WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
WHAT PERSONAL DATA DO WE COLLECT AND WHEN?
We ask you for certain personal data to provide you with the products or services you request. For example, when you create an account, participate in challenges or fitness activities, or interact with our Platform.
This personal data includes your:
• contact details including first name, last name, corporate email, and job title and
• login and account information, including screen name, password and unique user ID;
• personal details including gender, date of birth;
• images, photos and videos;
• data on physical characteristics, including weight, height;
• fitness activity data provided by you or generated through our Platform (time, duration, distance,
location, calorie count, pace/stride); or
• personal preferences including your fitness aspirations.
We collect additional personal data from you to enable particular features within our Platform. For example, we request access to your phone’s location data to log your run route, your contacts to allow you to interact with your friends, your calendar to schedule a training plan or your social network credentials to post content from our Platform to a social network. This personal data includes your:
• movement data from your device’s accelerometer;
• photos, audio, contacts and calendar information;
• sensor data, including heart rate and (GPS) location data; or
• social network information, including credentials and any information from your public posts about BomFit or your communications with us.
• Device IDs, call state, network access, storage information and battery information.
• Cookies, IP addresses, referrer headers, data identifying your web browser and version, web beacons, tags and interactions with our Platform.
We comply with local laws and do not allow children to register on our Platform when they are under the legal age limit of the country in which they reside. We will ask for parental consent for children participating in Bomaid experiences and events.
TOOLS TO MANAGE WHAT PERSONAL DATA WE COLLECT
When using our Platform we also provide in-time notice or obtain consent for certain practices. For example, we will obtain consent to use your location or send push notifications. We may obtain this consent through the Platform or using the standard permissions available on your device.
In many cases, your web browser or mobile device platform will provide additional tools to allow you to control when your device collects or shares particular categories of personal data. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarize yourself with and use the tools available on your devices.
WHY AND HOW DO WE USE YOUR PERSONAL DATA?
We use your personal data in the following ways:
To Provide the Features of the Platform and Services You Request
When you use our Platform, we will use your personal data to provide the requested product or service. For
example, participate in an challenge, we will use the contact information you give us to communicate with you about the rewards or leaderboard. If you contact our customer services, we will use information about you, such as platform debugging report, to help us resolve a problem or question.
If you use our Platform to track your fitness activity or physical characteristics, we will collect this personal data and store it so that you can review it in the Platform. Your fitness activity data may include data you enter about your activity or data collected by your device during your activity such as location data and movement data. We may use this activity data to calculate further information about your activity, such as distance run, or calories burned, so that the calculated information can be provided to you as part of the functionality of the Platform.
In many cases, to use particular features within our Platform you may need to provide BomFit with additional data or additional consent to use particular data in a certain way. For example, to use the heart rate tracking features of our Platform, you may need to connect to a heart rate monitoring device. Similarly, to share content on social media, you may be required to provide your social media account credentials to sign in.
To Communicate Information about our Products, Services, Events and for Other Promotional Purposes
When you consent, we will send you marketing communications and news concerning Bomaid products,
services, challenges, rewards and other promotions that may be of interest to you. You can opt-out at any time after you have given your consent.
If you are an existing Bomaid member (for example, if you have product subscription with Bomaid Healthcare Fund), we may use the contact details you provided to send you marketing communications about similar Bomaid products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information.
We may use the information that you provide to us as well as information from other Bomaid products or
services – such as your use of Bomaid’s Platform, your participation in Bomaid rewards and challenges – to personalize communications on products and services that may be interesting for you. In doing so, we may combine the information you provide to us with information that we create about your online activity, including internal insights and analysis.
To Operate, Improve and Maintain our Business, Products and Services
We use the personal data you provide to us to operate our business. For example, when you are engage in
fitness and or wellness activities, we use that information to assess the Wellness and Health of our members and users. We may use personal data about how you use our products, services and platform to enhance your user experience and to help us diagnose technical and service problems and administer our Platform.
To Protect Our or Others’ Rights, Property or Safety
For General Research and Analysis Purposes
We use data about how our members use our Platform and services to understand member and user behavior or preferences. For example, we may use information on user fitness or wellness activities corelate to the overall health and health claims of members.
Use (Processing) of Workout Info
As discussed above, Bomaid collects data about your fitness activity or your physical characteristics, together, “Workout Info”, to provide services on our Platform. Because of the personal nature of this data, we strive to provide you with clear information about how Workout Info will be used. As this data may be considered sensitive in certain jurisdictions, we take appropriate measures in protecting and using this data and, where required by applicable law or under Bomaid’s internal policies, will obtain your consent for use of your Workout Info.
We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.
To process your personal data, we rely on certain legal grounds, depending on how you interact with our
• When you use our Apps, we rely on your consent for processing and for certain limited purposes to fulfill
our contract with you (for example, for challenge tracking).
• We also rely on other legal grounds, such as our legitimate interests as a business to process
information about the effectiveness of our marketing campaigns, our products, services, challenges and
other promotional initiatives; to operate, improve and maintain our business, products and services; to
protect our or others’ rights, property or safety; and for general research and analysis purposes. When
processing personal data for our legitimate interests, we take appropriate measures to ensure that the
interests we pursue are balanced with your interests, rights and freedoms, which we are happy to
explain upon request.
• We also process your personal data to comply with a legal obligation, or to protect your vital interests.
SHARING of Your Personal Data
Bomaid shares your personal data with:
• Bomaid entities for the purposes and under the conditions outlined above.
• Service providers processing personal data on Bomaid’s behalf, for example to host, manage and service our data, distribute emails, research and analysis, manage brand promotions and develop and administering certain services and features. When using service providers we enter into agreements that require them to implement appropriate technical and organizational measures to protect your personal data.
• Other third parties to the extent necessary to: (i) comply with a government request, a court order or
our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or
investigation (e.g., counterfeiting).
• To any other third party where you have provided your consent.
We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our
business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
When you use certain social features on our Platform, you can create a public profile that may include
information such as your screen name, profile picture and hometown. You can also share content with your friends or the public, including information about your BomFit activity. We encourage you to use the tools we provide for managing BomFit’s social sharing to control what information you make available through BomFit’s social features.
PROTECTION AND MANAGEMENT OF YOUR PERSONAL DATA
Encryption & Security
We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data.
International Transfers of your Personal Data
We take measures to comply with applicable legal requirements for the transfer of personal data to recipients in countries outside SADC. We use a variety of measures to ensure that your personal data transferred to these countries receives adequate protection in accordance with data protection rules; this includes signing the EU Standard Contractual Clauses or verifying the recipient has adopted Binding Corporate Rules. Where personal data is transferred within BomFIT, we use an intragroup data transfer agreement.
Retention of your Personal Data
YOUR RIGHTS Relating to Your Personal Data
You have the right to request: (i) access to your personal data; (ii) an electronic copy of your personal data
(portability) and to have this information transmitted to another company; (iii) correction of your personal data if it is incomplete or inaccurate; or (iv) deletion or restriction of your personal data in certain circumstances provided by applicable law. These rights are not absolute. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time. If you like would to request a copy of your personal data or exercise any of your other rights, please contact Portée Digital through email at Digital@Portee.co.uk
Opting Out of Direct Marketing
If you have a BomFIT account, you can opt-out of receiving BomFit’s marketing communications by modifying your preferences in the “view or change my profile” section of our Sites. You can also opt-out by modifying your email or SMS subscriptions by clicking on the unsubscribe link or following the opt-out instructions included in the message. You can also contact us using the contact details in the “Question and Feedback” section below.
COOKIES and Pixel Tags
BomFIt collects information, which may include personal data, from your browser when you use our Platform. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (i) IP address; (ii) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with our Platform such as click behavior, purchases and indicated preferences; and (ix) access times and referring URLs. Third parties may also collect information via our Platform through cookies, third party plug-ins and widgets.
These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies.
• Functional: These cookies are required for basic site functionality and are therefore always enabled.
These include cookies that allow you to be remembered as you explore our Platform within a single
session or, if you request, from session to session. They help make the shopping bag and checkout
process possible as well as assist in security issues and conforming to regulations.
• Performance: These cookies allow us to improve our Platform’s functionality by tracking usage. In some
cases, these cookies improve the speed with which we can process your request and allow us to
remember site preferences you have selected. Refusing these cookies may result in poorly-tailored
recommendations and slow site performance.
• Social media and Advertising: Social media cookies offer the possibility to connect you to your social networks and share content from our Platform through social media. Advertising cookies (of third
parties) collect information to help better tailor advertising to your interests, both within and beyond our Platform. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on
For a comprehensive and up-to-date summary of every third-party accessing your web browser (through
BomFIT Platform or otherwise), we recommend installing a web browser plugin built for this purpose. You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Platform more efficient and some of our services will not function properly. There are also general resources for opting out of interest-based advertising available on the website of the Digital Advertising Alliance.
Similarly, you can adjust your advertising preferences on your mobile device at the device level. For example, to adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads.
USING BomFIT Platform with Third-Party Products and Services
Our Platform allows you to interact with a wide variety of other digital products and services. For example, our Platform can integrate with third-party devices for activity tracking, social networks, music streaming services and other digital services. If you choose to connect your BomFIT account with a third-party device or account, your privacy rights on thirdparty platforms will be governed by their respective policies. For example, if you choose to share your BomFIT activity on third-party social media platforms, the policies of those platforms govern the data that resides there.
Our Platform may provide links to other (third-party) websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.
QUESTIONS and Feedback
If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal data, please email Digital@portee.co.uk
Our Data Protection Officer’s contact details are: Portée Legal Office, Portée Group
Plot 75749 Setlhoa Village Sebele Gaborone, Botswana or Digital@portee.co.uk.
If you contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner. You also have the right to lodge a complaint with the relevant supervisory authority in the country in which you reside.