Updated 30 June 2023
CH DIGITAL PTY LTD ACN 628 240 497 (including, but not limited to, Centr LLC, a Delaware limited liability Company)(collectively, “CENTR”), its subsidiaries and affiliates are committed to processing, using, transferring, and managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth), and in accordance with other applicable privacy laws. This Policy details how CENTR collects, uses, transfers, and shares your personal information.
Information we collect
We ask for personal information so you can use our services, sign in to your account, receive customer support and safety information, and communicate with you about our services, promotions, and activities. We collect the following information when you engage with us.
When you create an account we collect:
Name and contact information
Date of birth
Username and password that you may select in connection with establishing an account on our Services
Fitness and nutrition statistics which you provide to us
Emergency contact information
Your photograph, social media handle, or digital or electronic signature
Publicly available information (e.g., public posts on your social media accounts)
Details of the products and services (such as membership options) you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your inquiries
Personal preferences such as favorite classes and instructors
Any additional information relating to you that you provide to us directly through our websites or by other means such as over the phone, via email, or in person
Information you provide to us via voluntary members feedback or engagement surveys;
Details of the products and services (such as membership options) you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your inquiries;
Any additional personal information you provide to us, or authorize us to collect, as part of your interaction or membership with CENTR
When you buy products through CENTR or our partners, affiliates, and subsidiaries:
Billing information (e.g., credit card details)
Shipping information such as your address
When you use our Websites or Apps
Information on your interaction with our apps, web sites and advertisements such as pages you visit
Social media handles, content, and other information that you post to our social media pages or tag us on your social media pages, and information we obtain from third-party social media services (e.g., Facebook) if you choose to link to, or create or log in to your CENTR online account through these platforms
When you choose to sync or connect your devices
Fitness information with your consent (e.g. heart rate, calories, steps, distance, duration, location) collected from third-party fitness devices (e.g. Apple Watch, Android Wear), apps or services (e.g., Apple Health, Google Fit, Samsung Health) when you consent to connect your device or account.
When you interact with us
Any additional information relating to you that you provide to us through our Services
Information you provide to us via voluntary members feedback or engagement surveys
Information provided when attending CENTR events or CENTR sponsored events (e.g., email address, professional affiliation)
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings
Information collected by automated means
When you interact with our online services, we obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A 'cookie' is a small text file that websites send to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We use these automated technologies to collect information about your equipment, devices, internet connection, browsing actions, and usage patterns. The information we obtain in this manner may include your IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, browsing history, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Sites. We may also obtain information about how you interact with our services, such as features and pages you visit, search queries, and download errors.
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please note that not all tracking will stop even if you delete cookies. For information about Do Not Track, please visit: www.allaboutdnt.org
Third Party Pixels and Cookies
When you visit, register for or log in to our Services, cookies, web beacons, and similar technologies may be placed on our Services by our online data partners and vendors to associate these activities with information they or others have about you, such as email addresses, to help us to serve relevant marketing offers to you. You may opt out of receiving marketing messages at email addresses provided by Retention.com by visiting https://app.retention.com/optout.
We do not sell your personal information or transfer personal information to third parties to use for their own benefit; however, we allow certain companies to place tracking technologies like cookies on our Services. Those companies receive information about your interaction with our Services that is associated with your browser or device and may use that data to serve you relevant ads on our Services or others. Except for this kind of sharing, we do not sell any of your information.
For more information please see the above section of our policy titled, “Information Collected by Automated Means.”
How we use your personal information
CENTR collects personal information reasonably necessary to carry out our business, to assess and manage our members' needs, and provide our Services to you. We may also collect information to fulfill administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing member relationships.
The purposes for which CENTR usually collects and uses personal information may include:
To fulfill obligations under a membership agreement and/or any other contract you may have with us;
To deliver the Services and/or products you requested;
To manage our relationship with you, with your consent, this may involve the use of fitness information from connected devices, apps or services;
To provide information and marketing about products, Services, and/or special offers to members;
To obtain opinions or comments about products and/or Services from members;
To record statistical data for marketing analysis from members;
To improve our Services to members, as well as for training and quality purposes;
Responding to requests, questions, complaints, and other general inquiries;
Managing, planning, advertising, and administering programs, events, competitions, and performances;
Researching, developing and expanding our facilities and Services;
At your direction and with your consent;
Information to provide you with access to events (e.g., for certain events, we may require professional licensure information);
For quality control and administration and assisting us to develop new and improved products and Services;
To recruit interns, staff, and employees;
To comply with any requirement of any applicable statute, regulation, rule, and/or good practice;
To fulfill our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
Sharing personal information
We may share your personal information for the purposes as follows:
Within our company and with our affiliates
With service providers that perform Services on our behalf, including for the purposes of operating our website, assisting us to perform business functions, managing and updating member lists and records, analyzing data, handling billing and payments, and facilitating customer service.
With professional services such as legal advisors, accountants, and consultants;
With select partners we may collaborate with;
With other parties with your consent and at your direction; and
We reserve the right to disclose your personal information as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us, or to protect the safety, rights, or property of our customers, the public, us or others.
We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. When we no longer need the personal information we collect, we either anonymize the information upon your request or securely destroy the information, unless we are legally required to retain it.
Your marketing choices
You can opt-out of our use and disclosure of your personal information for marketing purposes and customer satisfaction surveys, and/or withdraw your prior consent for same, by the methods provided below. Upon requesting an opt-out, your consent will be withdrawn; however, please note that it often takes some time to process these requests. Therefore, it is possible that you may receive communications scheduled prior to our receipt of your withdrawal of consent.
You may reply to a promotional or marketing e-mail that you have received from us with the word "Unsubscribe" in the subject line or you can email us directly at firstname.lastname@example.org. You may also unsubscribe from receiving marketing or other commercial emails by following the instructions included in the email. (If you use more than one e-mail address, then send your opt-out e-mail from each of your e-mail addresses.) Another way to unsubscribe is to delete your account in the app but this is irreversible, and you will lose access to your account and records. You would also need to cancel your subscription to avoid ongoing subscription charges. We may also provide additional methods for you to opt-out of having your personal information used or disclosed for promotional and marketing purposes.
Your privacy choices
You may have certain rights and choices regarding our processing of your personal information. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right to:
Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
Access a copy of the personal information we retain about you
Update any inaccuracies in the personal information we hold about you
Request deletion of your personal information
Request that we transfer your information to another entity in the format in which we maintain it in the ordinary course of business
Object to the processing of your personal information
Restrict how we use your personal information whilst a complaint is being investigated
We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.
Under some circumstances, we will use your email address on file to verify your identity. We may also request additional information. For example, if we suspect an access request is fraudulent, we will request additional information in order to verify your identity.
We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will endeavor to inform you of the denial, provide an explanation of our actions, and the reasons for the denial.
We will not restrict or deny you access to our Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the Services.
Where you have consented to our processing of your personal information, you have the right to withdraw, at any time, any consent that you have previously given to us for use of your personal information. In certain circumstances even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations. To make a request to exercise any of these rights (where applicable) in relation to your personal information, please contact us using the contact details below.
If you wish to contact us to make a request in connection with your personal information we have or to inquire or provide feedback about our privacy practices, you can email us directly at email@example.com.
Your exercise of the rights described above is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
You may make a complaint about privacy to the Privacy Officer at the contact details set out below. We may ask you to provide further information about your complaint and the outcome you are seeking.
If you are not satisfied with our response to your complaint, or you consider that CENTR may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website.
With respect to individuals located in the EU/UK, where we are unable to resolve an inquiry or a complaint, you have the right to contact the data protection regulator in the European country in which you are based.
International data transfers
We may transfer personal information from the United Kingdom or the European Economic Area (“EEA”) to countries that the United Kingdom’s Secretary of State or the European Commission (as applicable) has deemed to adequately safeguard personal information, in which case no additional safeguards are required in order to transfer this information. If we transfer your personal information to other countries, we will either transfer it subject to the recipient’s compliance with standard contractual clauses, Binding Corporate Rules, or with your consent to the transfer, unless we are permitted by law to transfer personal information without such formalities.
How we protect information
We maintain administrative, technical and physical safeguards designed to protect personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Despite such efforts, however, please note that no organization can fully eliminate risks or guarantee the security of personal information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information about you at any time, and we bear no liability for uses or disclosures of personal information or other data arising in connection with the theft of the information or other malicious actions.
Links to third-party websites
The contact details for CENTR are:
Postal: Level 2, 9-11 Cremorne Street, Cremorne, VIC 3121
Residents in the United Kingdom or the European Economic Area
You have explicitly agreed to us processing your information for a specific reason;
The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
The processing is necessary for compliance with a legal obligation we have; or
The processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
a) To prevent fraud;
b) To protect our business interests;
c) To ensure that complaints are investigated;
d) To evaluate, develop or improve our products; or to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
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