Privacy Policy

PRIVACY NOTICE

This Privacy Notice explains the information Play Coyotta Ltd. (“Play Coyotta”) and its subsidiary BlazePod Inc. (“BlazePod”, “we,” “us”, or “our”) collect from you as you use the BlazePod websites and mobile application (collectively, the “Services”), how we use this information, with whom we share it, and the choices you have in connection with this.

DATA CONTROLLERS

We collect and use your personal information as described in this privacy notice. When you visit our [url for EU website] and/or in our mobile application, your data is collected and processed by PlayCoyotta  as the data controller. When you visit our [URL for US website]. Your data is collected and processed by  BlazePod. The data is then incorporated in a joint Customer relationship management system which is used by Play Coyotta and BlazePod jointly for the purposes set forth in this Privacy Notice. To this end BlazePod and Play Coyotta act as “joint controllers” as such term is defined under the European Data Protection Regulation.  We have reached a joint controllership arrangement which in essence is the following:

- Both BlazePod and Play Coyotta collaborate in the processing activities described in this Privacy Notice and share information with third parties as described in this Privacy Notice; The personal information collected may be used by either BlazePod or PlayCoyotta or both.

- If you have any questions or concerns with respect to this Privacy Notice, or in order to exercise your rights under data protection law, please contact BlazePod at info@blazepod.com. 

- Each of BlazePod and Play Coyotta may engage processors on behalf or for the benefit of the other entity. They will be engaged through an agreement meeting with the terms of Art. 28 of GDPR.

You can contact Play Coyotta at info@BlazePod.com.

You can contact BlazePod at info@BlazePod.com.

 INFORMATION WE COLLECT

Through your use of our Services, we collect personal information, which is information that identifies you as an individual or relates to you as an identifiable individual. We collect personal information directly from you and automatically as you use our Services. 

1. Information You Provide To Us

When you engage with certain features of the Services, we will collect personal information from you. Except as otherwise indicated below, for example in cases where you choose whether to provide information, the personal information you provide is such that we need in order to provide the Services. If you do not provide us with your personal information, we would not be able to do so. Specifically, we collect personal information from you when you: 

• Create a BlazePod account. In order to use BlazePod pods, you will need to download our mobile application and create an account. To create an account, we will collect your personal identifiers (name, email address, and date of birth). While creating an account, you also have the option to provide us with personal identifiers (gender), biometric information (height and weight), visual information (photograph), and your preferences (sports interests). The legal basis for this processing is that it is necessary to perform the contract with you.

As you use the Services, certain information may be inferred from your biometric information, such as benchmarks and how you compare to other users with similar biometric information. We obtain your consent to the collection of your biometric information when you take actions leading to the collection of this biometric information, such as when you provide it to us and use the Services. The legal basis for this processing is your consent. Collection of your biometric information is optional and you can withdraw your consent at any time by deleting your biometric information. 

• Add Additional Content. You have the option to photograph an exercise and upload the photograph and/or video to your BlazePod account. In order to do so, we will collect your visual information (photograph and/or video). When you upload your visual information, the visual information is stored on your device for your own purposes. BlazePod does not use your visual information for any purposes.

• Add BlazePod users.Once your account is created, you have the option to add additional users. To add additional users, we will collect personal identifiers (name) on the additional users. The legal basis for this processing is that it is necessary to perform the contract with you. It is your responsibility to ensure that additional users consent to their information being provided to us.

• Make a purchase. If you make a purchase through the Services, we will collect your personal identifiers (name, email address, physical address, and telephone number) and your payment information (payment card number, CVV, and expiration date). We collect this personal information to process your payment for the requested product or service. This information is collected by our third-party payment processor, Shopify. The legal basis for this processing is that it is necessary for the performance of the contract with you. If you leave unpurchased items in your cart, we will also use this personal information to send you reminder emails about the item(s) that remain in your cart. Our legal basis for this processing is your consent. You can withdraw your consent at any time by clicking the “unsubscribe” link provided with each email.

• Subscribe to our mailing list. When you subscribe to our mailing list, we will collect personal identifiers (email address). We collect this information to fulfill your request to receive updates and exclusive deals from BlazePod. The legal basis for this processing is your consent. Subscribing to our mailing list is optional and you can withdraw your consent at any time by clicking the “unsubscribe” link provided with each email.

• Contact us. When you send us a question or inquiry, or ask for other support, you will need to provide us with personal identifiers (name and email address). We collect this information to fulfill your request for additional information or support from us. The legal basis for this processing is your consent.

1. Information Collected Automatically.

In addition to the personal information you provide directly, we may also collect information from you automatically as you use the Services. This information includes the following internet or other electronic network activity information:

 

• Usage Information.This includes which pages of the Services you visit, the frequency of access, how much time you spend on each page, what you click on while using the Services, and referring website addresses. For the mobile application this includes: which exercises you picked and your results for such exercises as well as how many pods you are connected to. 

• Device Information. This includes certain information about your device that you use to access the Services, such as browser type, browser language, hardware model, operating system, and your preferences.

• Location Information. We may collect information about your location, which may be determined through your IP address or via Bluetooth.

To collect this information, we use cookies and other tracking technologies. Cookies are small pieces of text sent by your browser to your device. Cookies can be persistent (cookies that remain on your device for a set period of time or until you delete them) or session (cookies that are deleted as soon as you close your browser). When you use the Services, we and our third-party providers may place a number of cookies on your device. These cookies include:

• Essential Cookies. We use essential cookies to authenticate users, prevent fraudulent use of the Services, and to allow the Services and its features to function properly.

• Functional Cookies. We use functional cookies to provide enhanced functionality and personalization, to remember your preferences, to diagnose server and software errors, and in cases of abuse, track and mitigate the abuse.

• Analytics Cookies. Our analytics providers use cookies as part of their tools. Analytics cookies allow us and our analytics providers to recognize and count the number of users to the Services, see how users interact with the Services and different functions, and when users are using the Services. We use this information to improve the Services.

• Advertising Cookies. Our advertising providers use advertising cookies to identify and store behaviors that users take when visiting our Services. These cookies are used in order to: (i) identify you as a prospect for our services; (ii) deliver advertisements that are more relevant to you and your interests; (iii) limit the number of times you see an advertisement; and (iv) help measure the effectiveness of our advertising campaigns.

A list of all cookies we use, their purpose, and the information they collect can be found here [hyperlink].

Particular third-party cookies on our Services to note include: 

• Google Analytics.We use Google Analytics to collect information on your use of the Services to improve our Services. In order to collect this information, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Services or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy, available for review here. Such sharing may be deemed a sale under the California Consumer Privacy Act. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.

• Facebook Pixel. We use Facebook Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our Services by clicking on the Facebook ad. The Facebook Pixel stores a cookie on your device to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the information collected through the Facebook Pixel. However, the information collected via the Facebook Pixel, on the Services as well as other websites on which Facebook Pixel is installed, is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook's Data Usage Policy. The Facebook Pixel also allows Facebook and its partners to show you advertisements on and outside of Facebook. Such sharing may be deemed a sale under the California Consumer Privacy Act. You can opt-out of displaying Facebook ads by visiting your Facebook Ad Settings, and you can clear and control the information third parties share with Facebook in your Off-Facebook Activity If you do not have a Facebook account, you can opt-out of Facebook ads through the Digital Advertising Alliance here. For European users, please visit the European Interactive Digital Advertising Alliance here.

• Bing Ads.Bing Ads is a remarketing service provided by Microsoft. We use Bing Ads to serve you advertisements based on your past visits to the Services. You can learn more about the privacy practices of Microsoft here. Such sharing may be deemed a sale under the California Consumer Privacy Act. To opt-out of Bind Ads, you can follow the instructions here.

• We use Hotjar in order to better understand user experience and to optimize the Services. Hotjar allows us to better understand users’ experience (e.g. how much time you spend on which pages, which links you choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Services. For further details, please see the ‘about Hotjar’ section of Hotjar’s support services. You can opt-out of HotJar here.

• Google Tag Manager. Google Tag Manager is a tag management system to manage tags used for tracking and analytics on Services. Tags are small code elements that, among other things, are used to manage traffic and visitor behavior and to test and optimize websites. We utilize Google Tag Manager to manage and organize all third-party tags on our Services and to control when those tags are triggered. You can view more information about Google Tag Manager’s privacy practices here.

HOW WE USE YOUR INFORMATION

We process your personal information on servers located in the United States, for the following purposes as necessary to provide the Services to you and perform our contract with you:

• Provide the Services and Blazepod Products You Request.We use your personal identifiers, biometric information, visual information, and payment information to provide the Services, including creation of your BlazePod mobile application account, to maintain your account, to add users as requested, to process your payment for products, and to fulfil your request for certain products or other services.

• Communicate and Provide Support. We use your personal identifiers to communicate with you about our Services and the products and services we offer through them, to send you account updates or other communications regarding your account, to inform you of any changes to the Services, and to provide any support you may need. Support may include technical support or answering your questions or inquiries.

We also process your personal information as part of our legitimate interests to:

• Communicate About New Features and Offers. We use your personal identifiers to send you communications about new products or events from BlazePod that we feel may be of interest to you. These are tailored for you based on your characteristics and interests classifications we have made in reliance on the information collected through your use of the mobile app. For example, identifying you as a soccer coach and sending you communications on products that might be of interest to you. For this purpose, we use automated analysis techniques that provide us with analysis and conclusions concerning you, including profiling. The legal basis for this processing is your consent.

• Maintain and Improve the Services.We use personal identifiers and internet or other electronic network activity information to diagnose any problems with the Services and to improve user experience. We process your personal information as part of our legitimate interests in improvement of the Services and ensuring the security of the Services.

• Personalize Marketing.We use your personal identifiers and preferences to identify your interests and needs in order to provide you with more personalized and tailored marketing communication in order to enhance user experience. These are tailored for you based on your characteristics and interests classifications we have made in reliance on the information collected through your use of the mobile app. For example, identifying you as a soccer coach and sending you communications on products that might be of interest to you. For this purpose, we use automated analysis techniques that provide us with analysis and conclusions concerning you, including profiling. We process your personal information as part of our legitimate interest in the improvement, optimization, and marketing of our Services.

• Benchmarking. We aggregate personal information and use and share the aggregated de-identified information for the purpose of research, benchmarking and marketing.

In our processing of your personal information, we may also use your personal information to defend our rights and the rights of others, to efficiently maintain our business, to comply with the law as, and for other limited circumstances as described in HOW WE SHARE YOUR INFORMATION.This is part of our legitimate interest in the performance of our contractual obligations, protection of legal rights, compliance with legal obligations, and protection of the rights of users of the Services and other individuals.

 

HOW WE SHARE YOUR INFORMATION

General Sharing

We share your personal information with our service providers and other third parties as described below: 

With Service Providers. We share personal information with third-party service providers that perform functions on our behalf and help us to administer the Services. The legal basis for this is our legitimate interest in providing the Services more efficiently. We use the following service providers:

• We use Shopify to process your payments.
• We use Klaviyo to send and analyze our email campaigns. In order for Klaviyo to send emails on our behalf, we provide Klaviyo with certain information about you, such as your name and email address. The Klaviyo emails technologies that allow us to determine if an email has been opened and which links within the email you click on. In addition, Klaviyo collects technical information associated with the email, such as IP address, time of retrieval, browser type, and operating system. You can disable the email tracking by disabling the display of images by default. You can revoke your consent and opt-out of such email communications at any time by clicking the "unsubscribe" link at the bottom of each email.
• We use Zendesk and Ness Digital to provide customer assistance and technical support.
• We use UPS to ship your purchase.

Within BlazePod.We may share personal information within the BlazePod corporate family, such as with subsidiaries, joint ventures, or affiliates, in order to efficiently carry out our business and to the extent permitted by law. The legal basis for this is our legitimate interest in carrying out our business operations efficiently. 

In the Event of a Corporate Reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. The legal basis for this is our legitimate interest in carrying out our business operations. 

 

To Prevent Harm. We will share personal information if we believe it is necessary to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person. The legal basis for this is compliance with the law, compliance with legal obligations, and our legitimate interest in the protection of the rights of others.

For Legal Purposes. We will share personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal processes; to establish, protect, or exercise our legal rights or contractual obligations; to defend against legal claims or demands; or to comply with the requirements of any applicable law. The legal basis for this processing is compliance with a legal obligation applicable to us and our legitimate interest in compliance with other laws applicable to BlazePod.

With Your Consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time.

Sharing In The Preceding Twelve (12) Months

For a Business Purpose. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose with the following categories of third parties:

• We have disclosed your personal identifiers, internet and electronic network activity information, and payment information to third parties that help administer the Services, including our payment processors, our email vendor, our website provider, IT support, and our database hosting provider.
• We have disclosed your personal identifiers and internet or other electronic network information to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair Services errors.

For a Sale. Certain sharing we engage in may be considered a sale under the California Consumer Privacy Act. In the preceding twelve (12) months, we have sold your internet or other electronic network activity collected via cookies to data analytics providers and ad networks. You may opt-out of the use of these cookies by following the instructions in YOUR INFORMATION CHOICES below.

YOUR INFORMATION CHOICES

 Access or Correct Your Personal Information. You may access your BlazePod account to access or correct certain information you have provided to us and which is associated with your account, such as information you have uploaded to the mobile application. To access other information relating to your account, such as usage statistics or profiling categories you will need to contact us at info@blazepod.com. 

Google Analytics. You can control the information provided to Google and opt-out by using one of the methods set forth here. You can also download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.

Facebook Pixel.You can opt-out of displaying Facebook ads by visiting your Facebook Ad Settings, and you can clear and control the information third parties share with Facebook in your Off-Facebook Activity page. For those without a Facebook account, you can also take the steps outlined in Online Advertising below.

 

Bing Ads.To opt-out of Bind Ads, you can follow the instructions here.

 

Hotjar. You can opt-out of Hotjar here.

 

Online Advertising.To opt-out of interest based advertising generally, you can visit the Network Advertising Initiative or the Digital Advertising Alliance. For European users, please visit the European Interactive Digital Advertising Alliance here.

Email Tracking. You can disable the email tracking by disabling the display of images by default. You can revoke your consent and opt-out of such email communications at any time by clicking the "unsubscribe" link at the bottom of each email.

Cookies. All session cookies expire after you close your browser. Persistent cookies can be removed by following your browser’s directions. To find out how to see what cookies have been set on your device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each browser is different. For information on reviewing or deleting cookies from specific browsers, click on the appropriate browser: Firefox, Firefox IOS, Firefox Android, Safari, Safari Mobile, Chrome, Internet Explorer, Microsoft Edge, Opera. To find information relating to other browsers, visit the browser developer’s website. If you reset your browser to refuse all cookies or to indicate when a cookie is being sent, some features of our Services may not function properly. If you choose to opt-out, we will place an "opt-out cookie" on your computer. The "opt-out cookie" is browser and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences.

Marketing Communications. You can opt-out of receiving marketing communications from us by clicking the “unsubscribe” link provided in each communication. Please note we will continue to send you notifications necessary for the Services, your purchases, and your account.

Uninstall Our Mobile Application. You can stop all further collection of your personal information from our mobile application by uninstalling the mobile application. After the application is deleted we will retain the unique token assigned to your device through the mobile application, and would be able to identify you if you decide to reinstall the mobile application.

RIGHTS OF INDIVIDUALS IN THE EUROPEAN UNION 

Individuals in the European Union (EU) are entitled certain rights under the General Data Protection Regulation (GDPR). If our processing of your personal information is subject to the GDPR, you are entitled to the following rights:

• Right to Access. You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process.

• Right to Rectification. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Right to Erasure. You have the right to ask us to erase your personal information in certain circumstances.

• Right to Restrict Processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances. See YOUR INFORMATION CHOICES for additional ways you can restrict processing of your personal information.

• Right to Object to Processing. You have the right to object at any time, for reasons arising from your particular situation, to processing of your personal information, which is carried out on the basis of our legitimate interests. See YOUR INFORMATION CHOICES for additional ways you can object to processing of your personal information. 

• Right to Data Portability. This only applies to personal information you have given us. You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you. 

• Right to Lodge a Complaint.A list of Supervisory Authorities is available here.

To exercise these rights, please contact us at info@blazepod.com.

RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA), grants certain rights to California residents. If our processing of your personal information is subject to the CCPA, you are entitled to the following rights:

• Right to Access.You have the right to request what personal information we have collected, used, disclosed, and sold about you within the preceding twelve (12) months.

• Right to Deletion.You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.

• Right to Opt-Out.You have the right to opt-out of the sale of your personal information to third parties. To opt-out, please follow the instructions in YOUR INFORMATION CHOICES. BlazePod does not have actual knowledge that it sells personal information of minors under the age of sixteen (16) years.

• Right to Non-Discrimination.You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.

To exercise your right to access or delete your personal information, you may submit a request to info@blazepod.com or via telephone at [Number]. You may only make a request for access twice within a 12-month period. To opt-out of the sale of your information, please follow the instructions in YOUR INFORMATION CHOICES.

For requests submitted via telephone or email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

You can request deletion of your account by contacting us at info@blazepod.com. 

We will retain your personal information until the earlier of (i) the information is no longer necessary to accomplish the purpose for which it was provided; or (ii) we delete your information pursuant to your request. We retain your personal  information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. Below are some more specific reasons we would retain some data for longer periods of time:

• Security, Fraud & Abuse Prevention. For example, to protect you, other people, and us from fraud, abuse, and unauthorized access. 

• Financial Record-Keeping. When you make a payment to us we are often required to retain this information for a longer period of time for purposes of accounting, dispute resolution, and compliance with tax, anti-money laundering, and other financial regulations 

• Comply With Legal or Regulatory Requirements. To meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations

• Direct Communications With Us. If you have directly communicated with us, we may retain reasonable records of those communications.

Even if you delete your account or personal information, please keep in mind that the deletion by our third-party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time.

 DO NOT TRACK

We do not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

CHILDREN’S PRIVACY

The Services are not intended for individuals under the age of eighteen (18). If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below. 

SECURITY OF YOUR INFORMATION

We implement and maintain reasonable security procedures and practices to protect the personal information we collect from unauthorized access, destruction, use, modification, or disclosure.  These security practices include encryption and access controls. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHANGES TO THIS PRIVACY POLICY

From time to time, we may amend this Privacy Notice. We will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you via email.

CONTACT US 

If you have any questions about this Privacy Notice or our information practices, please contact us at info@blazepod.com.

Last modified on September 30s, 2020