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Privacy Policy – CREW by True Rowing

Effective date: February 15, 2019

CREW by True Rowing (“CREW” or “us” or “we” or “our”) provides a variety of fitness products, services, content, and features though our website (www.hydrow.com), Hydrow, and CREW’s Live Outdoor Reality Rower (LOR)™, and through our mobile device application (including Android and IOS applications) (the “App”), and through certain CREW-controlled social media pages social media pages (including Facebook, Instagram, Twitter and YouTube) (all such products, services, content and features collectively described herein as the “Services”).

This privacy policy (the “Privacy Policy”) has been complied to better serve those who are concerned with how our policies regarding the collection, use and disclosure of information, including information that can be used to identify you (directly or indirectly) (“Personally Identifiable Information” or “PII”) when you use our Services and the choices you have associated with that data is being used online, as described in U.S. privacy laws and regulations. If you do not accept this Privacy Policy, then please do not access or use the Services.

We will not use or share your PII with anyone except as described in this Privacy Policy. By using the Services, you agree to the collection and use of information in accordance with this policy.

Information Collection

We collect several different types of information for various purposes to provide and improve our Services to you.

While you use the Services, contact us directly, or engage in certain activities such as registering for an account, we may ask you to provide us with certain Personally Identifiable Information which may include, but is not limited to:

  • First name
  • Last name
  • Email address
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • User Profile Data
  • Cookie and Usage Data

User Profile Data

When you use the Services, you may be asked to create a “User Profile” and provide PII about yourself such as your username, first name, last name, phone number, address, email address, weight, height, gender, age, birthday, phone number, and/or image or avatar.

Once you create your User Profile, anytime you log-in to participate in a CREW workout, we will also collect additional information relating to your account such as the total number of workouts you participated in, the dates you took the workouts, and fitness performance history i.e. leaderboard rank, achievement badges earned, speed, distance, and calories burned.

User Provided Information.

We may also collect information when you provide us with feedback, contact us with a question or comment, or provide information in public forums through the Services.

Payment Information

We do not collect, store, or maintain your financial information. When you make purchases through the Services, we process your payments through a third-party payment processor. In these instances, the third-party application may collect financial information from you to process a payment on behalf of CREW, including your name, email address, address, and other billing information in which case the use and storage of your financial information is governed by the third-party terms, conditions, and privacy policies.

Usage Data

We may also collect information that your browser sends whenever you access our Services through a rower, app, desktop, mobile device, or other method (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), cookie identifier, MAC address, IMEI, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Services with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information.

Cookies are files with a small amount of data which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.

We use this information to understand traffic and the usage of the Services, enabling us to improve the Services, provide the best online experience possible, and improve our customer service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Services.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. Check the help menu in your browser’s or device’s help or support menu for further information. Remember that if you disable cookies, you may not be able to use some portions of the Services. Unless you have adjusted your browser settings so that it will refuse cookies, our system Services will place cookies when you log on to the Services.

Sweepstakes Registration Data

Periodically, CREW may run a sweepstake. We ask those who enter in the sweepstakes to provide contact information i.e. phone number, email address, or other relevant information pertaining to the sweepstakes. If you participate in a sweepstakes, your information may be used to reach out to you about the sweepstakes, and, to the extent permitted by law, for other promotional, marketing and business purposes.

Data Provided via Third Parties.

We may receive about you from third parties. For example, to the extent that we offer access to the Services through a third party platform or log-in, we may also collect your email address and other information associated with that third party, and any information you have made public in connection with that service or which the third party shares with partner services. Our treatment of the information you provided to them, which they provided to us, is subject to the terms of this Privacy Policy. See also the “THIRD PARTY WEBSITES AND LINKS” section below.

Third Party Analytics

We use third parties’ analytic and tracking tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content, and to help those parties serve more targeted advertising to you across the Internet or help us serve more targeted advertising to you. Those third party companies may use cookies, pixel tags or other technologies to collect and store Non-PII such as time of visit, pages visited, time spent on each page of the Service, device identifiers, type of operating system used and other website(s) you may have visited. They might combine data they collect from your interaction with Services with PII they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.

Use of Data

CREW uses the collected data for various purposes:

  • To provide you with and to maintain our Services
  • To administer your User Profile.
  • To notify you about changes to our Services
  • To allow you to participate in interactive features of our Services when you choose to do so.
  • To provide customer support and communicate with you about your User Profile or transactions with us.
  • To gather analysis or valuable information so that we can improve our Services
  • To monitor the usage of our Services
  • To detect, prevent and address technical issues.
  • To personalize and improve the Services and user experiences, to increase the functionality and user friendliness of the Services, to deliver content or features that match User Profiles or interests.
  • To detect, investigate and prevent activities that may violate our policies or be illegal.
  • To provide you with news, special offers and general information about other goods, services and events which we offer that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Retention of Data

CREW will retain your PII only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your PII to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, establish legal defenses, conduct audits, pursue legitimate business purposes, and to continue to develop and improve our Services.

CREW will also retain Usage Data for internal analysis purposes. This data is used to strengthen the security of our Services, to improve the functionality of our Services, to satisfy legal obligations, and other uses. Information is not retained when otherwise prohibited by law or regulation.

Transfer of Data

Your information, including PII, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the information, including PII, to United States.

Disclosure of Data

CREW will not share your PII outside CREW except in the following limited circumstances, which you consent to:

  • When you allow us to share your PII with another company, such as directing us to share your PII with third-party platforms or log-ins.
  • When we contract or partner with third party companies and individuals to facilitate the Services (“Services Providers”), provide the services on our behalf, to perform complementary services and /or to assist us in analyzing how the Services are used. Examples may include storage data, delivering messages, analyzing data, providing marketing assistance, managing our agreements with you, supplementing the data you provide us in order to provide you with better service, and providing customer service. We do not transfer data to non-agent third parties. These third parties are given access PII to perform specific tasks on our behalf.
  • In connection with the sale of a business (including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings).
  • To comply with law enforcement and legal process, such as, a court order, or subpoena.
  • To prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity.
  • To protect and defend yours, ours or others’ rights, property, and safety.
  • To enforce CREW’s policies or contracts.
  • To prevent or investigate possible wrongdoing in connection with the Services.
  • To protect against legal liability.

In addition, we may share anonymized and aggregated data sets with third parties,.

Security of Data

The security of your data is important to us and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the Internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the PII we have collected from you.

Our Policy on “Do Not Track” Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform such websites and services that they do not want certain information about their website visits collected over time and across websites, platforms, or online services. Please note that we do not respond, support, or honor DNT signals or similar mechanism transmitted by web browsers.

Third Party Websites and Links

CREW’s website may contain links to other websites or online platforms operated by third parties and other websites may reference or link to the Services. These other domains and websites are not controlled by us, and CREW does not endorse or make any representations about Third-Party websites or social media platforms. We do not control such other websites or online platforms and are not responsible for their content, their privacy policies, or their use of your PII. We encourage you to read the privacy policies of each and every website, platform, and application with which you interact. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or application.

Please keep in mind that data you post on public or semi-public venues, including data you share on third party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. When you provide data to a third-party online platform, the data you provide may be separately collected by that third-party. The data the third-party online platform collects is subject to the third-party online platform’s privacy practices. Privacy choices you make on the third-party online platform will not apply to our use of the data we collect directly through the Services.

Visiting other websites, platforms, and applications is at your own risk. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of PII by third parties.

Analytics

We may use third-party Services Providers to monitor and analyze the use of our Services.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Advertising

We may use third-party Services Providers to show advertisements to you to help support and maintain our Services.

Google AdSense DoubleClick Cookie

Google, as a third-party vendor, uses cookies to serve ads on our Services. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Services or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Behavioral Remarketing

CREW uses remarketing services to advertise on third party websites to you after you visited our Services. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Services.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

AdRoll

AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1nt=1nw=false. For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

Children Online Privacy Protection (COPPA) Act

Our Services are not directed to children under 13 years of age. In addition, you are not permitted to use our Services if you do not meet the minimum age requirements to our Services in your jurisdiction. We do not knowingly collect PII from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with PII, please contact us at support@hydrow.com. If we learn that we have collected PII of a child under 13 years of age, we will take steps to delete such PII from our files as soon as possible.

California Privacy Rights

This Privacy Policy describes how we may share your PII for marketing purposes. It applies to all users of the Services, including California residents. California law additionally permits California residents to request and obtain from us once per year, free of charge, a list of third-parties to whom we have disclosed their PII (if any) for direct marketing purposes in the prior calendar year, as well as the type of PII disclosed to those parties. See How to Contact Us below.

If you are a California resident under the age of 18, you may request to have your posted content or information removed from the publicly-viewable portion of these Services by changing your privacy settings on your Profile page or contacting us directly by emailing support@hydrow.com.  Content or Data may not be removed from our systems or databases.  In certain situations not all information can be removed from our systems or databases.

Other Privacy Rights

The Services and this Privacy Policy are intended for individuals residing in the United States. We acknowledge individuals’ residing outside of the United States may have privacy rights in addition to those described in this Privacy Policy. Where permitted by applicable law, you may request access to your PII via email to support@hydrow.com, and ask that we correct, amend or delete your PII where it is inaccurate or has been processed in violation of your rights under applicable data privacy laws in your country of residence. Although CREW makes a good faith to provide individuals with access to their PII, there may be circumstances in which CREW is unable to provide access, including but not limited to – where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense or providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary.

If CREW determines that access should be restricted in any particular instance, we will provide you with an explanation of why such determination has been made and a contact point for any further inquiries. To protect your privacy and security, we will also take reasonable steps to verify your identity before updating or removing your information.

Contacting Us

If you have any questions about our privacy policies, this Privacy Policy, or how to submit a complaint with the appropriate authority, please contact CREW at support@hydrow.com or by mail at the address below. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

CREW by True Rowing

14 Arrow Street, 4th Floor

Cambridge, MA 02138

Changes to This Privacy Policy

We may update our Privacy Policy from time to time in which case we will update the “Effective Date” at the top of this Privacy Policy. We will use reasonable efforts to provide notice to you and obtain your consent as required by applicable law. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.