SOLDIERFIT VIRTUAL STUDIO’S PRIVACY POLICY

Effective Date: May 12, 2020

This privacy policy describes the personal data collected or processed when you use Soldierfit VIRTUAL STUDIO’S website (“Platform”). It also explains how your personal data is used, shared and protected, what choices you have relating to your personal data, and how you can contact us.

WHO is Responsible for Processing Your Personal Data?
Soldierfit (referred to as “Soldierfit”, “our”, “we” or “us” in this privacy policy).

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 make purchases, contact our consumer services, request to receive communications, create an account or use our Platform. 

This personal data may include:
- contact details including name, email;
- login and account information, including screen name, password and unique user ID.

When interacting with our Platforms, certain data is automatically collected from your device or web browser, as further described below in the section titled “Cookies and Pixel Tags.” This data includes:

Device IDs, call state, network access, storage information; and

Cookies, IP addresses, referrer headers, data identifying your web browser and version, web beacons, tags, and interactions with our Platform.

KIDS

We do not knowingly collect personal information online from children under the age of 18. 

TOOLS to Manage What Personal Data We Collect
In some 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. 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 Communicate Information about our Products, Services, Events and for Other Promotional Purposes

If you are an existing customer of Soldierfit (for example, if you have placed an order with us), we may use the contact details you provided to send you marketing communications about similar Soldierfit 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 Soldierfit products or services - such as your use of Soldierfit’s Platform, your visits to or purchases made in Soldierfit stores, your participation in Soldierfit events and contests (possibly through other Soldierfit affiliates) - to personalize communications and advertisements regarding our products and services that may be of interest to you. For registered users, this may include data collected from your interactions with our Platform that are associated with your account across devices.

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 make a purchase, we use that information for accounting, audits and other internal functions. We may use personal data about how you use our products and services 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 
We may also use personal data about how you use our Platform to prevent, detect, or investigate fraud, abuse, illegal use, violations of our terms of use, and to comply with court orders, governmental requests or applicable law. 

For General Research and Analysis Purposes 
We use data about how our visitors use our Platform to understand customer behavior or preferences. For example, we may use information about how visitors to www.soldierfitvirtualstudio.com search for and find products to better understand the best ways to organize and present product offerings in our Platform. 

Other Purposes
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.

SHARING of Your Personal Data

Soldierfit’s Sharing

Soldierfit shares your personal data with:

- Soldierfit entities for the purposes and under the conditions outlined above 

- Service providers processing personal data (including the personal data noted above for business purposes on Soldierfit’s behalf, for example to host, manage and service our data, distribute emails, research and analysis, advertising, analytics, manage brand and product promotions as well as administering certain services and features. 

- Other third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law; (ii) prevent illegal uses of our Platform or violations of our Platform’s terms of use and 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).

We do not sell your personal data.

PROTECTION and MANAGEMENT of your Personal Data
- Encryption & Security: We use a variety of technical, administrative, and organizational security measures, including encryption and authentication tools in certain circumstances, to maintain the safety of your personal data. 

Despite our efforts, no website, mobile application, database or system is completely secure or “hacker proof.” You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse. 

- Retention of your personal data: We retain your personal data for as long as necessary to fulfil the purposes described in this policy, unless otherwise required or permitted by law. For example, we keep your account profile information for as long as you keep your Soldierfit account, but we may keep your order history longer to comply with legal obligations.  

Managing your personal data: You may have the right to request: (i) access to your personal data (both the categories of data we collect, which is laid out in this policy, and particular types); (ii) an electronic copy of your personal data; (iii) correction of your personal data if it is incomplete or inaccurate; or (iii) deletion or restriction of your personal data in certain circumstances as provided by applicable law. We will not discriminate against you for the exercise of these rights. If you have a request regarding your personal data that cannot be fulfilled from your account settings, please contact us. Contact details can be found below.   

COOKIES and Pixel Tags
Soldierfit collects information, which may include personal data, 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.  

Some advertising and technology partners may also collect personal data when you use our Platform. These partners have committed to act as service providers on Soldierfit’s behalf and have committed to only use your personal data for Soldierfit’s purposes as described in this policy. 
We use cookies and pixel tags to track usage of the Platform and to understand our customers’ preferences (such as country and language choices). This enables us to provide services to our customers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about Platform traffic and Platform interaction, to identify trends and obtain statistics so that we can improve our Platform. There are generally three categories of cookies used on our Platform:

- Functional: These cookies are required for basic Platform 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. 

- 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 Platform preferences you have selected. Refusing these cookies may result in poorly tailored recommendations and slow Platform performance.

Your browser can help you manage cookies. You can 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 websites of the Network Advertising Initiative and 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.  

CHANGES to Our Privacy Policy
Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Platform. If we materially change the way in which we process your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our privacy policy and keep yourself informed of our practices.

QUESTIONS and Feedback
We welcome questions, comments, and concerns about our privacy policy and privacy practices.

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 contact us via our website. 

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.