Podium Technologies Limited (“Pod1um”) is a private company limited by shares incorporated in Ireland with company number 686532 and having a registered office at the Athletic Grounds, Claremount, Co. Mayo, Ireland (“we”/ “us”/ “our”). We provide an [app through which our customers can access online coaching and tailored training plans] (the “Services”).
We respect your right to privacy and take seriously our responsibilities in relation to the processing of personal data. We do not collect or process personal data unnecessarily.
Under this Policy, and unless we have entered into a different agreement with you, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as the “controller” of the personal data you provide to us.
We will collect and process the following data about you for the following purposes:
Your Data. This is information about you that you give us by filling in forms on our Site, or on our App, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use either our Site, or the App, or the Services, or report a problem with our Site.
The information you give us may include:
Automatically Collected Information. With regard to each of your visits to our Site and the use of our App we will automatically collect the following information:
Special categories of personal data. Special categories of data, including Health Data, may be collected by us as part of the performance of the Services. You may submit special categories of personal data to us through our Site or our App. We have additional measures in place to safeguard your special categories of personal data, and we will only disclose this data to your coaches, team or advisors with your explicit consent.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in table format, a description of the ways we plan to use your personal data and the legal basis we rely only to do so. We have also identified our legitimate interests where appropriate:
|Purpose/Activity||Type of data||Legal basis for processing|
|To respond to your queries and to provide you with the information you request from us in relation to our products or Services.||-Identity Data|
|-Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business)|
-Performance of a contact with you
|To provide the Services and/or the App to you and to provide you with access to our coaches and, where relevant, provide you with personalised content, a personalised training plan or analytics about your wellbeing.||-Identity Data|
|-Performance of a contract with you|
|To monitor and analyse your training, [health, fitness and nutrition information] to enable you to optimise your training.||-Identity Data|
|-Performance of a contract with you|
|To share your training information with our coaches, team or advisors.||-Activity Data|
|-Performance of a contract with you|
|To manage payments, fees and charges and to collect and recover money owed to us.||-Identity Data|
|-Performance of a contract with you|
-Necessary for our legitimate interests (to recover debts due to us)
|-Performance of a contract|
-Necessary to comply with a legal obligation
-Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).
|To provide you with information about services we offer that are similar to those that you have enquired about or are subscribed to.||-Identity Data|
|-Necessary for our legitimate interests (to develop our products or Services and grow our business)|
|Where you have given us your consent to do so, to provide you with information about other services we feel may interest you and any promotional offers that we may have which may be of interest to you.||-Identity Data|
|To ensure that content is presented in the most effective manner for you and for your computer or device.||-Identity Data|
|-Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business).|
|To administer and protect our business, our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.||-Identity Data|
|-Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site and the Services safe and secure)|
|To use data analytics to improve or optimise our Site, marketing, customer relationships and experiences.||-Technical Data|
|-Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).|
|Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site, the App and the Services safe and secure)||-Technical Data|
|-Necessary for our legitimate interests (to define types of customers for our and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).|
|To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you.||-Identity Data|
|-Necessary for our legitimate interests (to study how customers use our products or Services, to develop them, to grow our business and to inform our marketing strategy).|
|To anonymise, and conduct statistical analysis or research using this anonymised data and/or to appoint or collaborate with our research partners or a third party to do so.||-Usage Data|
-Health Data (all of the above anonymised)
|-Necessary for our legitimate interests (to identify general (anonymised) trends, behaviours, results in relation to training, recovery and nutrition strategies relevant to our business).|
|To review and process applications for employment with us.||-Identity Data||-Necessary for our legitimate interests (to develop our products or Services and grow our business)|
Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.
How long we keep your information. 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. This means that the period of time for which we store your personal data may depend on the type of data we hold. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For more information about our data retention policies please contact us at firstname.lastname@example.org.
We do not sell your personal information to third parties for marketing purposes. We may disclose information to third parties if you consent to us doing so as well as in the following circumstances:
You agree that we have the right to share your personal information with the following recipients or categories of recipients:
Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the European Economic Area (“EEA”), where the privacy and data protection laws may not be as protective as those in your jurisdiction. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer.
For more information about this and the safeguards in place relating to the transfer, please contact us by email at email@example.com.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
To exercise your right to object at any time, please email firstname.lastname@example.org. Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.
You have the right to be informed if your personal data will be subject to automated decision making, including profiling. You also have the right not to be subject to a decision based solely on automated process, including profiling, where that decision impacts on your legal rights. There are some exceptions to this rule, where, for example, the decision is necessary in connection with the performance of a contract between us, is authorised by law or where you have given your explicit consent to this automated processing. [In this case, however, we do not engage in profiling or automated processing for profiling purposes.]
General. We will not use your data to send marketing communications to you about promotions, competitions, updates and new products or services that may be of interest to you, unless we have your permission to do so.
Your right to object. You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at email@example.com. You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal
Any changes made to this Policy from time to time will be published on our Site and our App. Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data, will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.
Contact Us. If you have any questions or complaints relating to this Policy, please contact us at:
Podium Technologies Limited
Supervisory Authority. We are committed to complying with the terms of the GDPR and to the processing of personal data in a fair, lawful and transparent manner. If, however, you believe that we have not complied with our obligations under the GDPR, you have the right to lodge a complaint with the Data Protection Commission.