Inspire Brands Asia Privacy Policy

Effective Date: September 2020

Inspire Brands Asia Pte. Ltd., including its affiliates and subsidiaries, (“we”, “our” or “us”) values your personal information and is committed to protect your privacy. This Privacy Policy outlines how we use and protect your personal data and covers all information we may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act (“PDPA”), as well as, all the applicable data protection and privacy laws.

General Policy and Scope

In general, you can anonymously browse, read, or download information on the public, the non-password protected portions of our website, except for our limited processing of data via “cookies” as described in Section 3 below.

However, with your continued use of this website and our services, by submitting your personal information to us, or providing us your acceptance by other means permitted by the applicable laws, you consent to the collecting, processing, using, sharing and disclosing your personal data in accordance with the terms of this Privacy Policy, as well as, agree to the terms of our Terms & Conditions.

You may refuse or withdraw your consent at any time by giving us notice in writing; however, we may not then be able to provide you with our full range of products and services, as well as, the use of our Website, Apps, or our products or services if you do not agree to the Privacy Policy.

We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

We encourage you to read this whenever you visit our Website or use our Apps, since we may change this Privacy Policy from time to time. A copy of the current Privacy Policy is always posted at [please insert IBA website privacy policy link here]. Your continued use after we make changes and notify you in advance of such changes is deemed to be acceptance of those changes, so please check our Privacy Policy periodically for updates.

1. Personal Data We Collect from You

The data we may collect through your use of our Website may include, but is not limited to:

• Complete name, email address, landline/mobile phone number
• Details that can be used to identify an individual, such as name, gender, date of birth, nationality, passport, or other government issued or personal identification numbers;
• Contact information, such as mailing address, phone number, email address;
• Payment information, such as credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
• Computer data or files, obtained via so-called “cookies,” which may be sent by your web browser and stored on an individual computer to allow our server to “recognize” you through the navigation of the Website and for us to credit your account for various online transactions;
• Computer data files, obtained via so-called “web beacons” that are collected from emails or links on third-party website that allow our server to evaluate the popularity of those links or the information contained in emails or on third-party website; and
• Your IP address to measure our website traffic and to help provide a more personalized experience.

Children Under the Age of 15

Our Website and Apps are not designed for children and we do not knowingly collect data from any person under the age of 15. If you are under the age of 15, please do not access or submit any personal data to us through the Website. If we learn we have collected or received personal data from a child under 15, we will delete that data.

2. How We Use and Share Your Personal Data

We will use your personal data for the following purposes:

• Conducting marketing and research, through direct surveys to you;
• Providing you with information you have requested from us;
• Developing and displaying content and advertising tailored to your interests and preferences;
• Processing your franchise application and contacting you regarding franchise opportunities;
• Sending you electronic communications you have requested, such as text messages, push notifications, notifications through our Apps or through your mobile device;
• Providing you with updates and content based on your geo-location data you have provided to us; and
• Contact you regarding updates to the Website, Apps, or provide administrative notices to you.

and for all other specified and legitimate purposes necessary to provide our services to you.

In order to operate the Website as one seamless experience, however, we must share your personal data with our subsidiaries, and affiliates within our group to provide you with the integrated services offered through the Website. We may provide user data to third-party service providers or vendors for purposes of, including without limitation, initiating direct marketing programs on our behalf, data tracking, maintenance or development of our Website or Apps, development of online products and services, customer service or new product development, or other contracted promotional opportunities provided to our users. We, our vendors, or other business partners may use this data for marketing and solicitation purposes.

While we try to be selective in working with third parties, we are not responsible for their use of your personal data. Where payments are involved, we must release your credit card data to credit card authorization service providers and associated banks to process your payment for purchases, returns or refunds. We may transfer to our online service providers personal data you provide to us so that these parties may store and process your personal data to provide their services to us.‎

We may share aggregate data with vendors, potential advertisers, business partners, or other third parties. Aggregate data does not include personal data.

Except as described in this section, we will not give or sell your personal data to any other party.

Additional Disclosures.

We may also disclose personal data in any of the following circumstances: (1) in response to a subpoena, search warrant, court order, or other legal process or request, or as may otherwise be required by applicable law or regulation; (2) to protect and defend our rights or property or those of its franchisees, suppliers, related entities, affiliates, business partners, or others; or (3) as we, in our sole discretion, believe is appropriate under exigent circumstances in response to a perceived threat to the personal safety, property, or rights of any other person or organization.

In addition, since member data on our Website and in our Apps is a business asset, in the event we are reorganized or sold to or merged with another company, we may sell, assign, or transfer your personal data to a purchaser of all or substantially all of our business assets, or to an affiliate, as applicable.

3. Our Use of “Cookies” on the Website

A “cookie” is a small data file stored on your web browser or on your mobile device that allows us to recognize your computer or mobile device when you visit our Website by associating identification numbers with other user data you have provided us. Some cookies will remain on the hard drive of your computer or mobile device for the duration of your browser or user session, while others will remain until deleted by you. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all the services or functionality of our Website. Some third-party service providers may use “flash cookies,” which are saved on your computer, but cannot be rejected, disabled, turned off, opted out of, or deleted in the same way as regular cookies. To learn how to manage your flash cookie settings, visit the Flash player settings page on Adobe’s website.

In collecting and maintaining cookie-based data or other data collected directly from your mobile device, such as your geolocation, we are able to:

• Provide the basic functionality of the Apps, such as displaying your live location and movement;
• Installing and monitoring elements of the Apps for security purposes;
• Help diagnose problems with the Website or Apps, administer and improve the Website or Apps, and measure the use of the Website or Apps;
• Identify your internet provider, page views and other data regarding utilization of the Website;
• Gather other web analytics data related to your and other users’ use and navigation of the Website and Apps;
• Provide you with relevant content, including advertisements and other offers from third parties;
• Aggregate cookie data across all users to track overall visitor traffic patterns and provide this aggregated data to vendors, potential advisors, business partners, new agencies, or other parties to identify interests or plan for technical infrastructure requirements;
• Conduct advertising based on your use of the Website or Apps, as described below; and
• Otherwise provide improvements and enhancements to the Site.

We may also use third-party vendors, such as Google Analytics, to advertise to our users online. These third-party vendors may display Anytime Fitness® product advertisements on another website based on your internet usage. More specifically, these vendors use first-party cookies (such as the Google Analytic cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to the Website or another site affiliated with Anytime Fitness® products or services. Any data that these third parties collect via cookies is not linked to any personally identifiable data (name, address, email address, or phone number) we collect, or you provide on the website. You can opt-out of Google Analytics for Display Advertising by using Google’s Ads Settings.

4. Our Relationship with affiliate Websites

This website may contain links to other websites that may have integration with certain mobile applications. Additionally, other website may contain links to this Website. We do not review or monitor the website linked to the Website and are not responsible for the contents or privacy policies related to any other website. If you visit one of these other websites, you may want to review the privacy policy on that web site. Where this Website contains a link to another web site owned and/or operated by us, such web site use may be subject to its separate privacy policy and additional terms of service.

5. Your Rights

If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

Pursuant to applicable data protection laws you may have the right to: request access to your personal data, request rectification of your personal data; request erasure of your personal data, request restriction of processing of your personal data; request data portability, and object to the processing of your personal data. Please note that these aforementioned rights might be limited under the applicable national data protection law.

For further information on these rights please refer to the Exhibit – Your Rights. You also have the right to lodge a complaint with a data protection supervisory authority. To exercise your rights please contact us as stated in Section 9.

Opting Out or Unsubscribing

You may opt out of certain collections of cookies or other web or mobile device based enhancements, including geolocation data collection, by changing your browser settings or going into your preferences on your mobile device and restricting the transmission of certain data. Your limitation of the collection of this data, however, may disable our ability to provide you with the most relevant products or information regarding the Website and Apps. Currently, our servers do not respond to browser “do not track” signals. If you would like more information regarding online marketing practices and know your choices about not having this information used by our third party service providers, you may visit www.networkadvertising.org/choices.

To limit the integration of the Website and Apps with other related applications you may disable the application through your setting preferences on the Apps or delete the applicable application from your mobile device. Deletion of the application may not delete data previously obtained through the related application.

To unsubscribe from our emails or other communication from us or a third party, you may follow the “unsubscribe” link at the bottom of the email or sign onto your account and change your email settings. To unsubscribe from text messages or any other mobile messages, you may follow the instructions provided at the time of opt-in or submit your request through the inquiry form.

6. Security of Your Personal Data

We take reasonable precautions and have implemented managerial and technical procedures to try to protect the security of data and information, including personal data. However, we cannot guarantee against any loss, misuse, unauthorized disclosure, or alteration or destruction of data or personal data.

7. Retention of Your Personal Data

We keep your personal data only as long as we need it for the purposes for which it was originally collected (or to which you have subsequently consented) or for other legitimate purposes (such as regulatory compliance), or as permitted by applicable law.

When we no longer need to use your personal data, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information, including personal data, to comply with legal or regulatory obligations to which we are is subject, e.g. statutory retention periods, or if we need it to preserve evidence within the statutes of limitation, which is usually [three years] but can be up to [thirty years].

8. How to Contact Us

For further information or enquiries regarding your personal data (including to request access to or correction of your personal data or to make a privacy complaint), please contact our Data Protection Officer at:

Inspire Brands Asia Pte Ltd.
Attention: Data Protection Officer/ Compliance Officer for Data Privacy
1 Phillip Street, #09-00 Royal One Phillip, Singapore 048692
[DataPrivacy@inspirebrandsasia.com]

For questions, comments, or complaints related to this Privacy Policy or how we have collected or handled your personal data, please contact our Data Protection Officer at the mail address set forth above.

1. Right of access

You may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

You may have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

2. Right to rectification

You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3. Right to erasure (“right to be forgotten”)

Under certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

4. Right to restriction of processing

Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

5. Right to data portability

Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.

6. Right to object

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.