Privacy Policy
1. Introduction
This document sets out the privacy policy of Prymo Sports App Pty Ltd (ABN 19685029476) (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’). For the purposes of applicable data protection law, (in particular, the General Data Protection Regulation (EU) 2016/679 (the ‘GDPR’) and the UK Data Protection Act (2018)), your data will be controlled by us. This privacy policy applies whenever we collect your personal information and/or personal data (your personal data). This includes between you, the visitor to this website/landing page (whether directly as our customer or as personnel of our customer), and us, the owner and provider of this website/landing page and also where we are directed by a third party to process your personal data. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of our mobile app and website/landing page and the provision of our services to you. We take our privacy obligations seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data in connection with your use of our website/landing page. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
2. TYPES OF PERSONAL INFORMATION WE COLLECT
The personal data we collect may include the following:
(A) name;
(B) Mailing or street address;
(C) Country of residence;
(D) Email address;
(E) Social media information;
(F) Telephone number and other contact details;
(G) Age;
(H) Date of birth;
(I) Information such as your height, weight and performance data to support our performance tracking and training features. While this is not considered health information under the Australian Privacy Act 1988 (Cth), it may be treated as sensitive personal data in some jurisdictions. We process this information only with your consent and use it solely to personalise your experience within the mobile app;
(J) Credit card or other payment information;
(K) Information about your business or personal circumstances;
(L) Information in connection with any client surveys, questionnaires and promotions you participate in;
(M) When we use analytical cookies, your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
(N) Information about third parties;
(O) Performance tracking data such as skills progress, activity logs; and
(P) Any other information provided by you to us via this mobile application, website/landing page, in the course of us providing services to you, or otherwise required by us or provided by you.
3. HOW WE COLLECT PERSONAL INFORMATION
We endeavour to ensure that information we collect is complete, accurate, accessible and not subject to unauthorised access. We may collect personal data either directly from you, or from third parties, including where you:
(A) Register through our mobile app;
(B) Contact us through on our website/landing page; address;
(C) Communicate with us via email, telephone, SMS, social applications (such as Instagram or Facebook) or otherwise;
(D) Engage us to perform services to you;
(E) When you or your organisation offer to provide, or provides, services to us;
(F) Interact with our mobile app, website/landing page, social applications, services, content and advertising;
(G) Invest in our business or enquire as to a potential purchase in our business; and
(H) Are contacted by a member of our sales or customer support team (e.g via phone or email) in the course of business development or account management.
We may also collect personal data from you when you use or access our mobile app, website/landing page or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website usage. For more information, please see clause 9 below.
4. USE OF YOUR PERSONAL INFORMATION
We collect and use personal data for the following purposes:
(A) To provide services or information to you;
(B) For record keeping and administrative purposes;
(C) To improve and develop our services to you and the mobile app;
(D) To comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
(E) To personalise your training insights and performance tracking;
(F) To calculate performance benchmarks or recommendations based on physical characteristics;
(G) To improve accuracy in tracking skill progression and challenge outcomes;
(H) Where we have your consent, including to send you marketing and promotional messages and other information that may be of interest to you. In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt-out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
(I) For our legitimate interests including:
(i) To develop and carry out marketing activities and to conduct market research and analysis and develop statistics;
(ii) To improve and optimise our service offering and customer experience;
(iii) to send you administrative messages, reminders, notices, updates and other information requested by you;
(iv) To consider an application of employment from you; and
(v) The delivery of our services.
5. SHARING YOUR DATA
We may share your personal data in certain circumstances, as follows:
(A) Where you choose to share your performance data with another user (such as a coach, training partner, or friend), or request feedback on your activity, we will facilitate that sharing through our mobile app. This sharing is entirely controlled by you and limited to the parties you nominate;
(B) If you are part of a gym, club, or coach membership, the associated gym, club, or coach may have access to certain performance data and journal entries you submit through the mobile app. However, you can restrict this access at any time by using the in-app privacy settings to limit visibility on specific training entries;
(C) If you use our in-app messaging, forums, or group challenges, certain personal information (such as your name, profile picture, and shared content) may be visible to other users, depending on your privacy settings and the structure of the feature (e.g. public vs private groups);
(D) Where there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal data and non-personal data contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances;
(E) Credit-checking agencies for credit control reasons;
(F) Disclosures required by law or regulation; and
(G) To improve accuracy in tracking skill progression and challenge outcomes;
(H) We may share your information with trusted third-party service providers and other affiliated third parties who assist us in delivering the mobile application and our services to you, such as cloud hosting, analytics, customer support, and other professional advisers such as accountants, disaster recovery service providers or auditors and/or overseas counsel. These third-party service providers include but are not limited to:
(i) Amazon Web Services (AWS);
(ii) Stripe;
(iii) Apple In-App Purchase (IAP);
(iv) Google Play Billing;
(v) Google Analytics;
(vi) Mailchimp;
(vii) Meta (Facebook, Instagram, Pixel).
6. SECURITY
We take reasonable steps to ensure your personal data is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal data
7. LINKS
Our website/landing page may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.
8. YOUR RIGHTS
You have various rights with respect to our use of your personal data:
(A) Access: You have the right to obtain access to your information (if we’re processing it) and certain other information (similar to that provided in this privacy notice). This is so that you’re aware and can check that we’re using your information in accordance with data protection law.
(B) Be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this privacy policy.
(C) Rectification: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using our contact form to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
(D) Objecting: You also have the right to object to processing of your personal data in certain circumstances, including processing for direct marketing.
(E) Restricting: You have the right to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further.
(F) Erasure: You have the right to ask us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
(G) Portability: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
(H) Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority.
(i) In Australia, this is the Office of the Australian Information Commissioner (OAIC);
(ii) If you are located in the European Union, you may contact your local supervisory authority;
(iii) In the UK, the supervisory authority is the Information Commissioner’s Office.
(iv) Withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time. This includes your right to withdraw consent to us using your personal data for marketing purposes. You may, at any time, exercise any of the above rights, by contacting our email address provided below.
9. Cookies and Tracking Technologies
(A) (General): While our mobile app does not use traditional website cookies, it may use similar tracking technologies such as software development kits (SDKs), device identifiers, and analytics tools to enhance user experience, improve performance, and help us understand how our services are used.
(B) These technologies may collect information such as your device type, operating system, app usage behaviour, IP address, and location data. We may use this data for purposes including:
(i) App performance monitoring and troubleshooting;
(ii) Usage analytics to improve functionality and user experience;
(iii) Security and fraud prevention;
(iv) Personalised content or marketing (where applicable and with your consent)
(C) (Third Party Tools): We may work with third-party service providers, such as:
(i) Google Firebase / Analytics (usage and crash reporting);
(ii) Facebook SDK (user authentication or marketing, if applicable);
(iii) Other tools as listed in our updated documentation or app notices.
These providers may also process your data according to their own privacy policies, which we encourage you to review.
(D) (Your Choices): Where required by law (such as under the GDPR), we will request your explicit consent before enabling non-essential tracking technologies. You can withdraw your consent at any time through:
(i) In-app privacy settings (if available);
(ii) Device settings (e.g. disabling ad tracking on iOS/Android);
(iii) Contacting us at info@prymosports.com;
Please note that disabling certain types of tracking may impact the app’s performance or functionality.
10. HOW LONG WE KEEP DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will securely destroy your personal data in accordance with applicable laws and regulations. If you would like further information about our specific retention periods for your personal data, please contact us using our email address provided below.
11. TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA (‘EEA’)
To provide our services, we may transfer the personal data we collect to countries outside of Australia, the UK or EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection. When we do this, we will make sure that it is protected to the same extent as in Australia, the EEA and UK as we will put in place appropriate safeguards to protect your personal data, which may include standard contractual clauses.
For more information,please contact us at our email address provided below.
12. CONTACT US
For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:
Email: info@prymosports.com
We may change this privacy policy from time to time by posting an updated copy on our website/landing page and we encourage you to check our website/landing page regularly to ensure that you are aware of our most current privacy policy. Where we make any significant changes, we will endeavour to notify you by email.
