Play Coyotta Ltd. including our subsidiary BlazePod Inc. and affiliates worldwide (“BlazePod”, “we”, “our” or “us”), puts great efforts in making sure that the personal data we process is safe and used properly, and that our data practices are accurately communicated to our prospects, and users (collectively “you” or “your”).
Prospect data concerning our website visitors, prospective affiliates and resellers or distributors, who visit, shop or engage with our websites (such as https://blazepod.com/, https://blazepod.eu and its subdomains depending on their location), blogs or other similar forums, online ads and content, surveys, emails or other communications under our control (collectively, the “Sites”) or participate in events or webinars that we organize or take part in (collectively - “Prospects”).
User data concerning individuals (“Users”) who register to the BlazePod’s flash reflex training platform, features and tools (the “Platform” and together with the Sites – the “Services”).
Player data concerning users of our Users (“Players”), whose progress may be tracked via the Services.
- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Security
- Data Sharing
- Cookies and Tracking Technologies
- Data Subject Rights
- Roles and Responsibilities
- Additional Information and Contact Details
1. Data Collection
The data we process regarding our Prospects and Users is typically collected and generated through automatic means, directly from you, through your interaction with us or with our Services; from our Users; or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives.
Such data may include:
- Contact information: contact details and interests, as well as any needs, preferences, attributes and insights relevant to our potential engagement;
- Direct interactions and communications: messages, comments, posts, reviews, feedback and correspondence with other Users or with us (e.g., for user enablement, support and training purposes), including chats, surveys, calls and video recordings, transcriptions, managed contacts, and analyses thereof, and any other data you choose to provide or upload via the Services;
- Account information: e-mail address, name, nickname, date of birth, gender, profession and interests, and additional optional information such as profile photo, weight, height, as well as hashed password or other information used for authentication and access control. You can edit or delete these details under “My Profile” “Edit Profile” or “Delete User”.
You may also choose to login to our Services using your Facebook or Gmail account. By doing so, you provide us with information connected to such an account which may also include your name, profile picture, friends list, language preferences, demographic data, location, account ID number/token, and email address). Please note, BlazePod doesn’t have control over how any third party uses or discloses the personal data it collects about you.
- Analytic information: performance data such as reaction times, score history, improvement trends, exercises chosen, pods connected, personalized workouts, saved and favorites activities, benchmark and comparison with other Users;
- User generated content: information you choose to upload to the Services such as customized workout plans, exercise videos, photos, etc.
- Services usage information: connectivity, technical and aggregated usage data, user agent, IP addresses, device data (such as type, OS, device ID, browser version, locale and language settings used), Bluetooth, Geolocation, pods ID, access times and dates logs, communication and performance logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized on your device.
Player information: during the provision of our Services, the User may choose to add a Player to the Platform, in order to track their progress. In this case we will process certain additional data such as the Player’s first and last name, as well their performance and progress information (e.g., fitness level, strength and speed). Our Users are responsible to provide adequate notice of such processing to their Players and any other information necessary to comply with applicable laws, as further explained in Section 10 below.
BlazePod processes the personal data described in Section 1 as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services. These include understanding how our Services are used, and how our Services, campaigns and other activities are performing; gaining insights that help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use your data for the following purposes:
- to facilitate, operate, and provide our Services;
- to authenticate your identity and allow you to access and use our Services;
- to provide you with customer care, assistance and technical support services;
- to further develop, customize and improve the Services, and to improve your user experience, based on common or personal preferences, experiences and difficulties;
- to facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
- to contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 8 below, and to facilitate, sponsor and offer certain events and promotions;
- to support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- to create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
- to comply with our legal, regulatory, compliance and contractual obligations.
Our authorized Service Providers and we maintain, store and process personal data in the various locations we operate around the globe, including in Israel, the EU and the US, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
We retain your personal data for as long as it is reasonably necessary to provide you with our Services and offerings and to maintain and expand our relationship; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
Please also note that we do not retain your payment information, it is transferred directly to the relevant Service Provider (as per Section 6 below). We only retain a token of such payment information (which cannot be used to reidentify it) and the chosen payment method.
Our Service Providers and we implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, also confirmed by Verisign verification of BlazePod for using secure socket layer (SSL) encryption technologies when dealing with sensitive information. However, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Service Providers: we engage selected third-party entities to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, fraud detection services, billing and payment processing services, shipping and handling services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems; and our business, legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.
Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of BlazePod, our Prospects, Users, Players, or any members of the general public.
Additional Sharing: we may share your personal data in additional manners, pursuant to your request or explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
7.Cookies and Tracking Technologies
Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session - these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
Facebook Pixel: we use Facebook Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. 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. 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. 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.
We engage in service and promotional communications through e-mail, phone, SMS and notifications.
Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services (such as billing issues, login attempts or password reset instructions, alerts and notifications concerning anomalies detected by our Services, abandoned cart emails, surveys, etc.). You can control your communications and notifications in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use.
Notifications and Promotional Communications: we and our authorized partners (e.g., event or webinar co-sponsors or partners) may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. In order to control your notifications settings please follow the instructions included in the promotional communications sent to you. If you do not wish to receive such communication, you may also notify us by sending an e-mail to: email@example.com.
9.Data Subject Rights
Individuals have rights concerning their personal data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR), or the CCPA, such as the right to request access, rectification, or erasure of your personal data held with BlazePod, your right to restrict or object to such personal data’s processing, or to port such personal data – please contact us by e-mail at: firstname.lastname@example.org. You can also edit or delete your details under “My Profile” “Edit Profile” or “Delete User”.
Please be advised that deleting your personal data stored with BlazePod will adversely affect your use of our Services. Note that if you are a Player whose progress information is being tracked by the Services on behalf of our Users, your request should be directed to such applicable User. Please also note that if such a request will be directed to us, we will share such request with the relevant User.
Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
10. Roles and Responsibilities
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
BlazePod is the “data processor” of Player data which we process on behalf of our User, who is the “data controller” of such data. As controllers, our Users are solely responsible for providing adequate notice to their respective Players whose personal data may be processed – including sufficient reference to the processing of their personal data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Information and Contact Details
Children: Our Services are not designed to attract children under the age of 16, we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at email@example.com.
Effective Date: Nov 22, 2021