Privacy Policy

Effective as of: 12.18.2020

Palestra Performance LTD, doing business as Palestra Performance (“Trainer,” “we,” “our,” or “us”), operates a mobile application under the name Palestra Performance (“App”) developed in cooperation with and licensed to us by our partner LEAN ON DIGITAL, INC. (“App Developer”).

We value your privacy and are committed to protecting your personal data. This Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect your personal information when you use the App and related services (“Services”).

By creating a User Account or using the App, you agree to the terms of this Privacy Policy and our User Terms of Service. You may withdraw consent at any time, but this may limit your ability to use certain features of the App.

1. Personal Information We Collect

1.1 Information You Provide Directly:

• Contact and Profile Information: name, email, age, gender, address, training preferences, fitness and nutrition habits, and photos/videos you upload.
• Fitness and Health Data: weight, height, body composition, goals, and exercise activity.
• Payment Information: processed via Apple iTunes or Google Play; we do not store payment details.
• Communications: messages, comments, and feedback shared within the App or with customer support.

1.2 Information Collected Automatically:

• Device and software data (IP address, OS, device model, unique IDs).
• Usage information (features used, content viewed, time spent).
• Analytics information (collected via Google Analytics and similar tools).
• Cookies and tracking technologies to enhance user experience.

1.3 Information from Third Parties:

• Social login data (e.g., Google, Facebook) if you choose to connect your account.
• Analytics or advertising partners providing aggregated performance data.

2. How We Use Your Information

We use your personal information to:

• Provide and maintain the App and Services.
• Create and manage your User Account.
• Deliver personalized training content and recommendations.
• Communicate important updates, support messages, or marketing offers (only with your consent).
• Improve and secure the App experience through analytics and bug fixes.
• Comply with legal obligations and prevent fraud or misuse.

Legal Bases for Processing (GDPR/UK GDPR):

• Performance of a contract (to provide Services you requested).
• Legal obligation (to comply with applicable laws).
• Legitimate interests (to maintain App performance and user security).
• Consent (for optional features, analytics, or marketing communications).

3. Sharing of Your Information

We do not sell or rent your personal data. We may share it with:

• App Developer (Lean On Digital, Inc.) – provides hosting, analytics, and technical maintenance.
• Service Providers – third parties that assist with infrastructure, analytics, or support.
• Payment Processors – Apple or Google handle all financial transactions.
• Business Transfers – in the event of a merger, acquisition, or sale of assets.
• Legal and Regulatory Authorities – when required by law or court order.
• Other Users – when you post or share content publicly within the App.

4. Control Over Your Information

• You can access and edit your profile in your account settings.
• You can withdraw consent to marketing emails by clicking “unsubscribe.”
• You may request deletion or correction of your data at any time.

5. Cookies and Tracking

We use cookies, SDKs, and similar technologies to analyze usage and improve the App. You may manage cookie preferences through your device settings. Google Analytics may collect limited information for analytics; refer to Google’s Privacy Policy for details.

6. Data Storage and Security

Your data is stored securely on servers in the United States and other jurisdictions. We implement appropriate physical, administrative, and technical safeguards to protect your data. However, no system is entirely secure; users are encouraged to use strong passwords and protect their login details.

7. Data Retention

We retain personal data only as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce agreements. When no longer needed, personal data is securely deleted or anonymized.

8. International Data Transfers

Your information may be transferred to and processed in the United States. Where we transfer personal data outside the EEA or UK, we rely on the European Commission’s Standard Contractual Clauses (SCCs) or other approved safeguards to ensure adequate data protection.

9. Your Rights Under GDPR/UK GDPR

You have the following rights:

• Right of access – to obtain a copy of your data.
• Right to rectification – to correct inaccurate information.
• Right to erasure (“right to be forgotten”).
• Right to restrict or object to processing.
• Right to data portability – to receive your data in a structured, machine-readable format.
• Right to withdraw consent at any time.

To exercise any of these rights, contact support@leanondigital.com or our Data Protection Officer at info@palestraperformance.co.uk.

If you are located in the UK or EU and believe your rights have been violated, you can contact your local Data Protection Authority. In the UK, this is the Information Commissioner’s Office (ICO) – www.ico.org.uk.

10. Automated Decision-Making and Profiling

We may use limited automated processing to personalize your experience (e.g., suggesting workouts or meal plans). These processes do not have legal or similarly significant effects. You may request human review of any automated recommendation by contacting us.

11. Children’s Privacy

The App and Services are not directed to individuals under 18. We do not knowingly collect data from minors. If you believe a child has provided personal data, please contact us for immediate deletion.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The “Effective Date” above will indicate the latest revision. If material changes occur, we will notify you via email or in-app notification. Continued use of the App after such updates constitutes acceptance of the revised Policy.

13. Data Controller and Contact Information

Data Controller:
Palestra Performance LTD – CHRYSOSTOMOU, Andreas
Email: support@leanondigital.com

Data Processor:
Lean On Digital, Inc.
Email: support@leanondigital.com

Data Protection Officer (DPO):
Email: info@palestraperformance.co.uk
For all privacy-related inquiries, please contact the DPO via the email above or through the general contact email provided.

14. CCPA – California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you additional rights, including:

• The right to request access to the categories and specific pieces of personal information we have collected.
• The right to request deletion of personal data, subject to certain exceptions.
• The right to opt out of the sale of your personal information (we do not sell personal data).

To exercise these rights, contact us at support@leanondigital.com. We will not discriminate against you for exercising your rights.

15. Nevada Residents

If you are a resident of Nevada, you may request that we do not sell your personal information. To submit such a request, email us at support@leanondigital.com with “Nevada Opt-Out” in the subject line.

16. Supervisory Authority Contact (EU/UK)

For unresolved privacy issues, EU/EEA users may contact their national Data Protection Authority. UK users may contact:

Information Commissioner’s Office (ICO)
Website: www.ico.org.uk

17. Effective Jurisdictions

This Policy complies with the requirements of the EU General Data Protection Regulation (GDPR), the UK GDPR, and relevant U.S. data privacy laws, including the CCPA. In case of conflict between these laws, the higher protection standard applies to the user’s jurisdiction.

By continuing to use the App, you confirm that you have read, understood, and agreed to this Privacy Policy.