Solidcore Holdings, LLC
Effective Date: January 2022
Important note about children’s privacy: We take children’s privacy very seriously. We do not intentionally gather personal information online from visitors who are under the age of 13. If a child under 13 submits personal information to [solidcore] online and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information collected online from a child under 13, please contact us at firstname.lastname@example.org.
1. Information We Collect
We collect information from you when you contact us, register with our Website or App, reserve classes, make a purchase, or otherwise interact with our Website or our App. The type of information that we collect varies based on your interaction with us and may include: your name, email address, password, and phone number, and, if you make a purchase from us, payment information, purchase history, and shipping address. If you provide this information directly to one of our coaches or managers, we may associate this information with your account.
We automatically collect information about your use of our Website and App through cookies, web beacons, and other technologies, including technologies designed for mobile apps. We combine this information with other information we collect about you as well as use this information to identify you across your multiple devices. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
-Your browser type and operating system.
-Web pages you view; links you click; your IP address.
-The length of time you visit our Website.
-The referring URL or the webpage that led you to our Website.
-Mobile device ID; device name and model; operating system type, name, and version.
-Activities within the App; and the length of time that you are logged into our App.
-Location information. With your permission, we will collect location information from your mobile device to help you locate the nearest [solidcore] location and to send you push notifications, such as promotional notices when you are near a studio. You may turn off this feature through the location settings on your mobile device.
-With your permission, we may access your mobile device’s calendar to help you keep track of your upcoming classes.
-Contact list. With your permission, we may access your contacts to identify your emergency contact and upload your contact list and store it on company servers in order to suggest friends who also take classes to enhance the community of [solidcore].
2. How We Use Your Information
We use your information, including your personal information, for the following purposes, and as otherwise permitted by law:
-To provide our information to you, to communicate with you about your use of our services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
-To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Website and App.
-For marketing and promotional purposes. For example, as permitted by applicable law, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third party products and services. We also may use the information that we learn about you to assist us in advertising our services on third party websites and social networking sites.
-To send you push notifications (you may opt-out through the settings in your device).
To better understand how users access and use our Website and App, both on an aggregated and individualized basis.
-To evaluate, improve, or modify our Website, App, and Services, including our services offered in our studios.
-For research and analytical purposes.
-To administer surveys and questionnaires.
-To comply with applicable legal obligations, including responding to a subpoena or court order.
-For other business-related purposes, including, for example, in the context of merger, acquisition, sale/purchase of assets, or bankruptcy.
-To protect us and others.
3. How We Share Your Information
We may share your information, including personal information, as follows:
Affiliates: We may disclose the information we collect from you to our affiliates or subsidiaries, including for their own direct marketing purposes.
Service Providers: We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. For example, we share your information, both on an individual basis or in the aggregate, with third parties to assist us in advertising our products and services and to assist us in determining relevant advertising. These third parties may include entities that assist us and other companies with communicating with you and serving advertisements to you, including advertisements on third party websites, social media platforms, as well as through push notifications and email.
We may also share information in the following circumstances:
Partners: We may disclose the information we collect from you with our partners, including for their own direct marketing purposes. For example, we disclose information to our partners in connection with offering co-branded services, selling or distributing products or services, or engaging in joint marketing activities or promotions.
Business Transfers: If we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
In Response to Legal Process: We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others: We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which [solidcore] is involved.
With Your Consent or at Your Request: We may disclose the information we collect from you with your consent or to facilitate your requests.
Aggregate and De-Identified Information: We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
4. California Consumer Privacy Act
These additional disclosures for California residents apply only to individuals who reside in California.The California Consumer Privacy Act of 2018 (“CCPA”) gives California residents certain rights with respect to their personal information. If you are a California resident, we are committed to compliance with CCPA. Under CCPA, you may have the right to make certain requests:
Notice of Collection
Although the information we collect is described in greater detail in “Information We Collect” above, the categories of personal information that we have collected in the past 12 months – as described by the CCPA – are:
- Identifiers, including name, email address, and IP address.
- Customer records, phone number, billing and shipping address, and credit or debit card information.
- Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, including purchases and engagement with the Services.
- Biometric information, if you use the identified connected equipment or wearable devices at certain SoulCyle studios, we may collect heart rate information and performance metrics.
- Internet activity, including your interactions with our Services.
- Audio or visual sensory data, including pictures or videos you post on our Services and closed circuit monitoring of our studios.
- Geolocation data, including location enabled services such as WiFi and GPS.
- Employment and education data, including information you provide when you apply for a job with us.
- Inferences, including information about your interests, preferences and favorites.
For more detail on the information we collect and when, including the sources we receive information from, please review The Information We Collect above. In the past 12 months, we have collected and used information from all of the above categories for the business purposes described in the How We Use Your Information section, including to provide and manage our Services.
You may have the right to know about personal information that we have collected, disclosed, or sold, including:
- The categories of personal information we have collected or shared about you in the preceding 12 months,
- The categories of sources from which we have collected that information in the preceding 12 months,
- The commercial or business reason(s) we have collected or shared that information, and
- The categories of third parties with whom we have shared or to whom we have sold that information in the preceding 12 months.
In addition, upon receipt of a verifiable request from you establishing your identity, we may be obligated to disclose specific pieces of personal information that we have collected about you. Under some circumstances, you may have the right to request deletion of some or all of that information. You may be entitled to designate an authorized agent to exercise these rights on your behalf.
CCPA also gives California residents the right to direct businesses not to sell personal information. At any time, you may opt-out of any future disclosure that could qualify as the sale of personal information by submitting a privacy-related request as described below.
California residents also have the right to delete the personal information we have collected from you and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
To make a privacy-related request, including a request related to the exercise of your rights under the CCPA or any other law, please email us at email@example.com. Requests for access to or deletion of personal information are subject to our ability to reasonably verify your identity. In order to do so, we may ask you to provide additional information that can be matched with information that we maintain.
Please note that we will not treat you in a discriminatory fashion as a result of your election to exercise any rights you have under CCPA.
Cookies: Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and our App, while others are used to enable a faster log-in process or to allow us to track your activities at our Website or our App.
Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse certain areas of the Website, but some features may not function.
Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Website and our App to, among other things, track the activities of our Website visitors and App users, help us manage content, and compile statistics about Website and App usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. We also use third party SDKs to, among other things, track our conversions, associate with your account how you use our Website and our App when you are not logged in to the account, and bring you advertising both on and off our Website and our App.
Cross Device Use: We may use the information that we collect about you (whether directly from you from our Site, App, or in-store purchase activities, through your device(s), or from a third party) to help us and our third-party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We, and our third-party service providers, also may use the cross-device tracking and other information we learn about you to serve targeted advertising on your devices, to send you push notifications, and to send you emails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Third-Party Ad Network section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt-out each browser or device that you use.
Do-Not-Track: There is no industry do-not-track standard; [solidcore] has processes in place that are designed to recognize web browser “do-not-track” signals. The Help portion of the toolbar on most browsers will tell you how to use your web browser’s do-not-track feature. Please be advised that we cannot guarantee that our processes will capture all such do-not-track signals. You also may disable certain tracking as discussed in this section (e.g., by disabling cookies); you may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section.
6. Third-Party Networks
Users in the United States may opt out of many third-party ad networks, including those we work with on our Website and App. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Customer Matching: We use third-parties to serve advertisements targeted to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to the third-party (such as through Facebook Custom Audiences or Google Customer Match) or incorporating a pixel from the third-party on our Services, and the third-party matching common factors between our data and their data. We may also work with partners to deliver Matched Ads based on data about you and others in those partners’ own databases or match the partner’s data against our own customer lists. To opt-out of us using your data for Matched Ads, please contact us as at firstname.lastname@example.org and specify that you wish to opt-out of Matched Ads. We will request that the applicable third-parties not serve you Matched Ads based on information we provide to it. You may also contact the applicable third-party to opt-out. We are not responsible for such third-party’s failure to comply with our or your opt-out instructions.
Third-Party Links: Our Website and App may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
7. Security and Access of Personal Information
Security of Your Personal Information: We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite these measures, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access to Your Personal Information: You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or App for a period of time.
Promotional Emails: We may send periodic promotional emails to you. You may opt-out of our promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
8. Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at email@example.com.
9. Changes to this Policy
This Policy is current as of the Effective Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Website and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website and App.