collection and Use of Your Personal Data

Types of Data Collected

Personal Data
When using our service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• email address
• first and last name
• phone number
• address, state, province, postal code, and city
• bank account information to process payments for products and/or services within the service
• usage data

When paying for a product and/or service via bank transfer, we may ask you to provide information that identifies you and helps facilitate the transaction. Such information may include, but is not limited to:

• date of birth
• passport number or personal identification card number
• bank card statement
• other information that can be linked to your address

Usage Data
Usage Data is collected automatically when you use the service.

It may include information such as your device’s Internet Protocol (IP) address, browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the service via a mobile device, we may automatically collect certain information, including but not limited to the type of mobile device you use, your mobile device’s unique ID, your mobile device IP address, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, and other diagnostic data.

We may also collect information that your browser sends whenever you visit our service or when you access the service through a mobile device.

Data from Third-Party Social Media Services

The Company allows you to create an account and sign in to the service using the following third-party social media services:

• Google
• Facebook
• Twitter

If you register through these services or otherwise grant us access to them, we may collect personal data already associated with your third-party social media account, such as your name, email address, activities, or contact list linked to that account.

You may also have the option, through your third-party social media account, to share additional information with the Company. If you provide such data or other personal information during registration or otherwise, you consent to the Company’s use, sharing, and storage of that information in accordance with this Privacy Policy.

Data Collected While Using the Application
While using our application, and with your prior consent, we may collect:

• location data
• images and other information from your device’s camera or photo gallery

We use this data to provide application features, as well as to improve and personalize our service. The data may be uploaded to the Company’s servers and/or the servers of a Service Provider, or stored directly on your device.

You may enable or disable access to this data at any time through your device settings.

Use of Your Personal Data

The Company may use your personal data for the following purposes:

• to provide and maintain our service, including monitoring its usage
• to manage your account: to manage your registration as a user of the service. The personal data you provide gives you access to different functionalities of the service available to registered users
• to perform a contract: the development, compliance, and execution of the purchase contract for products, items, or services you have purchased, or any other agreement with us through the service
• to contact you by email, phone calls, SMS, or other equivalent forms of electronic communication, such as mobile app push notifications, regarding updates or informative messages related to functionalities, products, or contracted services, including security updates when necessary or reasonable for their implementation
• to provide you with news, special offers, and general information about other goods, services, or events we offer that are similar to those you have already purchased or inquired about, unless you have opted out of receiving such information
• to manage your requests: to handle and respond to your inquiries sent to us

We may share your personal data in the following circumstances:

• with Service Providers: we may share your personal data with service providers for monitoring and analyzing the use of our service, processing payments, or contacting you
• for business transfers: we may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business by another company
• with Affiliates: we may share your data with our affiliates; in such cases, we will require them to comply with this Privacy Policy. Affiliates include our parent company, subsidiaries, joint ventures, or other companies under common control
• with business partners: we may share your data with our business partners to offer you certain products, services, or promotions
• with other users: when you share personal data or interact in public areas, that information may be viewed and publicly shared by all users. If you interact with other users or register through a third-party social media service, your contacts on that service may see your name, profile, images, and activity description. Similarly, other users may view your activity descriptions, interact with you, and view your profile

By registering in the Extreme Training® application, the user agrees that their email address may be used to send promotional content related to app activities. If the user does not wish to receive such messages, they may unsubscribe at any time by clicking the “Unsubscribe” link included in every email.

The Company will retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when it is used to strengthen security or improve the functionality of our service, or when we are legally required to retain it for a longer period.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s offices and at any other locations where the parties involved in processing are based. This means your data may be transferred to — and maintained on — computers located outside your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your jurisdiction.

Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.

The Company will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to any organization or country unless adequate controls are in place, including measures to ensure the security of your personal data.

Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will notify you before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement
Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or government agency).

Other Legal Requirements
The Company may disclose your Personal Data in good faith if it believes such action is necessary to:

• comply with a legal obligation
• protect and defend the rights or property of the Company
• prevent or investigate possible wrongdoing in connection with the service
• protect the personal safety of users of the service or the public
• protect against legal liability

Security of Your Personal Data
We value the security of your Personal Data, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers may access your personal data only for the purpose of performing their duties on behalf of the Company and are not permitted to disclose or use it for any other purpose.

Email Marketing
• We may use your personal data to send you newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving all or part of these communications by following the unsubscribe link or instructions included in every email we send.

To manage and distribute email communications, we may use third-party email marketing service providers.

o Mailchimp
Mailchimp is an email marketing service provided by The Rocket Science Group LLC.
For more information about Mailchimp’s privacy practices, please refer to their Privacy Policy at: https://mailchimp.com/legal/privacy/

o AWeber
AWeber is an email marketing service provided by AWeber Communications.
For more information about AWeber’s privacy practices, please refer to their Privacy Policy at: https://www.aweber.com/privacy.htm

o GetResponse
GetResponse is an email marketing service provided by GetResponse.
For more information about GetResponse’s privacy practices, please refer to their Privacy Policy at: https://www.getresponse.com/legal/privacy.html

Payments
• Within the service, we may offer paid products and/or services. In such cases, we may use third-party services (e.g. payment processors) to handle payments. We do not collect or store your payment card details. That information is provided directly to third-party payment processors, whose use of your personal data is governed by their own privacy policies. These processors comply with PCI-DSS standards, which are managed by the PCI Security Standards Council, a joint effort by Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

o In-app payments via Apple Store
You can view the Privacy Policy at https://www.apple.com/legal/privacy/en-ww/

o In-app payments via Google Play
You can view the Privacy Policy at https://www.google.com/policies/privacy/

o WePay
You can view the Privacy Policy at https://go.wepay.com/privacy-policy

o PayPal
You can view the Privacy Policy at https://www.paypal.com/webapps/mpp/ua/privacy-full

When paying for a product and/or service via bank transfer, we may ask you to provide information that helps identify you and facilitates the transaction.

Privacy under the General Data Protection Regulation (GDPR)
Legal basis for processing personal data under GDPR

We may process your personal data under the following conditions:

• Consent: you have given your consent for the processing of personal data for one or more specific purposes.
• Performance of a contract: the provision of personal data is necessary for the performance of a contract with you and for any pre-contractual obligations arising from it.
• Legal obligations: processing is necessary to comply with legal obligations to which the Company is subject.
• Vital interests: processing is necessary to protect your vital interests or those of another person.
• Public interest: processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: processing is necessary for the purposes of the legitimate interests pursued by the Company.

The Company will be happy to help clarify the specific legal basis applicable to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR
The Company is committed to respecting the confidentiality of your personal data and ensuring that you can exercise your rights.

In accordance with this Privacy Policy and applicable legislation (if you are located in the EU), you have the right to:

• request access to your personal data. You have the right to access, update, or delete your personal data. Whenever possible, you can access, update, or delete your personal data directly in your account settings. If you are unable to do so, please contact us. This right also allows you to obtain a copy of the personal data we hold about you.

• request correction of your personal data. You have the right to have any incomplete or inaccurate information we hold about you corrected.

• object to the processing of your personal data. This right applies when the legal basis for processing is our legitimate interest, based on your particular situation. You also have the right to object to the processing of your personal data for direct marketing purposes.

• request deletion of your personal data. You have the right to request that we delete or remove your personal data when there is no valid reason for us to continue processing it.

• request data portability. We will provide your personal data to you or to a third party of your choice in a structured, commonly used, and machine-readable format. This right applies only to automated data that you initially consented to or data processed for the performance of a contract with you.

• right to restriction of processing.

• withdraw consent. You have the right to withdraw your consent to the processing of your personal data at any time. If you withdraw your consent, we may no longer be able to provide you access to certain features of the service.

Exercising Your Data Protection Rights under GDPR
You may exercise your rights of access, rectification, and erasure, as well as your right to object, by contacting us. Please note that we may request verification of your identity before responding to such requests. We will make reasonable efforts to respond to your request as soon as possible.

You also have the right to lodge a complaint with a data protection authority regarding our collection and use of your personal data. If you are located in the European Economic Area (EEA), you may contact your local data protection authority for more information.

Facebook Fan Page

Data Controller of the Facebook Fan Page
The Company is the data controller of your personal data collected during the use of the service. The Company and Facebook, in relation to the Facebook Fan Page https://www.facebook.com/ExtremeTrainingByVidaMacura/, act as joint controllers of personal data.

The Company has entered into agreements with Facebook which define, among other things, the terms of use of the Facebook Fan Page. These terms are largely based on Facebook’s terms of service: https://www.getresponse.com/legal/privacy.html

For more information on how Facebook processes personal data, please visit Facebook’s Privacy Policy at https://www.facebook.com/policy.php, contact Facebook via their support hotline, or write to: Facebook, Inc. ATTN: Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, USA.

Facebook Insights
We use Facebook Insights in connection with the operation of the Facebook Fan Page and, under GDPR, to obtain anonymized statistical data about our users.

For this purpose, Facebook places a cookie on the device of a user who visits our Facebook Fan Page. Each cookie contains a unique identifier and remains active for two years unless deleted earlier.

Facebook collects, records, and processes information stored in the cookie, particularly when users visit Facebook services, services provided by other members of the Facebook Fan Page, and services provided by other companies that use Facebook services.

For more information about Facebook’s privacy practices, please refer to their data use policy at: https://www.facebook.com/full_data_use_policy

Privacy under the California Consumer Privacy Act (CCPA)

Your Rights under the CCPA

In accordance with this Privacy Policy and applicable law (if you are a resident of California), you have the following rights:

• right to be informed. You have the right to be properly informed about all categories of personal data collected and the purposes for which it is collected.

• right of access/request. The CCPA allows you to request and obtain information regarding the disclosure of your personal data collected by the Company or its affiliates in the past 12 months, including disclosures to third parties for their direct marketing purposes.

• right to opt out of the sale of personal data. You have the right to request that the Company does not sell your personal data to third parties. Such a request can be submitted via a “Do Not Sell My Personal Information” section or webpage.

• right to know your personal data. You have the right to request and obtain information regarding the disclosure of:
o categories of personal data collected
o sources from which the personal data was collected
o business or commercial purposes for collecting or selling personal data
o categories of third parties with whom we share personal data
o specific pieces of personal data we hold about you

• right to deletion of personal data. You have the right to request deletion of your personal data collected within the last 12 months.

• right to non-discrimination.
o You have the right not to be discriminated against for exercising your consumer rights, including:
o denial of goods or services
o charging different prices or rates for goods and services, including discounts or penalties
o providing a different level or quality of goods or services
o suggesting that you will receive different prices, rates, or quality of goods or services

Exercising Your Data Protection Rights under the CCPA

If you are a resident of California, you may exercise your CCPA rights by contacting us via email, phone, or by visiting our “Do Not Sell My Personal Information” section or webpage.

The Company will disclose and provide the requested information free of charge within 45 days of receiving a verifiable request. This period may be extended once by an additional 45 days if reasonably necessary, provided you are notified in advance.

Do Not Sell My Personal Information

We do not sell personal data. However, service providers we work with (such as our advertising partners) may use technology that constitutes a “sale” of personal data as defined under the CCPA.

To opt out of the use of your personal data for advertising purposes and any potential sale as defined under the CCPA, please follow the instructions below.

Please note that each opt-out is specific to the browser you are using. You may need to opt out separately on each browser you use.

Website
You may opt out of receiving personalized ads provided by our service providers by following the instructions in the service, including:

• the “Cookie Consent” banner
• the “CCPA Opt-Out” banner
• the “Do Not Sell My Personal Information” banner
• the “Do Not Sell My Personal Information” link

By opting out, a cookie will be placed on your device that is specific to the browser you are using. If you change browsers or delete your cookies, you will need to opt out again.

Mobile Devices
Your mobile device may allow you to opt out of the use of information about the apps you use in order to stop receiving targeted advertising:

• “Opt out of interest-based ads” or “Opt out of personalized ads” on Android devices
• “Limit Ad Tracking” on iOS devices

You may also disable location-based information collection on your mobile device by changing your device settings.

Do Not Track Policy as Required by the California Online Privacy Protection Act (CalOPPA)
Our service does not respond to “Do Not Track” (DNT) signals.

However, some third-party websites may track your browsing activity. If you visit such websites, you may set your browser preferences to inform websites that you do not wish to be tracked. You can enable or disable DNT in your browser settings.

Your California Privacy Rights (Shine the Light Law)
California residents who have an established business relationship with us may request information once a year, under California Civil Code Section 1798, about the sharing of their personal data with third parties for direct marketing purposes.

If you are a California resident and would like to learn more about your rights under the “Shine the Light” law, please contact us.

Privacy Rights for Minors in California (California Business and Professions Code Section 22581)
California residents under the age of 18 who are registered users of online services, websites, or applications have the right to request or obtain removal of content or information they have publicly posted.

If you are a California resident and wish to request deletion of such data, please contact us and include the email address associated with your account.

Please note that your request does not guarantee complete or comprehensive removal of content or information posted online, and that in certain circumstances the law may not allow such removal.

Links to Other Websites
Our service may contain links to third-party websites that are not operated by the Company. If you click on a third-party link, you will be redirected to that third-party site. We strongly recommend that you review the privacy policy of every website you visit.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services.

Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

Before the updated Privacy Policy becomes effective and the “Last updated” date is changed at the top, we will notify you via email and/or through a prominent notice within our service.

We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

• Email: info@extremetraining.eu

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