CENTR Privacy Policy

Last Updated: October 15, 2024

This Privacy Policy applies to any website, application, feature, widget or other online service that is owned or controlled by Centr LLC, its subsidiaries and affiliated companies including that post a link to this Privacy Policy (collectively, “Centr”). This policy is meant to help you understand how we collect, use and share information to operate, improve, develop and protect our services. This includes how we collect and process your personal information such as when you visit Centr sites, use any Centr services including Centr applications, or purchase fitness equipment (including InspireFitness branded equipment), or when you interact with us via our call centers, support service including live chats and e-mail communications, or social media channels (together, the "Services").

1. WHAT PERSONAL INFORMATION WE COLLECT

The sources from which we collect this personal information fall into three categories: Information you provide, Information we collect automatically, Information we collect from other sources. See below for more information on the types of personal information in each category.

1.1 Information provided by you

Identifiers. Name, physical address, email, and phone number. These are collected when you register for Services, subscribe to Centr marketing, or communicate with us.

Profile Information. Information that you provide in connection with your Centr Profile, and any additional information you choose to provide to enhance your use of the Services, including your gender, general location, and the Identifiers listed above.

Preferences. Content preferences; dietary and fitness preferences; language preferences.

Connected Devices/Accounts. We enable you to connect your Centr account with third parties (i.e. devices, apps, APIs, or websites that integrate with the Services). Where you choose to connect another company's device or account to your account or engage in our Services that features a partnership with a third party, we may, with your consent, collect information from your use of the connected device(s) to facilitate interaction with our Services. This may include information like heart rate or calories burned that may be considered consumer health information under certain applicable laws.

Purchase Information. Information related to products and Services you order, and delivery information (including billing, shipping and delivery address) that you provide when you purchase products and Services. Please note, we do not store or capture any credit card information. This information is collected directly by our payment processing partners, but we would like to inform you about its collection since this information is collected from you through our site and from you, our customer.

Feedback and Support Communications. Any details of your communications/interactions with us, including when you call, email, live chat, video call or text with our support teams. We may record support calls for training and monitoring purposes and to help resolve issues. We will tell you before recording and, where required by applicable laws, obtain your consent for the collection of these recordings.

Surveys and Review Information. Any information you voluntarily provide to us or our Service Providers (or otherwise publish) in connection with a survey you complete or review / testimonial you provide about Centr goods and/or Services. We may collect this information to understand your opinions, better market our services and to collect relevant information about our business.

Promotions, Sweepstakes and Competition Information. Any information that you provide to us in connection with any promotions, sweepstakes and/or competitions.

1.2 Information that we collect automatically

Fitness Data. Information relating to the programs that you select and participate in.

Inferences. We may collect data and make inferences based on that Fitness Data, but the inferences are not used to infer specific characteristics about you other than what workouts, programs or products that you may enjoy.

Information from your device. Information from and about the device you use when you use our Services, including IP address, identifiers, type, mobile carrier, browser type and language, operating system.

Usage Data: We may also collect information about how your device interacts with our Services, such as the content you access, pages and sites visited before and after you reach the Services, the date and time of your use, the amount of time spent on the Services, and other actions taken through use of the Services such as preferences. We use data analytics with this Usage Data to better understand your use of the Services to improve the Services offered.

Internet or Other Network Activity. Information including browsing or search history, including interactions with our websites, mobile applications, marketing and advertising. For more information see Section 4 “Cookies, Analytics and Similar Tracking Technology” below.

1.3. Information we collect from other sources

Other Applications. If you access our Services through a third-party application, such as the Apple App Store or Google Play App Store (together with any similar applications, "App Stores") or Social Networking Sites ("SNS") such as Instagram, Twitter or Facebook, we may collect information about you from that Third-Party application that you have made public via your privacy settings.

Security. Security and Safety: We may collect certain information in order to protect and verify your information and our Services. This may include Device IP, and other identifiers with a third party application to ensure your safety and the security of your account.

2. WHY WE USE PERSONAL INFORMATION

To provide you with the Services. Centr uses data to operate, improve, and maintain our Services. We use data to:

• Verify your identity, set up and maintain your account.

• Process payments through our trusted third party payment processors, and fulfill product orders.

• Provide access to on demand workouts, programs and wellness content, and participation, and workout tracking.

• Communicate and track your workout.

• Maintain our services and operations.

• Provide workout recommendations: We may recommend workouts to you based on our inferences about your preferences and practices.

To communicate with you. Supporting and communicating with you when you require it such as for:

• Administrative matters (such as account management, updates to terms, or system maintenance).

• To provide you with information about our Services (such as product delivery and logistics, servicing and technical support).

• To respond to any questions, comments or requests you have about our your customer account.

To send you marketing and/or promotions. Centr uses data to market its Services, which may include:

• Contacting you by phone, email, postal mail, push notifications, in-app messages or SMS with information about news, offers, products, promotions, events, contests and/or Services and content that might be of interest to you, as permitted by applicable law. This may include various usage data to send marketing communications that are personalized.

For analytics, research and product and Service improvement. Centr works everyday to improve your experience by using data:

• Including monitoring and measuring your use of our products and Services and conducting research/surveys, to understand how they are being used and how they can be improved.

• Financial analysis and analytics to understand billing, pricing and other financial matters that can be improved.

• In some cases, research may be analyzed on an aggregate basis and we may share this aggregate data with our affiliates, agents, service providers and other third parties with whom we do business. This includes, but is not limited to for example usage, performance, product, and music. This aggregate information does not identify you personally.

For personalization and advertising. Centr uses data for personalization and advertising that may include:

• Providing you with a personalized and tailored Service, to serve you with Centr advertising on third party properties.

• To serve you with relevant advertising and content on our Services.

• Understanding and assessing the effectiveness of our ads displayed.

• We may contract with third-party advertising companies and social media companies to display ads on their service. These companies may use cookies and similar technologies to track your activity, the information collected by these third parties in this manner is subject to that third party’s own privacy policies. We may also use aggregated information from these sources for creating similar audiences in order to better target advertisements on their networks to potential consumers who appear to have shared characteristics.

For personalization and analytics.

• To provide workout recommendations to you based on our inferences about your preferences and practices.

• To improve our services and product offerings.

• To understand how you interact with our websites, products, mobile app, advertisements, and communications with you.

• To determine which of our products or services are the most popular; to improve our products and services, and marketing campaigns.

• To provide personalized recommendations about our products and services.

To ensure the security and integrity of our Services. Providing a safe and secure environment is key to providing a responsible platform and we do this by using data to detect and combat any abuse or any harmful activity, fraud, spam, and illegal activity affecting our Services such as using personal identifiers, user profile, data usage, and other types of data to detect fraud, authentication or other harmful activity.

To comply with any applicable law and/or regulations, legal proceedings. We use data to investigate disputes or claims related to our Services. In certain circumstances, we may be obligated to use your information to respond to legal, government or regulatory requests.

3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may disclose your personal information to the following categories of recipients:

Group Companies. We may share your personal information with other Centr related companies and for purposes consistent with this Privacy Policy.

Service Providers. We share your personal information with trusted Service Providers/Data Processors for the business purposes of providing the Services and includes the following types of services: sales automation, website management, platform hosting, security monitoring, email and marketing communications, marketing analytics, payment processing and technical support.

Third Party Apps that you link to your Centr account. As part of the functionality of our Services, we enable you to connect your Centr account with third party applications. If you choose to connect your Centr account, we may share certain personal information with the paired application depending on what information you choose to share with such third party apps or have otherwise been notified will be shared during the pairing process. The information may include information generated through your use of the Services, and other contact and profile information. The processing of your personal information by such third party applications shall be governed by the privacy policies of those third parties.

Interest Based Advertising. We and third parties may collect information about your online activities to provide you with advertising about products and services tailored to your interests. We contract with third-party advertising companies, which may collect information about your use and interactions with the services, over time and across third-party websites and online services. To tailor and deliver this advertising, these third-party companies place, use, or rely on the technologies described above, including cookies, clear gifs, device identifiers and similar technologies to obtain information about customer interactions through interactions with online services. These companies use the information they collect to send you ads that are targeted to your interests. To opt-out of the use of cookies and other similar technologies when you visit our website(s) or use our Services, please contact us at privacy@centr.com.

Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts or other Third Parties. We may share your personal information with competent law enforcement bodies, regulators, our insurers, external legal advisors, government agencies, courts or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise, establish or defend our legal rights; (iii) to protect your rights or vital interests or those or any other person; or (iv) to detect, prevent or otherwise address security, fraud or technical issues.

Potential Buyers (and their agents and advisors). We may share your personal information with actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, provided that we inform the buyer or transferee that it must use your personal information only for the purposes disclosed in this Privacy Policy.

4. COOKIES, ANALYTICS AND SIMILAR TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies such as pixel tags/web beacons and social media widgets (collectively "Cookies") to collect and use personal information about you, including for analytics purposes and to serve you interest-based advertising. For example, cookies are used to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy Page

7. YOUR PRIVACY RIGHTS AND PREFERENCES

At Centr, wherever possible, we give you control over the personal data we collect about you, to ensure it is accurate and reflects your preferences. Depending on the country or U.S. state in which you are located, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. Please note that those rights do not always apply and there are certain exceptions to them.

Please also be advised that we continue to maintain some of your personal data where permitted by law, and that such information has not been deleted from Centr systems. We retain your personal information where it is necessary for us to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with laws, provide a good or service that you have requested, or reasonably anticipated within the context of our ongoing business relationship, or otherwise perform a contract between you and Centr;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Comply with a legal obligation, existing warrant, litigation hold.

Please note that if you Delete your account this will result in the deletion of your Centr account and all associated information, including workouts.

We will also confirm your identity before acting on your requests. We may not be able to respond to your request or provide you with personal data if we cannot verify your identity, or the authority to make the request on someone else’s behalf.

7.1 U.S. STATES PRIVACY NOTICE: For additional information and rights available to consumers in certain states, see the U.S. States privacy notice link here

7.2 EU/UK Users: EU and UK users have several rights with respect to their personal data including the following: (i) the right to be informed (ii) the right of access; (iii) the right of rectification; (iv) the right of erasure; (v) the right to restrict processing; (vi) the right of data portability; (vii) the right to object to processing; and (viii) the rights in relation to automated decision making and profiling. EU or UK users also have the right to lodge a complaint about the collection or use of their personal information by notifying their EU (or UK) supervisory authority. Centr’s legal bases for collecting and processing personal data includes performance of a contract and/or consent. Please feel free to contact us regarding this or any other EU or UK data subject right at privacy@centr.com if you have any questions about these rights. You can also complain to a data protection authority about our collection and use of your personal information if you feel that Centr has not acted in accordance with applicable laws. For more information, please contact your local data protection authority.

7.3 Direct Marketing We may send marketing communications for purposes disclosed to you and, where required by applicable law, with your consent. You can unsubscribe from direct marketing at any time by following the instructions below or by contacting us using the details provided under the How To Contact Us. We will process your request within a reasonable time after receipt, in accordance with applicable laws. Unsubscribe options are provided in electronic marketing communications as required by applicable law.

Email and Telephone. You can unsubscribe from email communications at any time. To stop receiving our promotional emails, follow the unsubscribe instructions in the email messages you receive from us. For other options, review the How To Contact Us section below. We will process your request as soon as practicable after receipt, in accordance with applicable laws. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Centr and our Services and, to the extent permitted by law.

7.4 "Do Not Track"

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that, because there has been no agreed industry standard, we do not respond to or honor DNT signals or similar “do not track” mechanisms transmitted by web browsers.

8. DATA RETENTION

Centr retains the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold it.

9. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical and physical safeguards (which vary depending on the sensitivity of the personal information) designed to protect against unauthorized use, disclosure or access of personal information.

10. CHILDREN’S PRIVACY

Centr Services are not directed to, or intended for, children. We do not knowingly collect personal information directly from children who do not meet the minimum age requirement applicable in your jurisdiction, and if you do not meet the age requirements as specified in our Terms of Service. If we become aware that we have collected personal data from a child under the minimum age, we promptly delete the personal data.

13. HOW TO CONTACT US

If you have any questions about our privacy practices, this Privacy Policy or would like to contact us, you can do so by email at privacy@centr.com.

14. UPDATES TO OUR PRIVACY POLICY

We may update our Privacy Policy from time to time. When we do, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this notice.