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PRIVACY POLICY
CARONIFIT Online Fitness

YOUR PRIVACY AND COVID-19

This Privacy and Covid-19 Notice was last updated on November 13, 2022.
 

As the current circumstances and the needs of our community evolve, this Privacy Notice may be modified or updated in CaroniFIT®’s sole discretion. If we make any changes to this Privacy Notice, we will post the revised document here and such changes will be effective immediately upon that posting. Please review this Privacy Notice periodically to ensure you are aware of any changes.
 

  • What Information We’re Collecting: We may collect certain COVID-19 related information, including the following (“Screening Information”):

    • Health declaration:We may collect information about your potential exposure to COVID-19 through health declarations or questionnaires we may require you to complete. As part of this, we may record in our systems your acknowledgments of the health declaration and other information related to the declarations.

    • Contact Tracing:We may collect information provided by you, or a public health authority or other government agency, if you test positive for COVID-19, including information about how you interacted with CaroniFIT® during the time in which you may have been infected with COVID-19.
       

  • How We Use Screening Information:We use Screening Information to help provide a safe environment for our employees and members; to determine any potential COVID-19 exposure; to administer your membership, including managing our proof of vaccination status policy; and to as may be otherwise necessary to otherwise satisfy any obligations under applicable law or governmental requirements. If you choose to provide optional information regarding the type of vaccine you received and/or the date of your last vaccine dose, we will use this information only to help manage any future changes to our COVID-19 vaccination policy, such as determining if you need to provide proof of a required booster dose (if one becomes required). We will use Screening Information only in furtherance of those legitimate interests and business purposes. We reserve the right to use and disclose aggregated, de-identified information for any lawful purpose, such as our analytics and reporting. However, we will never use your Screening Information for any marketing, advertising or promotional purposes.
     

  • How We May Share Screening Information:While we generally will not share your Screening Information without your consent, we reserve the right to disclose Screening Information, and other related information, to the extent required to do so by subpoena or applicable governmental or regulatory authorities or as otherwise necessary or appropriate in furtherance of public health or safety. We may also share your Screening Information and other related information with service providers, advisors or consultants who are performing services on our behalf and for other reasons in accordance with applicable law, as further described in the “Sharing of Personal Data” section of our Privacy Policy
     

  • How We Retain Screening Information:Your Screening Information will be protected as described in our Privacy Policy. We reserve the right to record and indicate in our systems your acknowledgements of the health declaration, your vaccination status, and other related records or information. Except as noted above, any of these records and other types of Screening Information, such as health declarations and your vaccination status, that we retain will be stored for a reasonable period of time, including as we determine necessary to comply with applicable law or to establish or defend our legal rights.
     

PRIVACY POLICY

Effective Date: November 13, 2022
 

Overview
 

Carolina Nieto, CaroniFIT®, and its subsidiaries operating under the CaroniFIT® brand (collectively, “CaroniFIT®,” “we,” “us,” “our”) respect your privacy and are committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Policy or our processing of personal data, please see the bottom of this Privacy Policy for information about how to contact us. CaroniFIT® is the data controller of the personal data collected, and is responsible for the processing of your personal data.


This Privacy Policy explains our practices with respect to personal data we collect and process in connection with your relationship with us. This includes information we collect through, or in association with, our website with a home page located at caroniFIT.com, any related apps that we may provide, together with all products and services we may offer from time to time via our website and/or related apps, our related social media sites, or otherwise through your interactions with us (the website, apps, products, services, and social media pages, collectively, the “Services”). 


If you are providing information through the Services on behalf of someone else (e.g., a colleague, employee, family member, friend, significant other, etc.) you hereby represent that you have the right to do so and that you have provided such party with a copy of this Privacy Policy, and all references to “you” or “your” data or personal data herein refers to the data or information of both you and such individual, as applicable.
 

Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website, or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Policy. This Privacy Policy may be revised from time to time, so please ensure that you check this Privacy Policy periodically to remain fully informed.
 

Table of Contents

Overview

What Information Do We Collect?

How Do We Process Personal Data?

Protecting Personal Data

Retention of Personal Data

Your Rights Regarding Personal Data

Your Choices

Other Important Information About Personal Data and the Services

Modifications and Updates to this Privacy Policy

Applicability of this Privacy Policy

Additional Information and Assistance

 

What Information Do We Collect?
 

We collect a variety of personal data from and about you through the Services, including:

  • When you provide it to us directly, whether by signing up for an account on our online Services and/or becoming a CaroniFIT® member; through our apps, websites, and social media pages; or in-person

  • Automatically through digital logging and analytics tools, cookies, and pixel tags; and as a result of your use of and access to Services, both in person and online; and

  • From third-party sources, including corporate health initiatives, membership, and wellness programs; ad networks that provide online behavioral advertising and retargeting/remarketing services; service providers such as commercial email and marketing providers, sweepstakes providers, and survey providers; third-party platforms where we post job openings; analytics providers such as Google Analytics and Adobe Omniture; and through your interactions with us or our accounts and pages on social media websites. In addition, we offer features that enable users to connect their third party fitness devices or third party applications (collectively “Third Party Apps”) to the Services in order to utilize certain features and functionalities, and we collect information from certain Third Party Apps when these features are used.
     

You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services. In addition, as described below in the section captioned “Your Choices” it is possible to change your browser settings to block the automatic collection of certain information.
 

Finally, we may collect data from or about you that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.
 

Information You Share With Us.

We collect personal data from you when you provide it to us, including when you sign up for a CaroniFIT® membership, trial membership, sweepstakes, or user account; fill out CaroniFIT® forms, surveys, and questionnaires; place orders for products or services, interact with us on social media; or contact us with questions or comments.
 

For example, if you sign up for a CaroniFIT® membership, we collect your first, middle, and last name, email address, mailing address, billing address, payment information, birth date, employer, gender, telephone number, photograph, order history, and any other information you may optionally provide. You may also be asked additional optional questions about your lifestyle, fitness goals, and your interest in additional CaroniFIT® services such as personal training and/or group classes.
 

If you purchase products or services (such as merchandise, and/or personal training appointments) from us, you must provide us with information to process that request, (including but not limited to member name credentials, email address, first and last name, billing address, shipping address (if applicable), payment information, and any other information you may optionally provide, such as telephone number).
 

You can choose to sign up for email notifications about us and/or our affiliates through the Services by providing us with your email address. We also collect information you enter into forms on the Services, even if you do not finish filling out the forms or click “Submit” at the end. You can also choose to sign up to receive text messages from us through the Services by providing us with your mobile number.


If you contact us with questions, requests, or complaints, or to exercise your legal rights, we collect personal data sufficient to answer your questions, address your requests, and/or handle your complaints, as applicable. In certain situations, we may also require you to provide personal data to authenticate your identity in order to carry out your requests.
 

Information Collected Automatically.

When you use our Services we collect information about your use of the Services.

  • Cookies, Web Tracking, and Analytics. When you browse or use our online Services, we utilize commonly-used logging and analytics tools, including Google Analytics and Adobe Omniture, to collect information about your device, the network used to access the Services, and information about your use of the Services (such as how you navigate and move around the Services).


Information collected automatically through use of our online Services includes the software and hardware attributes of the device you use to access the Services, unique device ID information, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files and third-party analytics that record website activity. For example, log file entries and analytics data are generated every time you visit a particular page on our website, download our app, use our app, and track the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, your interactions with the Services, other similar usage information, and general data (including the name of the web page from which you entered our website).


We also use certain technologies on our online Services, including cookies and pixel tags, that allow us, our service providers, and other third parties to store information locally on your device, identify your device, track your activity within our Services, track your interactions with other sites or with our email campaigns, and track activity over time and across websites and devices.


These technologies allow us to personalize and enhance your experience in regard to our Services, to save and collect information entered into forms on the Services, to collect data about your visit to our Services (including learning about how our users navigate and use the Services), to help diagnose problems with our servers, to administer the Services, to evaluate the effectiveness of our marketing and advertising campaigns, to permit analytics providers to gather information about your visit to the Services, to permit advertisers to collect information about your online activity and target advertising to you that is relevant to your interests as determined from your online activity (also known as “online behavioral advertising”), and to gather broad demographic information about our users.


Please see the Your Choices section of this Privacy Policy for more information about cookies and other web tracking technologies on the Services; for information about how you can reject, delete, or prevent cookies from being placed on your system; and how you can opt out of, limit, or prevent certain web tracking technologies and/or advertising providers from collecting information about you.

  • Online Behavioral Advertising. We allow third parties, including Google (and its DoubleClick ad network), Bing Ads, Criteo, and others, to use cookies, pixel tags, and other tracking technologies to track your online activity over time and across websites, recognize repeat visitors to the Services, and collect information about your interests and demographics based on your browsing habits and online actions. We use this information to learn about our visitors and deliver our advertisements on sites across the Internet (including on Google, Bing, Facebook, and LinkedIn). For more information about these ad networks, including how to opt out of certain tracking items, please see the Your Choices section of this Privacy Policy.

  • Location Information: If you permit the Services to access information about your device’s location (including global positioning system (“GPS”) or general location information derived from the network you use to access the Services), we collect the precise or general location information provided by your device to market to you, serve member content (including advertising, promotions, and notifications) based on location, and make the check-in and payment process more convenient for our members. See the Your Choices section below for more information about how to disable or limit the collection of GPS data.
     

Information Obtained from Third Parties.
 

We receive personal data from partners. For the purposes of this Privacy Policy, “partners” means service providers, licensors, vendors, manufacturers, distributors, affiliates, or other third parties with which we have a business relationship.
 

These partners include service providers and vendors that provide live chat functionality on the Services; commercial email providers; marketing and advertising services; survey, special offer, and sweepstakes providers; and analytics providers such as Google Analytics and Adobe Omniture. We also receive personal data from the operators of third-party job sites and platforms where we post job openings.

If you choose to interact with us or our partners on social media such as by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, interacting with or commenting on our posts or pages, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.
 

As described above, if you connect Third-Party Apps to the Services in order to utilize certain features and functionalities, we collect information from such Third Party Apps when these features are used.
 

How Do We Process Personal Data?
 

We process personal data for two general purposes:

  • For our business operations (including communicating with you, fulfilling orders, providing information about our products and services, improving the Services, and complying with applicable legal requirements); and

  • To market and promote our, and our partners’, products and offerings.
     

We disclose personal data to our service providers and partners to allow them to provide services to us and assist in carrying out your requests, and to our partners in aggregate, demographic form in connection with our marketing and business development efforts.
 

In addition, we may disclose information we maintain, including personal data: when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity or security of the Services or our interests, rights, property, or safety, and/or that of our personnel, members, users, visitors, and others.


See the Your Choices section below for information about how you can make decisions about how we process personal data, including how to opt out of certain marketing communications.
 

Operational Uses.

We process your personal data as part of our operations, which include:

  • Processing orders and enrollments, providing you with information tailored to your requests, responding to inquiries, and delivering services and products;

  • Providing a more personalized, relevant, and curated experience to our members, users, and personnel.

  • Evaluating queries and applications for employment.

  • Operating, maintaining, and improving the quality of the Services and the services, content, and products we make available through the Services;

  • Communicating with you by email, mail, text message (SMS, MMS), telephone, push notification, and other methods of communication, in each case with your consent, if such consent is required in accordance with applicable laws, about products, services, order status, and other topics

  • Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;

  • Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our personnel, members, users, visitors, and other third parties; and

  • For other purposes, as permitted or required by law.
     

Marketing Uses.

We process your personal data to send messages to you about us, our partners, and the products and services we and our partners offer, which may from time to time include contests, rewards, sweepstakes, events, new offerings, and special offers for products and services.

Personal data you enter into incomplete or unsubmitted forms on the Services may be processed to send you reminders about completing the forms, as well as to save that information to make completing the forms easier. These communications will only occur with your prior consent, if such consent is required in accordance with applicable laws.
 

We also process personal data collected through social media platforms and web tracking technologies to market to and understand our audience.
 

We do not disclose personal data to third parties for their own direct marketing purposes.
 

Sharing of Personal Data.

Some of the above processing involves sharing collected personal data with third parties, including service providers, affiliates, and other partners.

  • We share personal data with third parties when you ask us to do so;

  • We share personal data we collect in aggregated, demographic form, with certain partners and prospective partners in order to provide us and/or our affiliates and partners with information about the use of the Services and levels of engagement with the Services, to allow us to enter into new business relationships, and to allow us to market products or services on their behalf; and

  • We share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law.


Protecting Personal Data

We employ reasonable physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data.
 

However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

Retention of Personal Data.
 

We retain personal data to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our personnel, members, users, and other third parties.
 

Your Rights Regarding Personal Data

You have a variety of legal rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us as provided at the end of this Privacy Policy, or by following instructions provided in this Privacy Policy or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests.

Note, however, that we may request certain reasonable additional information (that may include personal data) to help us authenticate the request and/or to clarify or understand the scope of such requests.


These rights vary depending on the particular laws of the jurisdiction applicable to you.


Accessing, Modifying, Rectifying, and Correcting Collected Personal Data.


We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.


If you wish to access, review, or make changes to certain personal data you have provided to us through the Services, you may do so by contacting us as provided below.
 

In accordance with applicable law, you may have the right to access or obtain from us certain personal data in our records by contacting us as provided at the end of this Privacy Policy. Please note, however, that we reserve the right to deny access as permitted or required by applicable law.
 

Your California Privacy Rights.

California residents, see our “CALIFORNIA PRIVACY NOTICE” section below for more information about certain legal rights.


Your Choices

In addition to your choices with respect to the collection of personal data (see What Information Do We Collect? above), you have the ability to make certain choices about how we communicate with you, and how we process certain personal data.
 

Communications Opt-Out.

You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Policy.
 

Note that if you do business with us, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).
 

If you signed up to receive text messages from us, you may opt out any time by texting “STOP” to the number from which you are receiving the text messages. Please read our Terms of Use for additional information and terms that apply to our text message program.

Location Information.
 

If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.
 

Cookies, Web Tracking, and Advertising.

You may opt out of certain tracking technologies through your device’s or browser’s cookie and/or advertising settings (including by blocking, deleting, or restricting cookies, or resetting your device’s applicable advertising ID). Consult your device and/or browser documentation for more information about how to do this.
 

Please note that blocking, deleting, or restricting cookies may negatively affect the performance or certain functionality of the Services, and opting out of online behavioral advertising will not prevent the delivery of ads, but rather may result in more repetitive and/or less relevant advertisements.
 

To opt out of many online behavioral advertising mechanisms, including Facebook, Google, Bing Ads, Criteo, and others, you can use the Network Advertising Initiative’s Consumer Opt-Out service and/or the Digital Advertising Alliance’s Consumer Choice Tool.


If you would like to opt out of Google Analytics, and certain Google advertising functionality, you may do so using Google’s opt-out tool.

To opt out of Criteo’s retargeting and online behavioral advertising services, consult Criteo’s Privacy Policy.

For information about opting out of Kochava’s analytics services, consult the Opt-Out & Right to be Forgotten section of Kochava’s “Privacy” page.
 

Other Important Information About Personal Data and the Services.
 

Our Privacy Policy also includes information about other practices with respect to personal data, including:

  • Collection of personal data from children;

  • Links and references to third-party websites and services on our Services:

  • What happens to personal data in the event we sell or transfer some or all of our business; and

  • Information about where we process and transfer personal data.
     

Collection of Personal Data from Children.

We offer CaroniFIT® membership to individuals who are at least 18 years of age. We also permit teenagers that are at least 14 years of age (16 years of age in California) to join with written parental consent. Similarly, the Services are intended for use by adults and authorized individuals aged 14 to 18 (16 to 18 in California), and by using the Services, you represent that you are 18 years of age or older, or are 14 years of age (16 years of age in California) or older and have valid parental consent to do so. Children under 14 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 13.

Third-Party Apps, Websites and Services.
 

As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business (including, but not limited to, Third-Party Apps, social media platforms, Google Maps, third-party partnerships, job application sites, and Amazon Web Services. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services or Third-Party Apps. You access these third-party services and Third-Party Apps at your own risk. This Privacy Policy does not apply to any Third-Party Apps or services; please refer to the privacy notices or policies for such third-party services for information about how they collect, use, and process personal data.
 

Business Transfer.

We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
 

International Use.

Your personal data will be stored and processed in the United States and other jurisdictions. If you are using the Services from outside the United States, by your use of the Services you acknowledge that we will transfer your data to, and store your personal data in, the United States, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States.

Modifications and Updates to this Privacy Policy
 

This Privacy Policy replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Policy. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Policy, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your acknowledgement of the amended Privacy Policy.
 

Applicability of this Privacy Policy

This Privacy Policy is subject to any agreements, including your Membership Agreement(s), service agreements such as Terms of Use, and any Service- or product-specific terms that govern your use of the Services. This Privacy Policy applies regardless of the means used to access or provide information through the Services.
 

This Privacy Policy does not apply to information from or about you collected by any third-party services, Third-Party Apps, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
 

Additional Information and Assistance

If you have any questions or concerns about this Privacy Policy and/or how we process personal data, please contact us at: caroni013@gmail.com 
 

Notice of Collection and Use of Personal Data

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.
 

Categories of Personal Data

Within the last twelve (12) months, we have collected the following categories of personal data:

  1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as your name, account or mailing address, phone number, and credit card number or debit card number.

  3. Characteristics of protected classifications under California or federal law, such as gender.

  4. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

  6. Geolocation data.

  7. We will not collect additional categories of personal data other than those categories listed above. If we intend to collect additional categories of personal data, we will provide you with a new notice at or before the time of collection.
     

Use of Personal Data
 

We collect and process your personal data for our business and commercial purposes, which include the following:

  1. Processing orders and enrollments, providing you with information tailored to your requests, responding to inquiries, and delivering services and products;

  2. For marketing purposes, including sending messages (including text messages) to you about us, our partners, and the products and services we and our partners offer, which may from time to time include contests, rewards, sweepstakes, events, promotions, new offerings, and special offers for products and services; using personal data you enter into incomplete or unsubmitted forms on the Services may be processed to send you reminders about completing the forms, as well as to save that information to make completing the forms easier; and processing personal data collected through social media platforms and web tracking technologies to market to and understand our audience;

  3. Providing a more personalized, relevant, and curated experience to our members, users, and personnel.

  4. Evaluating queries and applications for employment.

  5. Operating, maintaining, and improving the quality of the Services and the services, content, and products we make available through the Services;

  6. Communicating with you by email, mail, text message (SMS, MMS), telephone, push notification, and other methods of communication, in each case with your consent, if such consent is required in accordance with applicable laws, about products, services, order status, and other topics;

  7. Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;

  8. Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our personnel, members, users, visitors, and other third parties; and

  9. For other purposes, as permitted or required by law.
     

We will not use the personal data we collected for material different, unrelated, or incompatible purposes without providing you with notice.

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