Welcome to the website of MCE!

This innovative Erasmus+ social-innovation sport project based on collective “movement” activity and competition.

PRIVACY STATEMENT ENGLISH

Read this privacy statement before using our products and Services (described below), being our website (hereinafter referred to as “Website”) and the mobile application of MCE (hereinafter referred to as “App”)

MCE collects health and fitness data to enable sport community experience, healthy competition, physical activity-game.

Table of Contents

    1. TLDR (Too Long, Didn’t Read)
    2. What is Multisport Community Experience
    3. Who are we?
    4. Information About Your Personal Data
    5. How to Contact Us
    6. GDPR Details
    7. European Union Rights
    8. Consent as a Basis for Processing
    9. How We Protect Information
    10. Privacy Policy Changes
    1. TLDR (Too Long, Didn’t Read):

      Your privacy is critically important to us. At Multisport Community Experience (MCE), we have a few fundamental principles:

      • Your account is completely private by default.
      • You can add as much or as little data as you want.
      • You can delete your account and data at any time.
      • We are very protective of our user’s data and privacy.
      • It is easy to share your activity with your Team/Challenge in the App, but you do not have to.
      • Information you sync may be seen by others depending on your settings.
      • We do not sell your data, and only make money from people paying us directly.
      • We do automatic tracking and syncing in the background as much as possible, within the limitations that you gave us, so you do not have to do a lot of work to maintain your account and manually enter data every day.
      • Aggregate information may be used for research, quality assurance, and improving the Multisport Community Experience service.
      • Connecting a 3rd party service gives us access to that data but does not send your Multisport Community Experience info to them. It is a one-way connection. This does not reduce the privacy or security of your account in any way.
    2. What is Multisport Community Experience?

      Multisport Community Experience (MCE) is a dashboard to help you track and improve everything about your life. It is powered by data from your phone, wearables, and other connected accounts, also you could manually enter data.

      The entire purpose of the service is to process and store information for you, much of which occurs on our servers. Most of our users find the health improvements and other benefits from the service far outweigh the slight reduction in privacy. However, if you are not comfortable with us processing and storing your information, then you should not use the service or send us any data. In this privacy statement we give you insight into the personal data we collect, why we collect it and what we do with this personal data.

    3. Who are we?

      Kinetic Analysis B.V. based at Sint Janssingel 92, 5211 DA, ‘s-Hertogenbosch and registered at the Dutch chamber of commerce under number: 69045003, including its affiliated companies (hereinafter referred to as “Multisport Community Experience”, “MCE”, “VCC”, “we”, “us” or “our”) takes your privacy very

      seriously. As responsible for the processing of your personal data, we ensure that your personal data is treated and secured with the utmost care. We always comply with applicable laws and regulations.

      In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.

      We process personal data on the Basis (Basis 1-4 reference below) of the following principles that are included in European privacy legislation (click here) :

      1. Permission.
      2. Performance of an agreement.
      3. Legal obligation; and
      4. Legitimate interest of MCE or a third party (e.g., Responsible Party).

      Legitimate interests include personal health advice, security, auditing, fraud detection, prevention, (market) research into and analysis and improvement of our products and services, internal management, legal affairs, and business management.

    4. Information About Your Personal Data

      This Privacy Policy relates to data about you, your devices, and your interaction with our Services. “Personal Data” is information that can be used to identify you, directly or indirectly, alone, or together with other information. You are the owner of your data and by giving access you can decide what we will do with your personal data. This contains the following, if you accept to share:

      • Full name
      • Date of birth
      • Gender
      • Height
      • Weight
      • Email address
      • Phone number
      • Precise location
      • Device IDs
      • Certain cookie- and network identifiers
      • Fitness and Wellness data: stepping, cycling, flights climbed and more.Multisport Community Experience collects, uses, discloses, and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business, and to provide you with innovative fitness and wellness services, as further described in this Privacy Policy.We may create aggregated, de-identified or anonymous data from Personal Data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you, through obfuscation, or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy. The data is used in statistics and for research into the exercise behavior of residents of the chosen city. Your data will be used anonymously (if you have given us permission to do so) when reading and analyzing the data.

        INFORMATION MESSAGES

        MCE may use your name, address, city, and email address to send information messages (not marketing communications) that are necessary to use MCE wearable. Basis 2 applies.

        MARKETING

        To the extent permitted by applicable law, MCE may use your name, address, city, email address and telephone number for marketing communications, such as newsletters or activity promos and events. You can unsubscribe from this at any time. The subscriber file of the newsletter will not be provided to third parties unless you have given explicit permission for this. This data is kept until you cancel the subscription. Base 1 or 4 applies, depending on the processing.

        COMPLIANCE WITH (LOCAL) LAW

        To comply with applicable law, MCE may be required to process your personal data for purposes other than set out in this privacy statement, for example, for law enforcement and in the event of a court order. Basis 3 applies.

        FRAUD DETECTION

        MCE processes the personal data known to you for fraud detection and to prevent fraud and abuse. If we have a reasonable suspicion of any fraud, or criminal activity attributable to you, or determine this, your personal data will be processed to prevent you from using our products and Services in the future. Basis 3 or 4 applies. This concerns misuse of the data, hacking of the system or incorrect use of the App.

        CUSTOMER SERVICE

        MCE can collect and share your personal data to provide (international) customer service. For example, MCE may collect (telephone) requests received by customer service and related responses, along with your name, address, city, email address, and phone number. In this way, MCE can respond better to questions. Base 1 or 4 applies, depending on the processing.

        LINKED APPS

        When you sign up for an account, we start building your profile and adding data to it. A basic user account has details like your name, email address, date of birth, and gender. These can be manually entered.

        The Multisport Community Experience app tracks some basic stats like steps, but it is mostly powered by the other services and devices you connect to it. Depending on wearables or other connected devices, we have many integrations and are constantly adding more. We will update this list as the data we collect evolves. The more services you connect to your account, the more data you will be able to see on your profile and in the app. What you feel comfortable connecting and sharing is up to you.

        Each type of account has different content and various amounts of personally identifiable information, so you may be comfortable with connecting some and not others.

        We use our access to your accounts only to load the information we need, never to write or modify your data in any way. We load data once when your account is first connected, and then periodically to keep your account up to date. This data is processed and stored on Multisport Community Experience servers so it can be accessed through the website, mobile app, and other platforms. When you disconnect an account, we also delete all the associated data that was imported from that account.

        The following are some of the commonly used services we integrate with, and the data that can come from it.

        STEPS

        We load your count of daily steps from a variety of sources. You can select which is the primary source in settings. The common sources for steps include Apple Health, Google Fit.

        APPLE HEALTH

        From the iPhone app, we load various data-points from Apple Health during the initial install and keep them synced occasionally throughout the day. When installing the app, you will be able to choose which data types you want to sync. The possible options include steps, workouts, sleep, heart rate, weight, bodyfat percentage, blood pressure.

        Setting up Multisport Community Experience syncing will upload the data from your phone to our servers.

        COOKIES

        These are required to log in to your account and for basic web browsing features. When you visit the Services, a cookie will be stored on your computer.

        LOG FILES

        The Services use log files. Stored information 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 member movement in the aggregate,

        and gather broad demographic information for aggregate use. These files may be stored on our servers. We will update our policy on analytics platforms that we might use in the future.

        WHEN YOU JOIN TEAM/CHALLENGE

        Subject to your privacy settings, when you use Team/Challenge feature, some of your information and content like scores and physical activity data may be publicly accessible.

        VISIBILITY

        We only use your data to power your profile page and will never share or sell your details to any 3rd parties. Data in your account will not be used unless for promotional content based on the activities of your Team/Challenge, and we do not involve commercial or any other advertising material.

        There is currently no public API to get data out of Multisport Community Experience.

    5. How to Contact Us

      If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us by sending a message to vcchelp@kinetic-analysis.com

    6. GDPR Details

      HOW WE COLLECT AND USE PERSONAL DATA

      We collect your Personal Data in several ways and for various purposes, including:

      • When you register for an account or interact with our Services.
      • When you input Fitness and Wellness Data within our Services or use our Services that collect or infer such data from mobile device sensors.
      • When you use or interact with a wearable or other connected device.
      • When you give us permission to sync Apple Health data in the iPhone app.
      • When you give us permission to sync Google Fit data in the Android app.
      • When you give us permission to collect Location Data in the mobile apps.
      • When you connect an integration to sync data to your account.
      • When you communicate with us or sign up for promotional materials.
      • When you engage with our online communities or advertising.
      • When you access third party products and services.
      • When we collect data from third parties or publicly available sources.
      • When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies.
      • When we aggregate or centralize data.
      • When you take fitness tests or assessments; share content or achievements; or invite members in a Team/Challenge.
      • When we provide you geographically relevant Services, offers, or advertising.
      • When you ask us to customize products, or Services
      • When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes (Country/Region-Specific Disclosures may apply).HOW INFORMATION IS SHAREDWe may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy, and in the following ways:
      • To other Users/Multisport Community Experience Registered Users
      • To Affiliates and Partners
      • To Service Providers and Vendors
      • For Advertising and Marketing
      • For Certain Analytics and Improvement
      • For Interest-Based Advertising
      • For Legal Compliance, Law Enforcement, and Public Safety Purposes
      • In the event of an actual or contemplated sale PUBLICLY AVAILABLE INFORMATIONSubject to your privacy settings, some of your information and content may be publicly accessible. Having an account on the service will make your name, or cover photo in a Team/Challenge viewable so people can ask to join. More sensitive details like your recent activity and physical activity scores will remain private unless made public, or a Team/Challenge invitation is accepted.AFFILIATES AND ACQUIRORS OF OUR BUSINESS OR ASSETS

        We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Multisport Community Experience 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.

        TRANSFERS OF YOUR PERSONAL DATA TO OTHER COUNTRIES

        The Personal Data Multisport Community Experience processes, and all associated Services and systems, including registration, is housed on servers in Amsterdam, the Netherlands. If you are located outside of the Netherlands, please be aware that Personal Data we collect will be processed and stored in Amsterdam, the Netherlands (the data protection and privacy laws in the Netherlands may offer a lower level of protections than in your country/region).

        By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in Amsterdam. Where and as required, we will seek your explicit consent as outlined in this Privacy Policy.

    7. European Union Rights

      If you are habitually located in the European Union, 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. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

      ACCESS

      You can access much of your information by logging into your account.

      RECTIFY, RESTRICT, LIMIT, DELETE

      You can also rectify, restrict, limit, or delete much of your information by logging into your account and deleting integrations, data points. You can contact our Support Team to delete the entire account.

      OBJECT

      Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

      REVOKE CONSENT

      Where you have previously provided your consent, such as to permit us to process health-related data about you, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent by updating your settings or disconnecting an integration. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

      COMPLAIN

      Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

    8. Consent as a Basis for Processing

      In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in several ways, including, as permitted by law, ticking a box, or connecting an integration, to indicate your consent when (i) providing us with your Personal Data through our Services or a form (including enrolling in Promotions); or (ii) registering or creating an account with us. Due to different countries’ laws governing

      consent for the collection and use of Personal Data, the requirements for consent will differ across regions. We may request your consent for several activities including:

      • Multisport Community Experience Marketing and Communication
      • Third Party Marketing
      • Collecting Mobile Device IDs, Advertising IDs, and Data from Sensors
      • Processing Sensitive Personal Data
      • Collecting and Sharing Location Data
      • Research
      • Advertising
      • Transfer of Data
      • Automated Processing
      • To Connect with Us on Social Media
      • PromotionsMANAGING PREFERENCES AND WITHDRAWING CONSENTYou may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising, your communication settings, and app preferences. Depending on the Service, collection and use of Personal Data may be required for the Services to work. To withdraw your consent, you can delete your account and stop the future processing of data by contacting our Support Team.

        INTEREST-BASED ADVERTISING

        We do very little advertising, and mostly rely on word of mouth for growth. Occasionally we will do advertisements to get more users for the service. Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps.

    9. How We Protect Information

      DATA RETENTION

      We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. Since part of the service is keeping your history for you to view later, we will generally retain data as much as possible. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

      Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

      Where permissible, we will also delete your Personal Data upon your request. If you have questions about our data retention practices, please contact us through our Support Team at vcchelp@kinetic-analysis.com

      SECURITY

      We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

      Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

      LINKS TO OTHER WEBSITES

      Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide a link, recommendations or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third-Party Sites with that you interact with.

      CHILDREN

      We do not knowingly collect Personal Data online from children under 13 (note that the minimum age may vary based on country/region, and on local law). If you become aware that a child has provided us with Personal Data without parental consent, please contact us through our Support Team. If we become aware that a child under 13 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel the child’s account.

    10. Privacy Policy Changes

Although most changes are likely to be minor, Multisport Community Experience may change its Privacy Policy from time to time, especially as we add new features and improvements to the product.

Multisport Community Experience encourages visitors to frequently check this page for any changes to its Privacy Policy. Most changes will be around keeping the details up to date or in updating it to reflect changes in legal requirements, and not material changes to how we handle your privacy. If we make significant changes, we may send you a notification through email. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

If you object to anything in this Privacy Policy, you should stop using the Services and delete your account, please send us an email with your request at vcchelp@kinetic-analysis.com.

Thanks for reading.

VERSION

This privacy statement was created on July 8th, 2022.