This Privacy Policy describes how We collect, use and disclose information, and what choices you
have with respect to Your personal data when You use the Perifit’s application (the "App").

This privacy policy applies to our App. If You do not agree with its terms, please do not access or use
the App.

 

1. Who We are and what is Our mission?

We are X6 Innovations SAS (“Perifit/We/Our/Us”), data controller of the personal data of the users of
Our App (the “You/Your/Yours”). 

At Perifit We are as committed to protecting Your personal data as We are to creating cutting edge,
smart technology for women. It is a top priority for Us to build a relationship of trust with You as a user
of our product, a connected probe to the App (the “Product”). These steps include:

• Being completely transparent about how, when and why Your personal data is controlled and processed by Us.
• Allowing You control over the personal data We collect from You and how We process that personal data.
• If You do choose to allow Us to process Your personal data, We will make as clear as possible the specific reasons why and how that data may be collected, used and transferred.

We use Your personal data in accordance with Law no. 78-17 of 6 January 1978 on computer technology, computer files and civil liberties, known as the “Informatique et Libertés” Act, as well as with Regulation (EU) No 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and under certain applicable United States federal and state laws if you live in the United States of America (hereinafter referred to together as the “Applicable Regulations”).

2. What is personal data and what personal data do We process via the App?

Personal data is information relating directly or indirectly to You, such as Your name, an identification number, or Your email address.

The Applicable Regulations consider that some personal data are sensitive. Sensitive personal data includes, but is not limited to, personal data which reveals racial or ethnic origin, and data concerning health or sex life and sexual orientation.

When You use Our App, We collect and process the following personal data:

• If You create an account on the App: Your email address and name;
• If You use all the functionalities of the App: Your gender, country, name; age, height and weight, and data pertaining to Your health such as your menopausal status;
• App and Product’s usage data:
  • Data relating to Your performance and workouts with the Product;
  • Log data: As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Product and App and record it in log files, crash data;
  • Device information: We collect information about devices using the Product including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data;
  • Location information: the Product collect location information from devices in accordance with the consent process provided by Your device only to allow the connection of the Product with Your Bluetooth device;
• Messages exchanged with Our client care team; 
• Details of Your use of the App’s forum.

We may also collect sensitive personal data, such as: Your menopausal status, the reasons why You want to use the Product, your strength improvement, any information pertaining to Your health ou sex life if you wrote it on the forum. Such personal data is only collected and processed with Your explicit consent. If You don’t want to give Us Your consent, then You may use the App but You won’t have access to personalized game.

 

3. How do We use Your personal data and why?

Perifit uses personal data for several purposes and according to several legal basis. We use Your personal data for the following purposes:

• To provide You with the App and allow You to use the Product and the App, to create Your personal user account in order for You to monitor Your workouts and performances and to be able to keep Your data after changing phone or tablet, and use Our forums (legal basis: Terms of use of the App);
• To communicate with You by responding to Your requests, comments and questions. If You contact Us, We may use Your user data to respond (legal basis: terms of use of the App);
• To investigate and help prevent security issues and abuse (legal basis: Our legitimate interest to provide a secured App);
• To send emails and other communications. We may send You service, technical and other administrative emails, messages, surveys and other types of communications. We may also contact You to inform You about changes in our Product or App (legal basis: Your consent);
• To understand how You behave and use Our App as well as to improve the App (legal basis: Our legitimate interest to improve the App and the Kegel exercise);

All User Data will be anonymized when viewed by Us and any other third parties. No individual user data is shared with third parties. The only exception will require You to provide Us with explicit permission to access and assess Your User Data in order to resolve a problem You are having with
the Product. We will not be able to do this without Your permission.

All personal data We collect and process is stored on Our secure servers in accordance with reasonable security practices as required by applicable law, legal process or regulation.

Where You have chosen (or where We have given You) a password which enables You to access to Your account in the App, You are responsible for keeping this password confidential. We ask You not to share this password with anyone and to change it if You suspect someone has gained access to it.

 

4. For how long do We store Your personal data?

We collect, process and store Your personal data for the time You use Our App and are active on Our App. 

If You are inactive on Our App for more than two (2) years, we will contact You and, without response in a delay of thirty (30) days, we will delete Your account and all the personal data. 
We may also retain such data for a time of 1 year following deactivation of Your user account for the purpose of enabling You to reactive Your user account more easily.

 

5. What are Your rights and Our obligations?

5.1. Our Obligations

We undertake to collect and process Your personal data fairly, lawfully and respecting Your rights.

We make every effort to avoid any interference with the personal data of other users of the App, such as loss, misappropriation, intrusion, unauthorized disclosure, alteration or destruction thereof. We use industry standard encryption for transmission of data to Our systems. Although We cannot guarantee
the absolute safety of transmission of data via the internet, We adhere to industry standards to give Your data the most appropriate protection possible.

5.2. Your rights

When We process Your personal data with Your consent, You do have the right to withdraw that consent at any time, but this will not affect the lawfulness of processing prior to the withdrawal of such consent. You can exercise Your right to withdraw consent to processing at any time by contacting Us via support@perifit.co.

You may also exercise the following rights:

• Access: You have the right to know the personal data We hold about You and the reasons why it is being processed;
• Rectification: rectify personal data inaccurate or incomplete;
• Erasure: You have the right to request Us to erase personal data We hold about You, except for the personal data We must keep because of a legal obligation;
• Data portability: You also have the right to receive the personal data concerning You in a structured, commonly used and machine-readable format or to ask us to send your personal data to others data controllers;
• Restriction: You have the right to ask Us to restrict the processing of Your personal data. In such case, We won’t process Your personal data anymore but may store it in order to respond to Our legal obligations; 
• Objection: You have the right to object to the processing of Your personal data where We process Your personal data for Our legitimate interest. You may also object to the processing of Your personal data for commercial prospection purposes. This right may be exercised by clicking on the link in Our emails;
• Right to give Us Your digital will. 

If You have any concerns or complaints relating to this policy, its subject matter, or the manner in which We collect, control and/or process Your personal data, or to exercise Your rights, please do let Us know by sending an email to support@perifit.co or by mail at X6 Innovations, 128 rue La Boétie – 75008 Paris.

You may also make a complaint to a supervisory authority, in France the Commission Nationale de l’Informatique et des Libertés.

 

5.3. California Consumer Rights

Under California Civil Code Section 1798.83, California residents have the right to obtain: (a) a list of all third parties that we may have disclosed your personal information to within the past year for direct marketing purposes; and (b) a description of the categories of personal information disclosed. To obtain such information, please email your request to support@perifit.co.

 

6. Children’s privacy

The Product is not marketed to, and should not be used by, anybody under the age of 16.

We do not knowingly collect personal data from children under the age of 16. In the event that We discover that a child under the age of 16 has provided Us with personal data, We will delete such data from our servers. 

 

7. Sharing and transferring personal data

At Perifit, We share Your data to Our client care team and Our product team. Product team will only access to anonymized and aggregated data.

We may also share personal data We hold to third parties, our service providers, in order to provide You with the App. 

We share Your personal data with:

• Mixpanel, which is Our service provider for analyzing the use of the App. Personal data is stored in the USA;
• AWS, which is the hosting service provider for the App. Personal data is stored within the European Union;
• Typeform, which is Our service provider for survey. Personal data is stored in the USA;
• Intercom, which is Our service provider for chatting and providing You with support. Personal data is stored in the USA, Ireland and Australia; 
• Tribe, which is Our service provider for the forum of the App. Personal data is stored in the USA;
• Bugfender, which store the logs created by the App. Personal data is stored within the European Union;
• Sentry, Jira, and Segment which are services providers that help Us to monitor and resolve error, bug and issues. Personal data is stored in the USA, Germany, Ireland, Singapore, and Australia;
• Zapier, which is Our service provider for automating workflows between our third party apps. Personal data is stored in the USA.

If We are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect Our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

8. Changes to this policy

We reserve the right to change this policy at any time. Where appropriate, We will notify You, as a data subject, of those changes by email.

If amendments to Our privacy policy involve matters for which Your consent was previously required, we will notify You in order to reattain Your consent.