GSPconnect Policy

Effective Date: June 14, 2024

Your privacy is very important to us. Before we get to the details, check out our Privacy Label to see a summary of our privacy practices. Click on the links to learn more and read the full policy below.

Collection and Sale of Data

• Do we sell your personal information for monetary value?

No

• Do we share or sell aggregate information?

Yes

• Do we share your data with third parties that are not service providers?

Yes, with your consent

• Do we share your personal information for targeted advertising?

Yes, with your consent

• Do we use your contact list?

Yes, with your consent

• Do we retain your data for as long as we need it unless you request deletion?

Yes

Privacy Controls

• Can you control who sees your activity and content?

Yes

• Can you control who sees your location-based activity?

Yes

• Are your activity and profile privacy controls set to “Everyone” by default?

Yes, if you are 18 years of age and older

• Do we provide additional privacy protections for minors under 18?

Yes

• Can you download and delete your data?

Yes

• Do all users worldwide have the same suite of controls?

Yes

Tracking

• Do we track your device location to provide GSPconnect services to you?

Yes

• Do we track your device location while you are not using our app?

No

• Do we use non-essential cookies?

Yes, with your consent

• Do we track your browsing activities on other sites?

No

• Do we listen to you using your device microphone?

No

Communication

• Do we give you advance notice when we make important changes and updates to our Privacy Policy?

Yes

• Do we send you marketing communications?

Yes, subject to local requirements (for example, opt-in consent)

• Do we send you push notifications on mobile devices?

Yes, with your consent

Privacy Policy

Introduction

Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our websites and the related mobile applications and services (collectively, the “Services”). Please also read our Terms of Service which sets out the terms governing the Services.

GSPconnect is headquartered in Los Altos, California, USA and our Services are provided to you by Global Sport Platform Connect LLC.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to our subsidiaries (which have their own privacy policies) or third party products or services, including other companies you might interact with on or through the Services

Questions or comments about this Privacy Policy may be submitted by mail or email using the contact information below or via https:\\www.support.gspconnect.com Global Sport Platform Connect LLC

650 Fremont Avenue STE 316

94024 Los Altos

USA

Attn: Legal

legal@gspconnect.com

Information GSPconnect Collects

GSPconnect collects information about you, including information that directly or indirectly identifies you, if you or your other GSPconnect users choose to share it with GSPconnect. We receive information in a few different ways, including when you track, complete or upload activities using the Services. GSPconnect also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with GSPconnect. For example:

Account, Profile, Activity, and Use Information

We collect basic account information such as your name, email address, date of birth, gender, weight, username and password that helps secure and provide you with access to our Services. We also use dates of birth to enhance safety and privacy for our younger users, to place you on age-group leaderboards, and to provide more accurate performance analysis.

Profile, activity and use information is collected about you when you choose to upload a picture, video, post, or activity (including date, time and geo-location information as well as your speed and pace and perceived exertion), join a challenge, add your equipment usage, view others' activities, or otherwise use the Services.

We use your contact information so we can contact you when needed. For example, to respond to your support requests.

Location Information

We collect and process location information when you sign up for and use the Services. We do not track your device location while you are not using the Services.

Content You Share

We gather information from the photos, videos, posts, comments, kudos, ratings, reviews, and other content you share on the Services, including when you participate in sport events as an athlete or photographer or create sport events for uploading content.

Contacts Information

You can choose to add your contacts' information by connecting your contacts from your mobile device or social networking accounts to GSPconnect. If you choose to share your contacts with GSPconnect, we will, in accordance with your instructions,access and store your contacts' information in order to identify potential connections and help you connect with them.

Connected Devices and Apps

GSPconnect collects information from devices and apps you connect to GSPconnect. For example, you may connect your DJI drone, professional camera apps or Garmin (for example for GPX files) or Flywheel account to GSPconnect and information from these devices and apps will be passed along to GSPconnect.

Payment Information

When you make a payment on GSPconnect, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry (PCI) compliant third-party payment services and we do not store your credit card information.

Third-Party Accounts

GSPconnect allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Meta, Google, or Apple (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences. This information is collected by the Third-Party Account providers and is provided to GSPconnect under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.

Technical Information and Log Files

We collect information from your browser, computer, or mobile device, which provides us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information.

The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track user movement in the aggregate, and gather broad demographic information (e.g., country residence) for aggregate use. IP addresses may be linked to session IDs, athlete IDs and device identifiers.

Other Information

We may collect information directly from you or through our service providers, such as when we collect your feedback through surveys. We may also collect information about you from other GSPconnect users such as when they give you feedback on your activities.

How GSPconnect Uses Information

GSP uses the information we collect and receive as described below.

To provide the Services

We use the information we collect and receive to provide the Services, including providing you with the ability to:

• analyze your performance. For example, to compare your past efforts, analyze your event results
• Explore new places to go. For example, to discover sport events where you can engage in your activity.
• Visualize your activities in new ways. For example, by creating sport event maps
• Share insights with the GSPconnect community. For example, by sharing your public reviews and photos of specific sport events. We may also analyze your public photos from specific sport events or segments to attach characteristics to those sport events (e.g., shaded, waterfalls, flowers, etc.)

Subject to your privacy controls, your information, including parts of your profile, username, photos/videos, users you follow and who follow you, clubs you belong to on GSPconnecrt, your activities, the devices you use, and kudos and comments you give and receive will be shared on GSPconnect so that you may be able to participate in the Services, for example to receive a detailed analysis of your performance. Certain information (e.g., your name, and some profile information) is also available to non-users on the web. Your precise location information, such as where you run or ride, may also be shared on GSPconnect or to non-users, in accordance with your privacy controls.

To provide the messaging Services

We use the information we collect and receive (including your name, avatar, athlete ID, and content you choose to share) in connection with your use of GSPconnect Messaging on the basis of our legitimate interest in enabling you to find new ways to interact by using the Services. When you use Messaging, we use your information (i) to provide you with the GSPconnect Messaging service, (ii) to improve GSPconnect Messaging, for example to increase the functionality of Messaging by analyzing usage data to identify technical and design improvements and by assessing feedback you provide in relation to Messaging, and (iii) to protect you and other users of the Messaging service and the Services, for example by enforcing our Terms of Service, acceptable use policy and community standards. We use automated tools to assist us in protecting and safeguarding you and other users and to keep the Messaging service secure, for example to detect misuse and bad actors. To help us provide GSPconnect Messaging, we share your information with a third party service provider that specializes in messaging services and keeping these safe and secure.

To customize your experience

We use the information we collect and receive to customize your experience. For example, we may suggest sport events, content and athletes, teams on GSPconnect that may interest you, users that you may want to follow, or new features that you may want to try. For example, if we know that you like to run marathons, we may tell you about new marathon events or show you sponsored content related to marathons. Or if we see that you bike ride in a certain area, we may suggest joining a team or a sport event in that area.

To provide you with targeted promotions

We use the information we collect and receive to serve you with relevant promotions, subject to your notification and email preferences. For example, if we see you are an active user who has been on a monthly subscription plan for an extended period of time, we may serve you a promotion to switch to a discounted annual plan. Or if you are an active user who has never subscribed, we may send you an offer for a free subscription trial.

To protect you and the Services

We use the information we collect and receive to protect users, enforce our Terms of Services, acceptable Sservice policy, and Community Standards, and promote safety. For example, we find and remove content that violates our terms, such as hate speech or spam, as well as suspend or terminate accounts that share such content. GSPconnect reserves the right to review accounts and user actions on the Services to ensure compliance with our Terms

To assist you with a support request

We use the information we collect and receive to provide support in response to your requests and comments. Depending on your request, this may require us to access your account, for example, to troubleshoot or replicate a reported issue.

To improve our Services

We also use the information we collect and receive to conduct research, and to analyze, develop, troubleshoot, and improve the Services. To do this, GSPconnect may use third-party analytics providers to gain insights into how our Services are used, using aggregated data, and to help us improve the Services

To communicate with you

We may also use the information we collect and receive to market and promote the Services, activities and events on GSPconnect, and other commercial products or services, including using email and push notifications, in accordance with your preferences. We may also contact you for partnership opportunities, when investigating alleged violations of our terms, or to send proactive customer support messages.

To process your subscription

We use the information we collect to process your subscription, including using your location data to determine your country pricing.

How Information is Shared

We do not sell your personal information for monetary value. We may share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below. In addition, we may sell or share aggregated data about our users, as described in more detail in the “Aggregate Information” section below.

Service Providers

We may share your information with third parties who provide services to GSPconnect such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, to promote Strava or display information that may be relevant to your interests on the Services or other websites or services.

Publicly Available Information

When you join the GSPconnect community as an individual of 18 years of age or older, your profile and your activities are set to be viewable by everyone by default. Your name and other profile information is viewable by other GSPconnect users and the public and, subject to your privacy controls, additional information and content you share may also be viewable. For example, your media content and sport events may be accessed by other GSPconnect users and non-users or viewable on publicly accessible GSPconnect pages or in search engine results.

When you join the GSPconnect community as an individual under the age of 18, your profile and your activities are set to be viewable by followers by default. In order for another GSPconnect user to be able to see your detailed profile information or your activities, the GSPconnect user must first request to follow you and you must accept that request. For example, a GSPconnect user will not be able to see your uploaded activities or photos until after you have granted the GSPconnect user permission to follow you.

We provide a variety of privacy controls to manage the sharing of your information and encourage our users to adjust their controls to align with their desired experience

Sharing Information and Activities

We share your information with other GSPconnect users and the public in accordance with your privacy controls. You can change the visibility of the activities you register or upload. If you link your GSPconnect account to other social networks and share your activities, they will be viewable on such third-party platforms, including your location information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties.

Targeted Advertising

We may use the information we collect and receive about you to provide you with targeted advertising if you accept non-essential cookies using our cookie banner. You may opt-out of targeted advertising by clicking the “Do Not Share My Personal Information” link in the footer below or in our app by clicking on the “Personal Information Sharing” link in your Privacy Controls and following the instructions.

Third Party Business via API or Other Integrations

We enable you to share your information and content with third party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with GSPconnect to offer an integrated feature, such as a challenge sponsor, media streaming, or tracking device. You can choose to share your profile data and activity data (including private activities) with these third parties. Information collected by these third parties is subject to their terms and policies and may not provide you with the same privacy controls that are available on GSPconnect (for example, hiding a specific address or the start and end points on activity maps). GSPconnect is not responsible for the terms or policies of third parties.

Aggregate Information

GSPconnect may deidentify and aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. Examples include information about equipment, usage, demographics, routes, performance, and challenge participation and completion. GSPconnect may use, sell, license, and share this aggregated information with third parties for research, business or other purposes such as to improve individual marketing, data analytics and event performance or to help our partners understand more about users, including the people who use their products and services. GSPconnect also uses aggregated data to generate our Global Heatmaps and other community- powered features such as point of interests and start points. Please visit your privacy controls if you would like to opt out of GSPconnect using your information for these purposes.

Subsidiaries and Acquirors of our Business or Assets

We may share your information with our subsidiaries, such as Recover Athletics, photographer or business account, who are required to handle your personal information in accordance with their own Privacy Policies.

If GSPconnect becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction.

Legal Requirements

We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to: (1) prevent any person from death or serious bodily injury; (2) to address issues of national security or other issues of public importance; (3) to prevent or detect violations of our Terms of Service or fraud or abuse of GSPconnect or its users (4) or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

Managing Your Settings

Privacy Controls

GSP connect offers several features and settings to help you manage your privacy and share your activities. Most privacy controls are located in your privacy controls page, but some are specific to individual activities, athletes, photographers, business or features.

Adjust Notification and Email Preferences

GSPconnect offers various ways to manage the notifications you receive. You can choose to stop receiving certain email notifications by indicating your preferences. You may also unsubscribe from these emails by following the instructions contained at the bottom of these messages. In our app, you can access your “Push Notifications” in the settings menu. Where permitted by local regulations, we may opt you into marketing-related communications if you substantially interact with the Services or purchase a subscription. We may also send you periodic communications asking if you would like to opt into receiving marketing-related communications.

If you receive marketing communications from one or more of our subsidiaries, you must opt-out individually from each subsidiary you are receiving brand-specific marketing from.

Any administrative or service-related emails (for example, to confirm a purchase, to notify you of pricing changes, to deliver a training plan you requested, or provide an significant update to our policies, etc.) may not offer an option to unsubscribe as they are necessary to provide the Services you requested. You are responsible for providing us with a valid email address and keeping it updated to ensure you get these email notifications.

Updating Account Information

You may correct, amend or update profile or account information at any time by adjusting that information in your account settings. If you need further assistance correcting inaccurate information, please contact GSPconnect via the contact form.

Deleting Information and Accounts and Downloading Your Data

You can delete your account.

After you make an account deletion request, we permanently and irreversibly delete your personal information from our systems, including backups. Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated. Following your deletion of your account, it may take up to 45 days to delete your personal information and system logs from our systems. Additionally, we may retain information where deletion requests are made to comply with the law and take other actions permitted by law.

Note that we do not have control over content you have shared directly with others, such as photos or videos on other social media platforms, or that others may have copied. In other words, content or information may remain available after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

GSPconnect also provides you the option to remove individual activities you have posted without deleting your account. Once removed, the activities may remain on GSPconnect systems until you delete your account.

Children's Privacy

Our services are not intended for, nor directed to, children under 13 years of age. We use technical measures to prevent children under 13 years of age from creating an account and therefore do not knowingly collect personal information from anybody under 13 years of age. If you are under 13 years of age, do not use the Services.

Moreover, we strive to provide additional privacy and safety protections for individuals under 18 years of age. For example, when users under 18 years of age create an account, their profile and activities are set by default to be viewable by followers only. We also may limit how we collect or process the personal information of individuals under 18 years of age. For example, you must be at least 16 years of age to upload heart rate data or receive heart rate analysis.

How We Protect Information

GSPconnect implements technical, physical, and organizational measures and controls to safeguard and protect the transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity.

Please be aware that despite our efforts, we cannot guarantee absolute security of your account or information. In addition, you can take steps to protect your account and information such as creating a unique password for Strava that is not easily guessed and that you don't use anywhere else, not sharing your password with others, and promptly reporting suspicious activity or unauthorized account access.

Your Rights and Our Legal Bases

We provide the same suite of privacy controls to all of our users worldwide. Particular rights may be available to you if you reside in certain locations, such as the EEA, Brazil or certain U.S. states such as California.

Your Legal Rights in the EEA

If you reside in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. GSPconnect‘s lead supervisory authority in the EEA is the Data Protection Commission of Ireland.

Our Legal Bases

GSPconnect relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:
• as necessary to provide the Services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide the Services unless we collect and use your location information;
• where you have consented to the processing;
• where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
• to protect your vital interests, or those of others, such as in the case of emergencies; and
• where necessary for the purposes of GSPconnect‘s or a third party's legitimate interests such as our interests in protecting our users, our partners' interests in collaborating with our users, and our commercial interests in ensuring the sustainability of the Services.

Cross Border Data Transfers

The Services are operated from the United States. If you are located outside of the United States and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in the United States, as it is necessary to provide the Services and perform the Terms of Service

Whenever we transfer personal data internationally, we use legal mechanisms, such as Standard Contractual Clauses, to ensure data transfers comply with applicable law.

Retention of Information

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted or becomes inactive. In making these determinations, we consider the amount, nature, and sensitivity of the personal information, the purposes for which the information is processed, whether we can achieve those purposes through other means, and applicable legal requirements.

In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account. For example, if you withdraw your consent to GSPconnect a processing your health-related information, GSPconnect will thereafter delete all health-related information from activities you upload. Following your deletion of your account, it may take up to 45 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our Services to you may be de-identified or aggregated with other non-personal data to provide insights that are commercially valuable to GSPconnect, such as statistics of the use of the Services. For example, we may retain publicly available segments or routes and other depersonalized geolocation information to continue to improve the Services. This information will be de-associated from your name and other identifiers.

Other GSPconnect Sites

GSPconnect maintains certain websites that can be accessed outside ofhttps://www.gspconnect.com. The Other Sites may maintain the look and feel of the Services, but are hosted by outside service providers with their own terms and privacy policies. If you interact with the Other Sites, your information may be stored, processed, or shared outside of the Services. If you interact with the Other Sites, you acknowledge that you may be subject to the terms and conditions and policies applicable to such Other Sites, which may differ from this Privacy Policy. Please be aware that any personal information you submit to the Other Sites may be read, collected, or used by other users of these forums indefinitely, and could be used to send you unsolicited messages. GSPconnect is not responsible for the personal information you choose to submit via the Other Sites.

Privacy Policy Updates

GSPconnect reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If GSPconnect makes changes to this Privacy Policy, the updated Privacy Policy will be posted in a timely manner. If we make changes we deem to be material, we will provide a prominent notice. If you object to any changes to this Privacy Policy, you should stop using the Services and delete account.

Past Privacy Policy Versions

• June 14, 2024

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