Privacy
Policy

Privacy Policy Summary – Golazo Energy

Two-Minute Summary

We care about your privacy! That’s a fact! Would you like to know whether we live up to our word, but find a privacy policy rather boring and rather too full of legal jargon? So do we!

That’s why we’re giving you this summary that you can read in less than two minutes. It provides you with the necessary information and informs you in no time all about the way in which we process your personal data at Golazo Energy.

What should you know? Firstly, we live according to our mantra: you remain the owner of your personal data at all times.

What information do we collect about you?

By creating an account for our APP, we obtain various personal details that are necessary to create and maintain your account, such as your name, e-mail, gender, date of birth, weight and your photograph.
When you register certain workouts on our APP, we collect some personal details, such as your GPS location, speed, calories, distance and heart rate.
If you subscribe to the APP and select a coach to give you audio updates, we also process your chosen language.
If you subscribe to our newsletter, we will use your e-mail address to keep you up-to-date with news about the APP.
When you connect to STRAVA, we also collect the data you authorise us to share, such as your location, speed, calories, distance and heart rate.
In order to create a community, we process personal data such as your contact list (if you authorise us to do so), your name or nickname, photo or avatar, details of your workout, and likes and comments on your workout.
When you communicate about the app via reviews or testimonials, we process this communication as well as your name. We may also ask for a testimonial about the app; for this we will additionally process photos and the testimony.

Why do we collect this information?

To ensure that you can make the best possible use of our services.
To be able to view your workouts later.
In order to be able to send you the newsletter with personal recommendations, and to keep you informed of our services and/or products.
To communicate about the experiences of the app.
For scientific research, statistical purposes and to improve our services.

Who has access to your data?

Your personal data will only be used within Golazo Energy. Your personal data will never be sold or made available to other parties.
Only specific members of our reliable team have access to the information you give us.
We also use various suppliers and service providers, such as application administrators. These parties are legally obliged to ensure your privacy at all times. They may only process the data in accordance with our purposes.
Only anonymised data – which means that you cannot be identified in any way whatsoever – can be made available to other parties outside of Golazo Energy
, unless you have given your permission or consent to share your personal data with them.

What can you control?

You can at any time ask us to modify or delete your personal data.

Send us an e-mail via privacy@energylab.be. Please follow the procedure as described under Article 8 of the full Privacy Policy.

You can also always request a copy of all the information that we have collected about you by sending an e-mail to the same e-mail address.

How do we protect your personal data?

We have taken all kinds of security measures at the technical and organisational level.
Your data is stored on a secure server within the EEA.
We have implemented internal procedures to ensure the confidentiality of our IT infrastructure and to ensure that it is managed in a responsible manner.

FULL PRIVACY POLICY OF THE START 2 RUN APP

Energy NV, a company under Belgian law with registered office at Schoebroekstraat 8, 3583 Paal, and with company number 0872.287.544 (hereinafter: “Golazo Energy” or “we”).

This document provides a description of how Golazo Energy collects and uses personal data in the context of the Start 2 Run APP (hereinafter the “APP”). We also explain how we store your personal data and how we protect your personal data against misuse, and what rights you have with regard to the personal data that you have provided to us. This Privacy Policy must be read together with the Golazo Energy General Terms of Use, which can be consulted in the APP.

We collect and process personal data from the users who register on the APP. If you create an account, you are required to confirm that you have received and read this Privacy Policy. If you don’t agree with the processing it describes, you may no longer use the APP, and we will not be able to provide the services.

Golazo Energy is entitled to consult or use your personal data, either with your explicit consent, for the implementation of the services that have been defined in an agreement, or on any legal basis.

We reserve the right to modify, update or amend our Privacy Policy at any time. You will always find the most recent version on this page, however. We therefore recommend that you check this policy on a regular basis, in order to be sure that you are aware of any changes. If the new Privacy Policy has consequences for the way in which we process the data that we have already collected about you, we will notify you accordingly by e-mail.

1. Scope and purpose of the Privacy Policy

Data controller – Golazo Energy acts as the data controller with regard to the personal data the company collects in the context of the services referred to in this privacy policy; except for the personal data Golazo Energy collects in the context of the purchase of a subscription, the company acts as the processor.

GDPR – This Privacy Policy for the protection of your personal data is strictly in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and on the repeal of Directive 95/46/EC (“AVG” in Dutch, “GDPR” in English).

Contact – If you have questions about this privacy statement, or about the manner in which we collect, use or otherwise process your personal data, please contact us by sending an e-mail to the following e-mail address: privacy@energylab.be.

2. What personal data do we collect?

We can collect personal data that is provided by you or by third parties, insofar as this is necessary or useful for the functioning of the APP and the provision of our services.

This type of information may consist of:

Activity	Personal data	Legal basis	Context
The registration on the APP	First nameLast nameE-mail addressGenderDate of birthWeightPhoto (optional)Password	Contractual necessityConsent in the case of weight	If you register on the APP, we will collect and process the necessary personal data to create your account so that you can register your workouts.
Logging in to the APP with e-mail address and password or with Facebook or Apple ID	E-mail addressPassword	Contractual necessity	If you log in to the APP, we will collect and process the necessary personal data so that you can log into your account.
Purchasing a subscription from the Apple Store or Google Play Store	E-mail addressPassword	Contractual necessity	If you purchase a subscription from the Apple Store or Google Play Store, we collect and process the necessary personal data to be able to link the subscription to your account.
Supplementing/modifying your profile data	Data that is modified/supplemented	Contractual necessityConsent in the case of weight	If you modify your data, we collect this personal data in order to update your account.
Connecting to APIs	WorkoutLocationHeart rateSpeedKcal	Consent	If you give us permission to connect to an API, we collect and process personal data to update your workouts to ensure that you can track your progress.
Selecting an audio coach (in case the user purchased a subscription)	Language	Contractual necessity	We process this personal data in order to provide the audio updates in the correct language.
Monitoring of the heart rate/determining the heart rate zones (if the user has linked a heart rate to the app)	Heart rateHeart rate zonesMin and max BPM	Consent	If you link a heart rate sensor to the APP, we collect and process this personal data to ensure that you can define your goals and track your workouts and progress.
Overview of all workouts	DistanceTimeKcalHeart rateSpeedLocation	Contractual necessityConsent in the case of sensitive data	We collect and process your personal data in order to provide you with an overview of all the workouts that you have registered in the APP.
Subscription to the newsletter/APP updates and promotions	E-mail address	Consent	We collect and process your personal data if you sign up for our newsletter/APP updates and special offers.
The improvement of our APP and services	The personal data you have provided us with	Legitimate interests	We can make use of the data you have provided us with in order to improve our APP and services. We will at all times use this personal data in a GDPR-compliant form, using the most modern and patented software and solutions.
List of other app users	Identification data (name)Contact data (e-mail addresses from your contact list)	Consent	We collect this data to put you in touch with other users of the app.
Community (follow and motivate other users of the app)	Contact list Photo/avatar and name/nicknameInformation regarding your workout, such as time, distance, speed.Heart rate Likes and comments	Contractual necessityConsent in case of sensitive data such as heart rate.	We collect this data to create a community where the users of the app can encourage each other. You can choose whether your profile is public or private, and you can also define who can follow you. We will ask you for your permission for the processing of certain information.
Communicate about the experiences of the app.	Name/nickname, Photos, Testimony / review	Consent	We collect this data to communicate to others about the app and to share your experiences.

We collect your sensitive personal data (health data) when you use the APP. This is only done with your explicit consent. You are not obliged to provide us with your personal data, but then it will not be possible to create an account on the APP and to register workouts.

Direct marketing

Your personal data will only be used for direct marketing purposes if you have given us your explicit prior consent to do so in the APP.

Your e-mail address can be removed from our direct mailing list free of charge at any time, without giving any reason, by clicking the unsubscribe button that you can find at the bottom of each promotional e-mail.

UPLOADING YOUR CONTACTS

Uploading contacts is an optional feature that allows us to check which contacts from your device’s address book are also using our app. Your contact list is not stored with us, but only compared based on the email address of your contact.

If you use contact uploading and allow Start 2 Run to access your device’s address book, Start 2 Run will view and upload the new email addresses in your address book. This is done in a secure, encrypted manner every time the app is launched. We also do not collect any other information that may appear in your device’s address book, such as names, phone numbers, etc.

Following a contact is not done automatically, but that way we can compile a list of interesting contacts that you can then follow (as public profiles) or send follow requests to (as private profiles).

You can manage the contact upload function from the ‘community’ > ‘contact’ settings in the menu of our app.

3. Why do we process personal data?

We collect and process your personal data in order to provide you with a secure, comfortable and personal experience when using the APP.

The information we collect about you is mainly processed to help us ensure the proper technical operation and to improve the quality and content of the APP, on the basis of the legal purposes of “consent”, “legal obligations” and “contractual necessity” or “legitimate interests”, as permitted under the GDPR.

Your personal data is thereby exclusively used for the following (internal) purposes:

Activity	Processing purpose
The registration on the APP	We collect this personal data in order to create your account so that you can register your workouts, and to provide you with a better user experience.
Logging in to the APP with e-mail address and password or with Facebook or Apple ID	This personal data is processed to enable you to log in to the APP.
Purchasing a subscription from the Apple Store or Google Play Store	We collect and process the necessary personal data in order to be able to link the subscription to your account.
Supplementing/modifying your profile data	We collect and process this personal data in order to be able to update your account with the data you have added/modified.
Connecting to APIs	We collect and process this personal data in order to update your workouts to ensure that you can track your progress.
Selecting an audio coach (in case the user purchased a subscription)	We collect and process this personal data in order to provide the audio updates in the correct language.
Monitoring of the heart rate/determining the heart rate zones (if the user has linked a heart rate to the app)	If you link a heart rate sensor to the APP, we collect and process this personal data to ensure that you can define your goals and track your workouts and progress.
Overview of all workouts	We collect and process your personal data in order to provide you with an overview of all the workouts that you have registered in the APP.
Subscription to the newsletter/APP updates and promotions	We collect this data in order to keep you informed of relevant updates with regard to the APP.
The improvement of our APP and services	In order to continuously improve the APP, we will use your personal data in a GDPR-compliant manner by making use of anonymisation or pseudonymisation techniques. This also applies with regard to the further use of your data for legitimate secondary purposes.
List of other app users	We process the data in order to enable you to make optimal use of the app and to put you in touch with other users of the app.
Community	We process the data in order to be able to use the community feature within the app.
Communicate about the app through reviews and testimonials	We process this data to share your experiences about the app with others.

4. How (long) do we process personal data?

We never retain your data longer than is necessary in order to provide you with our services , for the purposes specified in this Privacy Policy, and for the legal purposes for which we are obliged to retain the information. If we no longer need to use your data, and there is no need for us to retain your data in order to comply with our legal or regulatory obligations, we will remove the data from our systems, or anonymise it so that we can no longer identify you.

Activity	Retention period
Registration on the APP	Up to 2 years from inactivity
Logging in to the APP with e-mail address and password or with Facebook or Apple ID	Up to 2 years from inactivity
Purchasing a subscription from the Apple Store or Google Play Store	Up to 2 years from inactivity
Supplementing/modifying your profile data	Up to 2 years from inactivity
Connecting to APIs	Up to 2 years from inactivity
Selecting an audio coach (in case the user purchased a subscription)	Up to 2 years from inactivity
Monitoring of the heart rate/determining the heart rate zones (if the user has linked a heart rate to the app)	Up to 2 years from inactivity
Overview of all workouts	Up to 2 years from inactivity
Subscription to the newsletter/APP updates and promotions	Up to 2 years from inactivity
The improvement of our APP and services	Up to 2 years from inactivity
List of other app users	Up to 2 years from inactivity
Community	Up to 2 years from inactivity
Communicate about the app through reviews and testimonials	Up to 2 years after the testimonial/review

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5. With whom do we share personal data?

We do not share your data with third parties for commercial purposes. In certain cases, however, your data may be shared with other companies of the GOLAZO Group, of which Golazo Energy is a part, or in the case of a transfer of activities from our company. These companies will, however, only use your data in accordance with the purposes specified in this Privacy Policy.

In certain cases, your personal data may be shared with third parties who provide services to us. This may relate to services that are provided by partners, IT providers, mail providers, cloud providers or statistics administrators such as, for example, Nextapps.

In addition, we are obliged to communicate your personal data when this is required by law or by a court decision. If we have to pass on personal data to third parties in other situations, this will only happen with your consent where this is legally required.

We will not sell, rent, distribute or otherwise make your personal data commercially available to third parties, except as provided for in this Privacy Policy, or if you have given your explicit prior consent.

Only specific members of our reliable team have access to the information you give us. We have taken all legal and technical precautions to prevent unauthorised access and use. We guarantee a similar level of protection by imposing contractual obligations on these suppliers and service providers that are comparable to this Privacy Policy.

6. Transfer of personal data outside the EEA

Insofar as personal data is stored outside the European Union, we use contractual or other measures to ensure that they are stored under suitable protective measures, comparable to the level of protection they would benefit from in the European Union.

7. Use of cookies

We use several types of cookies in the APP, as specified in our cookie policy.

8. Exercising your rights

The right to access and the right to obtain a copy

You have the right to freely access your personal data at any time, and to be informed about our purpose for processing your personal data.

A deceased person’s account can be managed by a family member or loved one. The personal data that we process at that time are name, e-mail address, connection with the deceased person and the death certificate. This data will not be kept.

The right of correction, deletion or restriction

You have a choice when it comes to sharing personal data with us. You always have the right to ask us to modify your personal data. You can also request to limit the processing of your personal data if you believe that your personal data is incorrect, and you subsequently inform us accordingly.

In addition, you have the right to ask us to delete your personal data insofar as we have been unable to anonymise it. You further acknowledge that a refusal to share personal data or a request to delete your personal data will make the delivery of various services or the purchase of products impossible.

The right to object

You have the right to object to the processing of your personal data if you have serious and justified reasons for doing so. You also have the right to object to the use of your personal data for direct marketing. No specific reason is requested in this case.

The right to the transferability of data

You have the right to receive the personal data that we process about you in a structured, commonly used format, and/or to have this personal data transferred to another data controller.

The right to withdraw consent

If the processing is based on prior consent, you have the right to withdraw this consent.

Automated decisions and profiling

You have the right to request us not to be subject to a decision that is exclusively based on automated processing, including profiling, that has legal consequences for you or that significantly affects you in a similar way.

Exercising your rights

You can exercise your rights by contacting us, with a copy of the front of your identity card as an attachment, either via e-mail to privacy@energylab.be or by letter to the following address:

ENERGY NV
Schoebroekstraat 8,
3583 Paal-Beringen
Belgium

Right to submit a complaint

You have the right to submit a complaint to the Belgian Data Protection Authority:

Data Protection Authority
Drukpersstraat 35,
1000 Brussels,
Tel. +32 (0)2 274 48 00,
Fax +32 (0)2 274 48 35,
E-mail: contact(at)apd-gba.be

This is without prejudice to proceedings before a civil court.

If you have suffered damage as a result of the processing of your personal data, you can submit a claim for damages.

9.How do we secure your personal data?

We attach great importance to the security, integrity and confidentiality of personal data. To the best of our ability, we implement adequate security measures that have been designed in accordance with the latest state of the technology to protect this personal data from unauthorised access, disclosure, use and modifications. Specifically, we make use of secured connections whenever users provide personal data via the APP.

10. Choice of law and jurisdiction

This Privacy Policy is subject to, and has been drawn up according to Belgian law. In the event of a dispute, the Courts of the judicial district of Antwerp, Hasselt division, have exclusive jurisdiction.

11. Questions

Questions, remarks and requests with regard to this Privacy Policy are welcome, and should be addressed to

ENERGY NV
Schoebroekstraat 8,
3583 Paal-Beringen
Belgium
Or to privacy@energylab.be

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PrivacyPolicy