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PRIVACY POLICY GENERAL

Technogym Privacy Policy

 

This privacy policy allows you to understand what data we collect, why we
collect it, and how we process it when you use our personalised training
services, access digital fitness content, reply to our assessment
questionnaires, participate in virtual challenges and competitions, when you buy
our products or services, and when you subscribe to our newsletter and to our
social&community initiatives (hereinafter also referred to as the “Service”).

 

Contents

 

 1. Who is the Controller and DPO and how can you contact them?. 
 2. When does this policy statement apply?. 
 3. Why do we process your personal data, what is the legal basis of the data
    processing and what personal data do we collect?. 
 4. What is the nature of data provision and what are the consequences arising
    of any refusal?. 
 5. Who will your personal data be disclosed to?. 
 6. What about international transfers?. 
 7. How long do we keep your personal data?. 
 8. Use of the Service by minors under the age of 16. 
 9. Data Subject rights and how you can exercise them.. 

 

 


1.   WHO IS THE CONTROLLER AND DPO AND HOW CAN YOU CONTACT THEM?

Controller

Technogym S.p.A., headquartered at Via Calcinaro 2861, 47521 Cesena (FC), Italy
(hereinafter also referred to as “Technogym”) will collect and process your
personal data in connection with your use of the Technogym® Digital Platforms:
these include our websites (e.g.
www.technogym.com, www.mywellness.com, www.skillathletic.com and others), our
mobile apps (e.g. the Technogym App, the Mywellness App, the MyRun app, and
others) and Technogym® connected equipment (hereinafter also referred to as the
“Platform”).

Technogym will act as the Controller in relation to your personal data for the
purposes indicated below and also in relation to centralised marketing
activities in relation to the precontractual and contractual relationship.

You can contact Technogym by standard post, sending a letter to Technogym
S.p.A., Via Calcinaro 2861, 47521 Cesena (FC), Italy, for the attention of the
Data Protection Officer (DPO) or by sending an email to privacy@technogym.com.

Joint controllers

In those foreign countries where ecommerce is available on
the www.technogym.com website, Technogym uses its own branches and/or local
distributors for the sale and service of its products, which are also
responsible for offering support to the customer in managing technical issues.
Local distributors and branches will act as joint controllers with Technogym
regarding data provided in the context of sales and service requests as well as
data collected for the management of the sales contract and related marketing
activities.

Data Protection Officer (DPO)

Technogym has appointed a Data Protection Officer (“DPO”), who you can contact
at dpo@technogym.com.

To know your rights, please visit the “Data Subject Rights” section below. 


2.   WHEN DOES THIS POLICY STATEMENT APPLY?

Technogym collects and processes your personal data in connection with your use
of the Platform, which includes:

 * the Technogym website technogym.com; and
 * the digital ecosystem for precision training services provided via Technogym
   mobile applications (e.g. The MyWellness® App, the Technogym App, the MyRun
   App, the Mycycling App, the Skillathletic App, etc.), through the
   website mywellness.com and Technogym® training equipment connected to the
   Internet, which is governed by the relevant Terms and Conditions of use.

Technogym may also collect your data through our inbound calling system, which
in some countries, and subject to your consent, may record the calls you have
with our staff.

Under certain other circumstances, your data will be collected via dedicated web
forms (for example, if you signed up to a specific call-to-action via social
networks, or if you register online for an event) or on paper, for example, when
you decide to share your business card.

If you train at a gym that uses the Platform and you have not registered with
the Service

This policy statement does not apply to the processing of personal data by third
parties, such as a gym, hotel, your company gym or other facility (hereinafter
also referred to as the “Facility”) offering services using the Platform’s
features. In such cases your relationship is directly with the Facility that
Technogym provides services to through the professional Platform, but only as a
service provider acting as processor. For these cases, please refer to the
privacy policy provided by the Facility.

If you train at a Facility that uses the Platform and you also have a Technogym
Account (“Join Facility”)

If you register for a Technogym Account and decide to connect the data collected
and processed by your Facility, Technogym will start processing that data as an
independent controller, and therefore the contents of this privacy policy will
apply in addition to that of the Facility (or Facilities) you train at. The Join
Facility feature will only be enabled if you provide your consent. You will find
all the information related to Facilities you joined in the “My Facilities”
section under “Settings” in the customer area of your Technogym Account.

IMPORTANT NOTICE: when making an electronic payment (using your credit/debit
card, Apple Pay, PayPal or similar tools) you will be redirected to the
authorised payment processor’s/payment institution’s secure website to provide
your payment details to them. While we cooperate only with trustworthy licensed
payment processors and payment institutions, we make no representation or
warranty for their processing of your data in the context of payment. Please
make sure your read and agree with their terms of service and with their privacy
policies before providing them with your data. In any case, we may not be held
liable or accountable for any breach, loss, destruction, unauthorized disclosure
or any similar incident involving your data when processed by any payment
processor or payment institution.


3.   WHY DO WE PROCESS YOUR PERSONAL DATA, WHAT IS THE LEGAL BASIS OF THE DATA
PROCESSING AND WHAT PERSONAL DATA DO WE COLLECT?

The possible actions when you access our Platform include:

(i) On www.technogym.com:

Your action Purposes Data collected Legal basis Apply to subscribe to our
Newsletter services We will collect your data to provide you with profiled
marketing content on the promotion of our products and services based on the
analysis of your preferences and your interests.

 

- Personal details (first name, last name);

- Email address

 

Execution of user's request to receive profiled marketing content (art. 6(1)(b)
GDPR)

 

Fill in a form on www.technogym.com We will collect your data to provide you
with the information or support you have requested from us by filling in the
relevant form and in the course of your interaction with us - Personal details
(first name, last name);

- Email address and/or phone number

- your request

 

Execution of user's request to receive precontractual or contractual information
requested (art. 6(1)(b) GDPR) Fill in the checkout page on our ecommerce site We
collect your data to perform the online sale and purchase of our products and
services - Personal details (first name, last name);

- Email address and/or phone number

- Address

- Notes

- Products and services in the basket

- Price and payment method

Execution of precontractual and contractual obligations (art. 6(1)(b) GDPR)
Create your Technogym Account We will collect your data to create your Technogym
Account; you may use the Technogym Account to login to www.technogym.com and to
receive the Services of the Technogym digital ecosystem for personalized
training –  (subject to updating your account); all data collected by the
Technogym Account will be processed to give you a personalised training
experience and, subject to your consent, a profiled marketing service. First
name, last name, email address OR telephone number Execution of user's request
to register a Technogym Account for use of specific Technogym Services (art.
6(1)(b) GDPR) Your request to use our Service We will collect your personal data
in the course of your use of the Service to perform the actions requested by you
as well as to fulfill our contractual obligations related to any sale of
Technogym products or services, to deliver them to you, to service and maintain
your Technogym products, to manage any enquiries, correspondence, and any
concerns or complaints you have raised Personal and contact details,

details of your geographical location

information about transactions (for example payment information, account and
authentication information, and billing, delivery and contact details)

Execution of contractual obligations (art. 6(1)(b) GDPR)  

(ii) On the Technogym digital ecosystem for personalised training:

 

Create or update your Technogym Account We will collect your data to create or
update your Technogym Account; you may use the Technogym Account to login
to www.technogym.com and to receive the Services of the Technogym digital
ecosystem for personalized training; all data collected by the Technogym Account
will be processed to give you a personalized training experience and, subject to
your consent, a profiled marketing service. First name, last name, email
address, date of birth, gender, weight and height

For children aged under 16, we also collect the email address of a parent or
guardian for parental control

 

Execution of user's request to register or update a Technogym Account for use of
specific Technogym Services (art. 6(1)(b) GDPR)

Consent to processing of special category data (art. 9(2)(a) GDPR)

Your request to use our Service We will collect your personal data in the course
of your use of the Service to perform the actions requested by you as well as to
fulfill our contractual obligations related to any sale of Technogym products,
content or services, to deliver them to you, to service and maintain your
Technogym products, to manage any enquiries, correspondence, and any concerns or
complaints you have raised Personal and contact details,

details of your geographical location

data collected from your connected wearable devices, if you allow this through
your device settings

information about how you use our Services, such as the types of training
programmes you perform, the content that you view or engage with, the features
you use, the actions you take, and the time, frequency and duration of your
workouts. For example, we log when you're using and have last used the product,
and what content you enjoyed

Information obtained from your mobile device which includes:

o  Device attributes: information such as the operating system, hardware and
software versions, battery level, signal strength, available storage space,
browser type, app and file names and types, and plugins.

o  Device operations: information about operations and behaviour when using the
device, such as whether a window is in the foreground or background, or mouse
movements (which can help distinguish humans from bots).

o  Identifiers: unique identifiers, device IDs and other identifiers, such as
from games, apps or accounts that you use, and Family Device IDs (or other
identifiers associated with the same device or account).

o  Device signals: Bluetooth signals, information about nearby Wi-Fi access
points, beacons and mobile phone masts.

o  Data from device settings: information you allow us to receive through device
settings that you turn on, such as access to your GPS location, camera or
photos;

o  Network and connections: information such as the name of your mobile operator
or ISP, language, time zone, mobile phone number, IP address, connection speed
and, in some cases, information about other devices that are nearby or on your
network, so we can do things such as help you stream a video from your phone to
your TV.

Information about transactions (payment information, account and authentication
information, and billing, delivery and contact details)

Execution of contractual obligations (art. 6(1)(b) GDPR) Request to use our
Service We will process certain categories of special data, to deliver you any
training programmes and dashboards with your training results

 

Data which may be related to your health, such as height, weight, and body
composition which may be collected directly from you or through other connected
devices, such body scales and other wearable devices.

Data collected by sensors on our machines, including heart rate monitors and
calorie burning calculators

 

Even if the processing of the mentioned categories of special data is necessary
to perform your contractual request, according to the GDPR, the legal basis to
process such data is consent (art. 9(2)(a) GDPR) Request to use our Service -
personalized training programmes We will collect your personal data to carry out
profiling and data mining activities aimed at providing you with a personalised
training experience with specific training programmes in line with your
characteristics, objectives and training progressions

[please see more information in the Profiling section]

 * data relating to physical characteristics, including weight, height and other
   body measurements collected directly from you or through other connected
   devices, such as sensors within the Technogym equipment or through connected
   body scales;
 * training performance data provided by you or generated through our Platform
   (time, duration, distance, location, calorie count, step count);
 * type of fitness equipment available for use at home or in the gym; type of
   fitness equipment typically used;
 * surveys and questions about objectives and interests;

Execution of contractual obligations (art. 6(1)(b) GDPR) Sign up to wellness
social & community activities

 

We could access (i) your friends’ contacts detail to allow you to interact with
them and share your training performance and results (ii) your calendar, to
program a training fitness programme; (iii) your social network profiles to
publish content by our Platform on social networks (iv) your geolocalisation
data to suggest any location close to you which is equipped with Technogym
training machines.
 * photos, audio, contacts and calendar information;
 * social networking information, including credentials and any information from
   your public posts on our apps

 

Consent to adhere to community (art. 6(1)(a) GDPR) Download Technogym® apps
(e.g. MywellnessApp, MyRun App, etc.) We will process your personal data to
deliver you the specific features included in the app you have downloaded. The
data collected by the app will enrich your profile in your Technogym Account.
 * Same data collected and process to deliver the Service [please see more
   information in the Request to use our Service section.

Execution of contractual obligations (art. 6(1)(b) GDPR) Sign up to marketing
profiling activities We will process your personal data collected during our
contractual relationship to send you personalised marketing communications based
on the analysis of your preferences and your interests (so-called “marketing
profiling”)

[please see more information in the Profiling section link]

 * All data collected in your Technogym Account with the exception of special
   category data (e.g. data revealing your health) and data of minors

Consent to receive marketing profiling communications (art. 6(1)(a) GDPR)
Analysis and statistics on aggregated data We will process your personal data to
(i) prepare aggregate statistics and analysis regarding or relevant to our
activities and improve our products and services; (ii) prepare anonymous
datasets for our research and development; guarantee the quality of customer
service; (iii) manage and internally control our activities; (iv) manage the
loss and/or destruction of data or unauthorised access; (v) collect and process
anonymised data about the devices used in order to obtain useful information
about how people use the Service; •           All data collected in your
Technogym Account Execution of legitimate interests of Controller (art. 6(1)(f)
GDPR) Soft-spam As part of our legitimate interests, we may also send you
promotional communications by email about products or services similar to those
you have bought in the past. You may unsubscribe from these communications at
any time by clicking on the appropriate link appearing in any such communication
Email and data on your purchases with Technogym Comply with the law and/or
orders issued by the authorities We will process your personal data to comply
with any other obligations deriving from the applicable laws or orders issued by
the authorities, including accounting and tax obligations, and product
warranties •           All data collected in your Technogym Account Execution of
legal obligation (art. 6(1)(c) GDPR)

When you interact with our Platform, certain data is automatically collected
from your devices or browsers. More information about these practices is
included in the following section: Cookie Policy . The aforementioned data
includes: device ID, call status, network access, memory information, and
battery information; Cookies, IP addresses, data identifying the browser and
version in use, web beacons, tags, and interactions with our Platform.

Read more about our Cookie Policy.

Profiling

The information you provide us, the information we collect during the course of
the Service as well as the information generated by your use of the Service or
Platform, is processed to allow us to identify your current and potential
preferences or interests. The information obtained may be used for the following
purposes:

(a) Provide you with Personalised Workouts: we will evaluate and analyse some of
your personal aspects (e.g. physical structure, training data collected through
the Platform, training goals achieved, etc.) to allow us to present you with
personalised training programmes, in line with your training and physical
wellness needs.  

In order to create personalised training programmes, Technogym collects and
analyses the information collected from time to time and suggests training
programmes that could best meet your interests and needs. The training
programmes are generated through an automated analysis of all the information
collected that allows, according to predetermined criteria, the identification
of training suitable for you.

The criteria taken into account in the definition of the personalised training
are essentially the following:

(i) Age and gender (age and gender tend to identify more appropriate workouts
while avoiding strenuous workouts);

(ii) Physical form and physical activities performed and frequency (information
that allows us to assess whether you are already fit and to avoid creating
excessively strenuous exercises). For example, a 50-year-old woman who performs
one training session per week will be different from a 50-year-old man who jogs
three times a week;

(iii) Passions and interests (e.g. if you love dancing, we could propose
programmes inspired by the dance world)

(iv) The results achieved during training, analysing your performance as well as
the feedback given, is useful to be able to propose programmes from time to time
that are in line with your progress, thus allowing you to achieve the results
you have given us or propose variations.

If you subscribe to the Service to receive personalised training programmes, we
do not require your consent to process this data as it is necessary to perform
the Service requested by you.

The Technogym digital ecosystem for personalised training is exclusively a
customised service and therefore without the analysis of the data provided or
otherwise acquired, Technogym would not be able to provide you with a training
experience, since this type of processing is inherent to the Service offered.
Therefore, if you are not interested or would not like your data to be profiled
for the purposes described in this section, you will not be able to use the
Technogym digital ecosystem for personalised training.

Nonetheless, you may continue to use your Technogym Account to visit and explore
the www.technogym.com website.

(b) Provide you with personalised marketing communications: the information
collected from your use of the Service and/or deriving from your interaction
with the Platform and the information provided by you, may be subject to
analysis in order to explore and assess your preferences and interests for
personalised marketing activities (market research, sending of profiled
commercial communications etc.), in line with your preferences and behaviour.

In order to present you with offers and promotions, initiatives and events, and
allow you to take part in surveys and contests that match your likes or
interests, we analyse the information we have collected about you or that you
have provided to us in the last 7 (seven) years, which will be calculated
backwards from the last interaction you had with us (e.g. the date you read our
last email, the last date you logged onto our equipment, etc.). In this way we
avoid sending communications that may be of no real interest to you.

In general, the indicators used to create these customisations are related to:

- Gender and age

- Interests and passions

- Analysis of your usage and preferences on our Platforms.

This activity requires your explicit consent, which you are free to express on
the Platform. The consent provided can be revoked at any time, through the
features indicated in the Data Subject Rights section.


4.   WHAT IS THE NATURE OF DATA PROVISION AND WHAT ARE THE CONSEQUENCES ARISING
OF ANY REFUSAL?

The disclosure of personal data requested for the execution of precontractual
and or contractual obligations is necessary to carry out your request and any
refusal to disclose the requested personal data in whole or in part may make it
impossible for Technogym to provide you with the Service.

Furthermore, you have the right to freely express your consent for the
collection of special categories of personal data when requested for the
delivery of the Service in the Technogym digital ecosystem for personalised
training. You may revoke your consent at any time. Any failure to give consent
or any subsequent revocation of consent will disconnect you from your training
services in the Technogym digital ecosystem for personalised training. You may
continue to use your Technogym Account for other Services, namely the use of
the www.technogym.com website.

Finally, you have the right to freely express your consent for the marketing
profiling purposes specified above, which may be revoked at any time. Any
failure to give consent or any subsequent revocation of consent shall in no way
prejudice the pursuit of any other purposes specified above and your use of the
Service.


5.   WHO WILL YOUR PERSONAL DATA BE DISCLOSED TO?

Depending on the case, your data may be disclosed to other parties.
Specifically, depending on the particular service you have requested, your data
may be disclosed to any of the following:

 * The Facilities at which you train, who will process the data as an
   independent controller, if and to the extent that you decide to share your
   data with them. You can manage your preferences using the “My Facilities”
   section in the “Settings” area of your Technogym Account. To obtain
   information about the data processing carried out by these controllers,
   please refer to their privacy policies; 
 * Third parties (as independent controllers) who offer you their products or
   services directly, who you allow to connect to the Service (for example, if
   you use a wearable device to track your training and connect that device to
   your account, or if you share your training sessions on Facebook or
   third-party Apps). To obtain information about the data processing carried
   out by these controllers, please refer to their privacy policies;
 * Your Wellness Community, which means people you decide to share your training
   results with (for example, when you take part in a challenge or book a
   class);
 * Technogym’s subsidiaries or distributors which support us locally with
   marketing activities and which may support you locally for any requests you
   may have in respect to product and/or service issues;
 * Subjects, companies or agencies that provide support and/or services to
   Technogym (for example, IT services, marketing services and analysis or
   consulting activities), who will process personal data on behalf of Technogym
   in the role of processor;
 * Other parties who are required to know the data in accordance with current
   legislation. In such cases, Technogym will merely communicate the data that
   is strictly necessary in accordance with the principle of proportionality and
   minimal processing.


6.   WHAT ABOUT INTERNATIONAL TRANSFERS?

When we transfer your data to third parties based outside the EU, we will do so
in compliance with the requirements set out by EU Regulation no. 2016/679
(“GDPR”) by adopting specific measures to legitimise the transfer to third
countries.


7.   HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal data will be processed for the entire time you use our Service
and/or your Technogym Account.

Even in the event when you cancel your Technogym Account, we may continue to
process your personal data in the role of processor on behalf of a Facility you
are a member of. You will need to ask the Facility to indicate the relevant
retention period.

After your Technogym Account has remained dormant for 5 consecutive years,
Technogym will send you two quarterly reminders of your right to portability
(see the “Data Subject Rights- section for more information). On expiry of the
second reminder from Technogym, your data used for the Technogym ecosystem
Service for precision training will be anonymised if you do not reply.

Please note that the information related to your purchases will be retained for
10 years as of the end of the warranty period, in accordance with the applicable
limitation period provided by the law.

This term may be extended for purchases of equipment bearing a serial number for
which Technogym maintains information about the sale and delivery of the
equipment based on the legitimate interest of assisting continuous safety of the
equipment, even after the warranty legal obligation has expired up to a period
of 10 years from the date when that specific machine was released on market.

You may request deletion of your Technogym Account at any time; however,
although your account will be promptly deleted, the data collected through your
account and related to your purchases and/or use of our Service will be stored
for 10 years, in accordance with the applicable limitation period provided for
by the law. In the event of anonymisation, it will no longer be possible for you
to recover the data. 

Please remember that if you have decided to share your personal data with the
Facility, the cancellation of your Technogym Account will not mean that your
data is inaccessible to that Facility. To erase the data completely you will
need to contact the Facility and follow the instructions in its privacy policy. 

Furthermore, if you give your consent, your personal data will be processed for
marketing profiling purposes until you will revoke your previous consent:

 * in the Profile Settings area of your Technogym Account; or
 * by clicking on the “unsubscribe” link at the bottom of each email received;
   or
 * by sending a request to our contacts indicated in the section 9 below (“Data
   Subject Rights”).


8.   USE OF THE SERVICE BY MINORS UNDER THE AGE OF 16

Children under the age of 16 (“Minors”) can only create a Technogym Account in
relation to the Technogym digital ecosystem for personalised training via the
Mywellness App or the www.mywellness.com website and subject to parental
authorisation.

In any event, we do not use the personal data of minors for marketing
activities.


9.   DATA SUBJECT RIGHTS AND HOW YOU CAN EXERCISE THEM

You have the right to know which personal data is being processed. In
particular, you have the right of access, rectification and erasure and the
right to portability of data, the right to limit the processing and the right to
object to the processing, where the conditions are met. If the data is processed
for marketing purposes, or is based on our legitimate interests, you may object
to it at any time. For more information about the processing of your personal
data, or to exercise your rights, you can write to the email
address dpo@technogym.com or write to us by standard post, sending a letter
marked for the attention of the Data Protection Officer at Technogym S.p.A., Via
Calcinaro 2861, 47521 Cesena (FC), Italy. 

Below is a brief illustration of your rights in relation to the processing of
your personal data.

 1. The right of access enables you to obtain confirmation of whether or not
    Technogym is processing your personal data and, if necessary, access that
    data and the related information;

 1. The right of rectification allows you to obtain the modification of
    inaccurate personal details without unjustified delay and, taking into
    account the purposes of the data processing, to obtain the completion of
    incomplete data;

 1. The right of erasure enables you to obtain the erasure of your data without
    unjustified delay (e.g. when your personal data is no longer required for
    the purpose for which it was collected), subject to the exceptions provided
    for by the applicable laws (e.g. when the retention of your data is
    necessary in order to comply with legal obligations applicable to the
    controller);

 1. The right to data portability allows you to receive your personal data, as
    supplied to Technogym, in certain circumstances provided for by the
    applicable laws, in a structured, commonly used, legible format from an
    automated device. You may send this data to another controller where
    permitted by the applicable laws, unless this could harm the rights and
    freedoms of others; for certain services we have put in place automated
    portability systems, which you will find on your account.

 1. The right to limit data processing allows you to limit the processing of
    your personal data in certain circumstances as provided for by the
    applicable laws. In such cases, Technogym may continue to process your data,
    but only in certain cases, for example, in order to exercise its right of
    defence and to protect the rights of another natural or legal person;

 1. The right to object to data processing allows you, in certain circumstances
    provided for by the applicable laws, to object to the processing of your
    personal data unless there are prevailing legitimate reasons, rights or
    freedoms that would allow Technogym to continue to process the data;

If there are reasons connected to your specific situation, you may object to the
processing of your personal data at any time if it is based on a legitimate
interest of Technogym or of a third party. In such cases, Technogym will no
longer process the data unless there are other legitimate reasons to proceed
with the processing.

 

If the personal data relating to the Service is shared with other parties who
process that data in the role of independent controller (e.g. the Facilities,
third parties offering products or services connected to your Technogym
Account), you will have to exercise your rights with those controllers,
following the instructions contained in their privacy policies.

Technogym, in accordance with the principles of privacy by design and privacy by
default, may supply you with tools to facilitate the exercise of your rights,
also with those parties with whom Technogym has entered into agreements in that
regard (e.g. the Facilities you have joined). You can find these tools in your
personal area of the MyWellnessApp and MyWellness website. 

 

At any time you may complain to the Data Protection Authority if you consider
that you have not obtained a satisfactory response from Technogym in relation to
your rights or if you consider that they have been violated.

 

 


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