Privacy policy
1. To whom does this Privacy Policy apply?
2. Who is responsible for data processing?
3. What is the legitimation for data processing?
4. What information do we process?
5. For what purpose do we process the data?
6. How long will we keep the data?
7. To which recipients are the data communicated?
8. Can data be transferred internationally?
9. What rights does the user have in relation to the data they provide?
10. How do we protect our users' data?
11. Modifications
12. Applicable legislation
1. To whom does this Privacy Policy apply?
When visiting or consulting the website move.fittoken.io(henceforth, the Website) and by downloading the FITTOKEN MOVE application (henceforth, the App) and using our services offered on this platform, the user (natural persons interested in using the application for mobile phones, tablets and other smart devices of the App), accepts the processing of his personal data, giving conformity to the terms established in this document (henceforth, the "Privacy Policy").
This Privacy Policy and the way we process your data will be regulated by the General Data Protection Regulation, or Regulation [EU] 2016/679 ("RGPD").
2. Who is responsible for data processing?
This is the relevant information of the person in charge of processing the personal data that is processed and provided by users:
| identity | FITNESS DIGITAL ASSETS, SL (from now on, “FITTOKEN”) |
| Domicile | C/Goya, 15 1r -28001, Madrid, Spain. |
| hola@fittoken.io |
3. What is the legitimation for data processing?
The legal bases for the processing of personal data are:
- The execution of the forms on the Website and the App, these forms (section 4.a), are filled in by the interested party or share certain information and thereby give full consent to the processing of personal data.
- The execution of a contract.
4. What information do we process?
The information that we receive from users or that they share, and that will be treated with the utmost confidentiality, is treated and managed as described below.
a) Information Users Provide Us Directly: FITTOKEN collects and stores certain information that users enter in the App, through the following section/form.
| "Register" | The information that the user provides us when requesting registration in our App full name, email, gender and date of birth, | Identification data. |
| "Boosters" | Information that the user provides to us when investing in some of our Booster packs, i.e. name, email and credit and debit card details. | Identification data. Economic data |
| Own and third-party cookies | FITTOKEN uses its own and third-party cookies to distinguish you from other users of our Website and App. Therefore, without exhaustiveness, it collects the following information, browser type, operating system, including the content you browse and the time of day you browse, as well as your online identifier (i.e. the IP assigned to the device). | Data derived from cookies for identification purposes Data derived from navigation. |
| Access to physical activity data | The App collects information about the user's location and physical movements through the Google Fit or Apple Health health platforms, necessary for the App to function properly and to monitor and verify eligible forms of movement. - Data received from Google Fit: steps, calories, pulses and physical exercise activities. - Data received from Apple Health: steps, calories, floors climbed and physical exercise activities. |
Data derived from physical activity monitoring of an identifying nature. |
1.1 Data quality: The user must guarantee, both to FITTOKEN and to third parties, the quality of the information and personal data provided through the Website and the App. This implies that all personal data and information provided must be real, truthful, up-to-date and belong to the user and not to third parties. If they belong to third parties, we understand that it is through their consent and request that this third party be invited to learn about our legal texts as soon as possible.
1.2 Modification of data: The user must notify FITTOKEN of any modification that occurs to the personal data provided, responding in any case to the veracity and accuracy of the data provided at all times.
5. For what purpose do we process the data?
| Provision of services/Create an account/Make purchases on the Website - App | FITTOKEN may use the personal data provided by the user: - By registering or logging into the App to confirm your identity and verify your personal and contact details. - To fulfill the obligations arising from the contract. - To analyze and quantify the data received to generate rewards within the App. - For the processing of claims submitted by the user in relation to our services. - To get in touch with the user, in particular for purposes related to the provision of services, to make communications via email about its operations and thus comply with internal procedures, to inform you of updates to the App, the Website, our Terms and Conditions and/or this Privacy Policy. |
| Communication of data to third parties (exceptions) | - The personal data will be shared exclusively with Atlas Sport Consulting, SL, (from now on, “Atlas”) who will act as Data Controller on behalf of FITTOKEN, in its capacity as a collaborator. In addition, the data may be transferred to other organizations that maintain a contractual relationship with FITTOKEN or Atlas. - In case it is strictly necessary for the requested services, in case FITTOKEN collaborates with third parties. When FITTOKEN has express and unequivocal authorization from the user. When requested by a competent authority in the exercise of its functions (to investigate, prevent or take actions relating to illegal actions).If a regulation requires it. |
| Promotional messages with cancellation option. | With the consent of the user, FITTOKEN and/or ATLAS will be able to use the personal data we obtain to send information, news and advertising about our services and other similar ones. In any case, you can avoid sending new informative e-mails by requesting it at the e-mail addresshola@fittoken.io orthrough the link that appears in the body of each of the e-mails we send and consequently, FITTOKEN and/or ATLAS will stop sending the aforementioned information. |
| Own and third-party cookies | In order to provide a better browsing experience and inform us about your last visit to our Website and App (technical and personalization cookies). With the user's consent, cookies can be installed to calculate the number of people who enter the Website and App, as well as store information on user behavior obtained through the continuous observation of their browsing habits ( analytical, advertising and behavioral). In order to use information collected by cookies and similar technologies in an optimized way, we use analytical tools and tools that allow us to manage the advertising and marketing of our products and services, including the display of targeted advertising based on the recognition of the device These tools also allow us to process the information collected to support our research and development work and our marketing activities. In accordance with your consent, your personal data (collected, among other things, through cookies) may be processed in an automated way (even for the definition of profiles) and, on the basis of the information collected (for example , data relating to your preferences), we can personalize the advertising content presented on and off our Website. Likewise, and with your consent, we may also share information about the use of our Website with our collaborators in social networks, advertising and analytics, who may combine it with other information that you have provided to them or that have collected as a result of the use of its services. Most browsers support the use of cookies automatically, but you can set your browser to be warned on your computer screen about the receipt of cookies and, in this way, prevent their installation on your hard drive . For detailed information about the cookies we use and the purposes for which we use them, please see ourCookies policy. |
FITTOKEN and Atlas will retain the user's personal data for as long as is reasonably necessary to: comply with any of the objectives mentioned in this Privacy Policy and comply with current legislation, regulatory requirements and relevant orders of competent courts, or, in any case, while we send you information or communications and the interested party does not request deletion or opposition.
Your personal data will be anonymized or deleted once it is no longer relevant for the purposes for which it was collected.
7. To which recipients are the data communicated?
The personal data that FITTOKEN collects will be exclusively used to achieve the object defined on the Website and App. For the achievement of said objective and the correct provision of the service, FITTOKEN could share certain personal data of users:
- With prior legal requirement, FITTOKEN may share information with bodies of executive authorities and/or third parties regarding requests for information relating to investigations of a criminal nature and alleged illegal activities.
- As set out in clause 5 with our collaborating partner Atlas.
- FITTOKEN may share personal data with third-party collaborators, such as public or private entities, in order to facilitate the delivery of prizes or for the management and coordination of activities related to the challenges in which users participate. This includes, among others, the possibility for the mentioned entities to contact the winners of the challenges for the awarding of prizes. In these cases, only the data necessary for these purposes, such as the user's name and email address, will be shared. By participating in the FITTOKEN platform, the user accepts this transfer of data under the agreed conditions, always guaranteeing compliance with current legislation on the protection of personal data.
- External service providers: in order to fulfill the purposes of this Privacy Policy, we need to give access to your personal data to third parties who support us in the services we offer you, namely: financial institutions, providers of technological and analytical services , providers of legal, accounting and tax services, providers and collaborators of marketing, advertising and social media services who in some cases may act as joint responsibles, always under the exclusive control of FITTOKEN, when necessary to provide the our services.
i. Platform for sending mailings: If you expressly authorize the sending of commercial information, you will be able to collaborate with ActiveCampaign, LLC, a company registered in the United States, always under the exclusive control of FITTOKEN. The user can consult the Privacy Policy of this providerhere.
ii. Online payment gateway: Redsys Services de Processing, SL, is the platform that allows us to manage payments for Boosters purchases. Some of the purposes for which it treats the data are: detect, control and prevent fraud and unauthorized payment operations, mitigate financial losses, claims, liabilities or other damages; to determine eligibility and offer new services, among others. For more information, the user can consult its Privacy Policyhere.
- With the consent of the user: aside from what has been established above, the user will be informed in the event that any information about him is brought to the attention of the commercial partners of the Website, or with third parties, in the nature of different from the purposes set out on the Website (eg: for commercial purposes), so that you have the opportunity to decide not to share your information. None of the above data communications will include selling, renting, sharing or otherwise disclosing personal information of customers for commercial purposes contrary to the commitments made in this Privacy Policy.
8. Can data be transferred internationally?
In the event that we transfer your personal data to a third country, i.e. a country outside the European Economic Area (the countries of the European Union plus Liechtenstein, Iceland and Norway) or that does not have a recognized appropriate level of data protection, we will comply with all laws applicable to such transfer, including ensuring that your personal data is kept secure and safeguards are in place to ensure that there is adequate protection. For this, FITTOKEN will use Contractual Clauses Type of data protection adopted by the European Commission or, where appropriate, we will rely on the EU – US Data Privacy Framework (for the case of data transfer to the United States).
9. Processing of personal data in the Blockchain
As part of the provision of FITTOKEN services, it is established that the Smart Contracts used by the App require certain data to be included in the Polygon network blockchain. This data is stored publicly and permanently, without the possibility of modification or deletion.
Data Included in the Blockchain:
- The amount of FITtokens (hereinafter “FIT”) earned as a result of interactions on the FITTOKEN platform (for example, weekly rewards).
- The date and time the FITs were transferred via a blockchain transaction.
- The public key (a unique and anonymous cryptographic identifier) of the wallet of the user receiving the FITs.
Although this data is anonymous, the user should be aware that their public key can be linked to the user if you share it with third parties, since anyone can access the public information stored on the blockchain. Neither FITTOKEN nor its partners control the blockchain; therefore, the user must assume that this information will be publicly available indefinitely.
Since the use of Smart Contracts involves automated decisions on the distribution of FIT, and these may have significant effects on the user (for example, loss of rights to tokens), it is established that the user has the right to:
- Request human intervention in any process that significantly affects your personal data.
- Challenge any automated decision made by Smart Contracts.
- Receive a clear explanation of the operation of automated decisions involving personal data.
If you do not want your data to be included in the blockchain or if you prefer not to participate in these automated decisions, we recommend that you do not use our service.
FITTOKEN adopts technical and organizational measures to guarantee the security of your personal data, minimizing the risks of errors or vulnerabilities in Smart Contracts. However, due to the immutable nature of the blockchain, we advise you to take the necessary precautions when using our services and sharing your public key.
10. What rights does the user have in relation to the data they provide?
The user may exercise the following rights before FITTOKEN:
- Right to be informed: The user has the right to receive clear, transparent and easily understandable information about how we use their information and their rights. For this reason, we provide you with this information in this Privacy Policy.
- Right of access: the user has the right to obtain access to his information (in case we are processing it), as well as to other types of information (similar to that provided in this Privacy Policy), so that he is informed and can check that we use your information in accordance with data protection legislation.
- Right to rectification: the user has the right to have his information (inaccurate data) corrected if it is incorrect or incomplete.
- Right of deletion: Also known as the “right to be forgotten” and ultimately allows you to request the removal or deletion of your information when the data is no longer necessary for the purposes for which it was collected. This does not constitute a general right of deletion; there are exceptions.
- Right to limit processing: the user has rights that allow you to "block" or prevent further use of your information. When processing is limited, we will only retain your information for the exercise or defense of claims. We also keep lists of users who have requested "blocking" so that their information continues to be used in order to ensure that the restriction is respected in the future.
- Right to data portability: the user has rights that allow you to obtain and reuse your personal data for your own purposes in different services.
- Right to oppose it: the user has the right to object to certain types of treatment, including treatment for direct marketing purposes. Except for compelling legitimate reasons, or the exercise or defense of possible claims.
The exercise of the aforementioned rights is strictly personal, so the user will need to provide proof of Identity.
To exercise the rights provided for in the legislation, the user can contact FITTOKEN via email hola@fittoken.io or by writing to the address listed in section 1 of this Privacy Policy. The communication will contain the following data and documents:
- Name and surname of the interested party, attaching a photocopy of the DNI or other valid document that identifies them and, if applicable, of the person who represents them; the use of electronic signature will exempt from the presentation of these documents.
- Indication of the domicile of the interested party and request specifying the request (the right that is intended to be exercised).
Likewise, we remind you that you can exercise any of these rights for yourself:
- Unsubscribe from receiving commercial information, using the "unsubscribe from commercial information" function available in the footer of each commercial information sent by us.
- You can withdraw your consent to the installation of cookies in relation to the processing of personal data for the purposes determined by the function of these cookies, in the cookie installation management tool that you can find at our Website.
The user will also have the right to submit a claim to the corresponding Control Authority or to the Spanish Data Protection Agency (www.aepd.es), when you consider it convenient.
11. How do we protect our users' data?
FITTOKEN informs the user that we have adopted the necessary technical and organizational measures required by current data protection regulations to guarantee the security of its data, in order to avoid alteration, loss, unauthorized access or treatment thereof.
As mentioned, the personal data provided by users through the Website and the App will not be transferred to other entities or companies to be used for their own purposes. However, some companies subcontracted by FITTOKEN could have access to personal data and information, always under the exclusive control of FITTOKEN, with the sole purpose of providing a service necessary for the correct functioning of the Website, the App and our services.
12. Modifications
FITTOKEN reserves the right to modify this Privacy Policy in accordance with applicable legislation at any time. For this reason, it is recommended that the user periodically review this Privacy Policy in order to be informed of the treatment and protection of personal data, as well as the rights that assist you.
13. Applicable legislation
This Privacy Policy will be governed and interpreted in accordance with Spanish legislation, as well as the resolution of any controversy or divergence related to the Website and the App. The use of the services of this Website implies the express acceptance of the Spanish jurisdiction.
Date of last update: October 2024