Privacy Policy

Twiik AB
Orgnr: 556947-7788
Address: Djäknegatan 9, 211 35 Malmö, Sweden
Email: hello@twiik.me

Definitions in this agreement:

Wellness Tech Labs
This refers to the services that are based on a system from Welltech Labs (Wellness Tech Labs International AB). Twiik is an example of such a service. The system allows you to log in to several health apps with the same login information and take your data with you between these services. Login with such an account is available on several services and apps under different senders and brands (Gym, coaches, PT, health providers, etc.) which are based on the same system from Well Tech Labs and which are also covered by these terms. The service from which you have been referred to these terms is covered by the above definition and these terms and uses login via an account in the Service or equivalent solution from Well Tech Labs.

The service
The service from which you were referred to these terms. It can, for example, be an app from a gym, a PT or another health provider. What they have in common is that they are based on a platform from Welltech Labs and use a common standard for login and data storage.

About this Privacy Policy
Your confidentiality and transparency in how your data is made available and used are important to Wellness Tech Labs International AB (hereinafter referred to as Welltech Labs) which operates services such as Twiik, Twiik Coach or other service connected to Welltech Labs system. This Privacy Policy is designed to provide you with information about how we process your personal information when you use the Service or systems linked to this platform.

As a basis, the Service is an open and social service and therefore much of the information you enter into the service is often visible to others. Examples can e.g. be that your compiled data, name, and pictures are visible in top lists and challenges, your contact information and logged data are available to coaches and program creators you choose to join and your activity flow is visible to those who follow you or visit your profile. You can set and change much of this under your profile settings.

Other websites and services from Welltech Labs that do not contain a link to this privacy policy but contain a link to another privacy policy are covered by that privacy policy.

“Personal information” is information about an identified or identifiable natural person.

Personal data that is processed when you create an account in the Service:
When you create an account in the Service, you are asked to provide your e-mail address and choose a username. Your username does not have to contain any reference to your real name or your person if you do not wish to do so. Other information you are asked to register for your profile in the Service is usually optional if they are not required for a certain service to be technically delivered to you. (read more below about this).

Purposes and legal bases:

Welltech Labs has a legal interest in maintaining the security of your account and being able to distinguish between different users’ accounts and access the right data for the right users. We, therefore, process your e-mail address because you use your e-mail address and password to log in to your account. The legal basis for processing your email address is based on the above purpose.
Welltech Labs also processes your email address for the purpose of sending you important information about your Welltech Labs products, apps or accounts, such as important security information or significant changes to this Privacy Policy. The username you provide is associated with your account profile and is displayed to your contacts when you participate in challenges, leaderboards, groups and segments, and when you leave comments etc. The legal basis for processing your email address and username for these purposes is the Service’s legitimate interest in providing important security information or other information about the Service, apps or accounts or significant changes to this Privacy Policy, and to enable you to interact with other users of the Service or users of services based on the Welltech Labs platform.
If you give your consent to receive marketing information from the Service, the Service will also process your e-mail address for the purpose of sending marketing information to you to the Service or Welltech Labs related apps and services. The legal basis for processing your email address for this purpose is your consent. You can withdraw your consent at any time by changing your settings in your account in the Service or through the link to end the subscription at the bottom of our email with marketing or other mailings. The marketing email you receive from the Service is based on the settings you make on your account in the Service, the location specified by your Internet Protocol (IP) address, the types of services, programs or activities that you have added to your account in the Service and subscriptions that belong to your account in the Service. The legal basis for processing this data for this purpose is the Service’s legitimate interest in reducing the amount of e-mail with marketing sent to each individual customer by choosing which customers receive a certain e-mail with marketing instead of sending all e-mail. mail with marketing to all customers who have given their consent to receive an e-mail with marketing.
If you give your consent, the Service processes your e-mail address for the purpose of sending notifications to you (eg when you participate in a challenge, receive messages from friends or your coach, when comments or interactions on your logged activities are left, etc.). The legal basis for processing your email address for this purpose is your consent. You can withdraw your consent at any time by choosing not to receive such notices or notifications.
The Service also processes your e-mail address to associate it with your account in the Service when you communicate with our customer support staff. The legal basis for this treatment is our legitimate interest in providing quality customer support.
Coaches you have given access to your account and your profile can also access your contact and profile information. The same applies to gyms or companies and suppliers you actively connect to in the service. The legal basis for this is the Service’s and the individual coach’s legitimate interest in providing direct support and contact with connected customers.

More personal information that is processed if you choose to enter it when you create an account in the Service:
You can add additional information to your profile, such as location, gender, date of birth, profile picture, height, description of yourself and weight.

Purposes and legal bases:

This information is used to calculate the calories you burn during an activity and for you to be able to show your contact information about yourself if you so wish. The legal basis for processing this information for these purposes is your consent. You can revoke your consent by deleting this information from your account profile.

Personal information that is processed when you log in to your account in the Service with login information for social media (optional):
You can choose to log in to your account in the Service with your login information to social media (eg your login information to Facebook). If you choose to do this, you will be asked at the first login if you agree that the social media provider provides the Service with certain information, such as name, e-mail address, profile picture, posts, comments and other information related to your social media account. All this information is made available to the Service by the social media provider due to the way in which the social media login configuration works. But the only information that the Service retains and processes is your e-mail address, time zone, gender and your name. The profile image is linked directly to the social media provider and is not saved at the Service.

If you do not want the social media provider to continue sharing your information with the Service, you can log in to your account in the Service with the login information for your account in the Service instead of the login information for your social media account. You can also remove the connection to the social media provider in your settings in your account in the Service.

Purposes and legal bases:

The Service associates the e-mail address provided by the social media provider with your account in the Service, so that in the future you can use your e-mail address to log in to your account in the Service if you no longer want to log in with the login information to your social media account. The legal basis for processing this information for this purpose is the Service’s legitimate interest in providing you with an alternative login method and maintaining the security of your account.

Personal data that is processed when you choose to transfer data or activities with associated data to the Service:
You can choose to transfer activities (eg jogging, walking, strength training, cycling) to your account in the Service by entering it into your account in the Service manually on websites or apps from Welltech Labs. You can also enter data from third-party services such as training apps and devices (such as Runkeeper, Garmin, FitBit and Polar) and activity data (such as step, distance, pace, activity time, calories burned, heart rate, GPS data) from your connected devices (eg activity bracelets, GPS watches, exercise data from mobile phones) to your account in the Service. In this regard, this can be done through a direct data connection to the third-party service or direct manual uploading of data/files created by third-party services or If you choose to transfer data or your activities to the Service, these are logged in your account and are set to “show all” by default. This means that others who visit your profile can take part in the information you save in your account. You control whether others can see your activity data and what information you want to share by managing the privacy settings of your account in the Service.

Purposes and legal bases:

(a) The Service processes your activity data – if you choose to transfer it to the Service – to enable you to analyze your activity data, see your round or movement patterns on maps, see your heart rate-related data such as exercise load, keep track of your exercise goals and your combustion. If you live in the European Economic Area or in Switzerland, the legal basis for this treatment is your express consent, which you can withdraw at any time in your account in the Service.

(b) If you choose to transfer activity data (such as steps, distance, pace, activity time, calories burned, heart rate, sleep, etc.) to your account in the Service, you will be able to receive recommendations and motivational messages, information and links to articles and others. programs that may be of interest to you based on your activity data, and a comparison of your activity data with aggregated activity data from others in the Service. If you live in the European Economic Area or in Switzerland, the legal basis for processing this data for this purpose is your express consent, which you can withdraw at any time in your account in the Service.

Personal data processed when applying for challenges or coaching programs:
When you search for challenges and coaching programs from your account in the Service, we may ask you for additional information, such as gender, height, weight, date of birth, activity level, conditions, interests, goals and times when you usually fall asleep and wake up or prefer to perform planned tasks from the Service.

Purposes and legal bases:

This information is processed to give you better advice and tips on action plans, programs and coaches that can help you reach your goals. The legal basis for processing this information for this purpose is your consent. You can withdraw your consent at any time by deleting this information from your profile.

Personal data processed when you use the Service or other services from Welltech Labs:
When you log in or use your account, we log data about this, such as the IP address used at login, date and time of use of the account, crash/diagnostic logs, information about the type of platform used (mobile, web etc) as well as information about the type of browser used.

Purposes and legal bases:

We process this information to identify and correct errors or problems. The legal basis for processing this information for this purpose is the Service’s legitimate interest in correcting errors or problems and providing qualitative product support.

Personal data that is processed when you communicate with the Service:
When you interact with our customer support staff via e-mail, telephone, online or in person, we collect personal information, e.g. name, postal address, telephone number, e-mail address and contact information and information about your use of the Service and affiliated coaches, programs and challenges. We can also create event logs that are useful in diagnosing performance issues with the product or app and collecting information regarding the support or service issue. To improve our customer service, within the framework of applicable laws, we can also record and review conversations with customer support staff and analyze views we have received through voluntary customer surveys. With your consent, our customer support staff can log in to your account in the Service, if applicable, to help you troubleshoot and resolve your issue. However, passwords are always encrypted and cannot be read by either support staff or technicians.

Purposes and legal bases:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal basis for processing this information for these purposes is the Service’s legitimate interest in providing qualitative product support. The legal basis for logging in to your account in the Service – if applicable – to assist you in troubleshooting and resolving your issue is your consent, which you may withdraw.

Different categories of recipients of personal data
Other users of the Service:
Your activities and activity data that are linked to your account in the Service are set to “show all” by default. You can choose not to allow others to see your activities and activity data by changing the privacy setting the payments on your account in the Service.

You can join groups and make contacts with other users of the Service. You can also choose to participate in challenges and leaderboards together with other users of the Service. When you interact with others in this way, you show your data regarding the challenge or the top list (eg total number of steps during a challenge or top list for steps) even if your privacy settings in your account in the Service are set to “private”.

Coaches, programs, PT-online and their suppliers:
Via Welltech Lab’s platform and in the Service, several third-party coaches can offer their services to you through the Service’s mobile apps and websites. These coaches are independent actors who run their own businesses and use only the Service as a marketplace and tool. If you connect to a coach, a program or other coaching service, the sender of the service (the coach) will have access to your profile and the data you have entered and put into your account as long as you are connected to the coach. Your contact information, purchase history for that particular service and information about you as a buyer such as an email, name, location, username, height, weight, goals, test values will also be available to the coach. This also applies to data you entered into the service before you joined the service/coach. Some parts of this data are available to the coach even after you have completed your connection to the coach.

The legal basis for this is that affiliated coaches must be able to handle your assignment satisfactorily, be able to assist with support and help and also maintain a basis for sales, repayment and accounting and offer suggestions for other services even after the user has completed the service.

Challenges and Team Boost Business Challenges:
The services and challenges that use the Welltech Labs platform as a basis for collecting data about your exercise habits will compile your data and show in context for challenges and competitions you have chosen to join. On these services, information such as your total training for different periods reported, team affiliation, achieved goals based on the challenge’s objectives and other aggregated exercise data and trends. Names, usernames and pictures, insofar as you have entered them, are also displayed in lists of participants and top lists. The information is often displayed on open web pages where only the page’s url is required to access the data.

The legal basis for processing and exposing this information is the Service’s legitimate interest in providing the challenge service and being able to account for participants’ results in a simple and easily accessible manner and your consent by agreeing to the challenge whose sole purpose is to create these compilations and lists. To withdraw this consent, you can choose to leave the challenge.

Content or feature providers; other third parties:
Sometimes we share or sell de-identified and collected activity data with or to companies that provide the Service and our customers with content or features for the purpose of improving the quality of content or features they provide, and with or to other third parties for research or other purposes.

Third-party providers of apps, platforms or services that you ask the Service to share your data with:
If you choose to accept that the Service allows a third party, such as your health software provider, or an app, such as MyFitnessPal, Runkeeper or Garmin, to access your activity data in your account in the Service, we will share such data with third parties. We will not do this without your express consent. When you ask us to share data with third parties, this third party is responsible for how it handles your personal data and you should carefully review this third party’s privacy policy. You can at any time choose to stop sharing data with the third-party provider of apps, platforms or services from within your account in the Service.

Other service providers:
The service uses cloud services from third parties such as Amazon and MailChimp etc. when sending e-mails. These services track the activities associated with this email, for example, if they were opened, if recipients clicked on links in the email, and if purchases were made after they clicked on those links. The service uses this data to analyze how much engagement our email generates. The Service uses third-party service providers that help us better understand how the Service’s websites and apps are used, and for similar purposes.

Other disclosures:
The Service or Welltech Labs may disclose your personal information and data to other parties: (a) if we have your consent expressly or through the approval of other user agreements; (b) If the Service or Welltech Labs is ordered to disclose such information within the framework of a police investigation or by summons to court, legal order, legal process or the legal obligation; (c) to be able to comply with and comply with our terms of use, rules and policies; (d) if it is deemed necessary to be able to take legal action or defend us against claims or in disputes relating to criminal or civil matters.

We may also transfer your personal information to an affiliated organization, a subsidiary or a third-party in the event of a reorganization, merger, sale, joint venture, transfer, transfer or other sales of all or part of the Service or Welltech Lab’s business, assets or shares, including – without limitation – in the event of bankruptcy or similar proceedings, provided that the organization to which we transfer personal data is not permitted to process your personal data in any other way than specified in this privacy policy without notifying you of this, and, if so required by applicable law, get your consent.

Transfers of personal data
The service and systems from Welltech Labs as a service are available in several countries globally. In order to offer our products, apps and services, we may need to transfer your personal information to other companies under or close to the Welltech Labs brand in other countries. Personal data regarding persons residing in a country within the European Economic Area or in Switzerland is controlled by Wellness Tech Labs AB International.

All Welltech Labs companies are required to comply with the privacy policies set forth in this Privacy Policy.

Cookies and similar techniques
Website:

To help you analyze how you and other visitors navigate the Service’s services such as websites and apps, compile collected statistics on website use and response speeds, diagnose problems with the Service’s servers and administer websites linked to the Service, we collect, with the help of third-party analytics service providers, certain information when you visit our website. This information includes the IP address, device geographical location, browser type, browser language, request date and time, time (s) of your visit (s), page views and page elements (such as links) that you click. We may use cookies, pixel tags, web beacon, clear GIF and other similar tools on our website or in our emails to assist us in collecting and analyzing such information. We use this information to provide better and more relevant content on our website, to identify and fix problems and to improve your experience on our website.

If you do not want information to be collected with these technologies, there is a simple approach in most browsers that allows you to automatically reject many of them, or to choose whether to reject or accept them.

If you reside in the European Union or any other jurisdiction where we are required to obtain your consent to use cookies on our websites, you have the option to manage cookie settings on the websites, except when special cookies are required to enable core functions on the website, in which case you can not choose to disable these cookies.

Here are examples of third-party analytics and similar services we currently use:

Analysis services:

Google: Google Analytics is used to track website statistics, app statistics and users’ demographics, interests and behavior of websites and apps. We also use the Google Search Console to better understand how our site visitors find our site and to improve our search engine optimization.

Crashlytics (Fabric; Crashlytics is used to help us better understand how the Service’s apps are used to improve the user experience and identify and resolve the root causes of the app crash. The data is anonymized.

Firebase; is used to track website statistics, app statistics and users’ demographics, interests and behavior on websites and apps. The data is anonymized.

Facebook; If the user uses a connection to Facebook, Facebook will have access to follow the user’s general navigation on the Service’s website and occasions of use in the Service’s apps. Exactly what is logged is something that is stated in Facebook’s terms of use and policies.

Program Performance Monitoring:

The service uses server systems from Amazon. At Amazon, there are tools for analyzing and monitoring the performance of our complex ecosystem. Traffic is logged there, including the IP address, which is necessary to detect and diagnose deviating errors and response times.

Children
Our websites and apps are not aimed at individuals under 16 years of age. If it comes to our knowledge that we have collected personal data about a child under the age of 16, we will take action upon request to delete the information as soon as possible.

Privacy Policy Updates
We may update this Privacy Policy as we add new services and apps as we expand our current offers and when technology and laws change. You can see when the privacy policy was last revised by checking the date next to the text “Last updated” at the top of this page. All changes take effect when we announce the revision of the privacy policy.

We will notify you if these changes are significant, and in cases where applicable law requires it, we will obtain your consent. This notice is given via e-mail or via notices about the changes on the Service’s website and apps that link to our privacy policy.

Retention of personal data
We retain your personal information as long as your account on the Service is considered active. In addition, there is more information about your right to deletion under “Your rights”.

Personal data controllers and data protection representatives
The personal information that the Service collects is controlled by Wellness Tech Labs International AB, with address Djäknegatan 9, 211 35 Malmö

Your rights
If you are a resident of the European Union, you have the right to request the following from the Service in accordance with the General Data Protection Regulation; access to and correction or deletion of your personal data, data portability, restriction of the processing of your personal data, the right to object to the processing of your personal data and the right to lodge a complaint with a supervisory authority. If you live outside the European Union, you may have similar rights under local law.

If you want to request access to, or correction, portability or deletion of your personal data, or delete your account in the Service, you can contact Welltech Labs by email appsupport@twiik.me.

If you are a resident of the European Union and you wish to exercise your right to restrict treatment or your right to object to treatment, please contact

Welltech Labs,
ATT: GDPR Agent
Djäknegatan 9
211 35, Malmö

or by email appsupport@twiik.me