Sport Strength Company Limited (“Primal,” “we,” “us,” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information we obtain about visitors to our website, www.primalperformancelab.com (the “Site”), users of our mobile applications (the “App” or “Apps”), and the services available through our Site and App, and how we use and disclose that information.

By visiting the Site, using or downloading the App, or using any of our services, you acknowledge that your personal information will be handled as described in this Policy. Your use of our Site, App, or services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

We use your information, including your personal information, for the following purposes:

- To provide our services to you, to communicate with you about your use of our services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.

- To tailor the content and information we may send or display to you, to offer location customization, to offer personalized help and instructions, and to otherwise personalize your experiences while using the Site and App. We also use information collected through our heart rate monitors, punching trackers, body scans, and your App out-of-studio workouts to customize workout programs and classes and to conduct workout challenges.

- For marketing and promotional purposes in accordance with applicable laws. For example, we use your information, such as your email address, to send you news and newsletters, special offers and promotions, or to otherwise contact you about products, services, workout sessions, or other information we think may interest you.

- We use your information (typically in the aggregate) to assist us in advertising the Primal brand on unaffiliated websites and in evaluating the success of our adverting campaigns (including our online targeted advertising and offline promotional campaigns).

- To better understand how users access and use our Site and Apps, both on an aggregated and individualized basis, in order to improve our Site and Apps and respond to user desires and preferences, and for other research and analytical purposes.

- To administer our membership reward program.

- To administer surveys and questionnaires, such as for market research or member satisfaction purposes.

- To comply with legal and regulatory obligations, as part of our general business operations, and for other business administration purposes, including authenticating your identity, maintaining customer records, to monitor your compliance with any of your agreements with us, to collect debts owed to us, to safeguard our business interests, and to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or ‎‎merger, as described below.

- Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud or error, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Privacy Policy.

- For other purposes, we may inform you about it from time to time.

2.1 How we use your information

We collect information about you directly from you and from other parties, as well as automatically through your use of our Site and App.

Information We Collect Directly From You. The information we collect from you depends on how you use our Site, App, and Services.

- To Sign Up for a Workout Online. To sign up for a workout at Primal through our Site or App, you must provide us with your name, email address, phone number, date of birth, your payment information (in order to hold your workout reservation). We also will collect information that you provide about any health conditions that could affect your ability to participate in a workout.

- To Schedule or Purchase Sessions Online. To create an account to sign up for workout sessions or to purchase sessions online through our Site or our App, you must provide us with your name, physical address, email address, date of birth, phone number, height and weight, payment and billing information, and username and password. If you complete a membership agreement or sign up for a fitness event, we also collect information that you provide about any health conditions that could affect your ability to participate in a workout. If you do not provide this information, you will not be able to create an online account, complete a membership agreement, or make a purchase. We will also collect information about the workouts you schedule and information about your purchases. You may also provide information about your preferences, such as your favourite studios and coaches.

- When You Visit Primal. If you sign up for a workout or become a member by registering on our app or at our studio, you must provide us with your name, physical address, email address, date of birth, phone number, height and weight, marital status, emergency contact information, and payment and billing information. We also will collect information that you provide about any health conditions that could affect your ability to participate in a workout. If you do not provide this information, we may not be able to offer our services to you.

We also will collect information about the workout sessions you schedule, details about your exercise frequency and goals (as provided by you), and information about your in-studio purchases. We will also collect information when you check in for a workout, such as your name, address, email address, member number, and studio location.

As part of your workout session, you may choose to use our heart rate monitors and/or punch monitors. If you do so, we will collect your workout session heart rate, and other workout statistics, such as the number of miles run and a number of punches.

At certain locations, you have the option of voluntarily participating in a body scanning program. This scan will measure your body’s muscle mass, fat percentage, and total body water, and will report your overall body composition and body mass index (based on your height, weight, gender, and age). These scans help you understand the effects of your workouts.

- Information We Collect from Social Networking Sites.

You may log into your online account or our Apps through Facebook. If you log in to your account or link your account to your Facebook profile, you must enter your Facebook email address and password. We will ask that you grant us permission to (i) access your Facebook basic profile information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account); (ii) post to your wall; and (iii) access posts in your newsfeed. If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public through Facebook.

We store the information we receive from Facebook with other information that we collect from you or receive about you in accordance with this Policy. Any social networking site, such as Facebook, controls the information it collects from you pursuant to its own terms. For information about how a social networking site may use and disclose the information it collects about you, including any information you make public through the social networking site, please consult the social network’s privacy policy. We have no control over how any social networking sites use or disclose the personal information they collect about you.

We also collect information about you when you interact with us on social networking platforms. If you message us or tag us in a social network post, we will collect information about your message or the post we are tagged in. Information We Collect Automatically. We automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Site:

- domain name;

- your browser type and operating system;

- web pages you view on the Site; links you click on the Site; your IP address;

- the length of time you visit our Site and or use our Services;

- the referring URL, or the webpage that led you to our Site;

- and your device’s location information, with your permission, to help identify primal located in your area and to help us market primal services.

App:

- mobile device ID; device name and model; operating system type, name, and version;

- language information;

- activities within the App; and the length of time that you are logged into our App;

- location information. With your permission, we will collect location information from your mobile device to:

(1) track and map your out-of-studio run/walk workouts that you initiate in the App;

(2) help you identify primal studios located in your area;

(3) to help us market the primal services. You may turn off this feature through the location settings on your mobile device.

- Out-of-Studio Workouts: You may use the App help you track your out-of-studio run/walk workouts. In addition to mapping your workout as described above, we will collect the date and time of your workouts, the elevation of your workout, your speed and workout pace, your workout’s total distance, your step count and cadence, estimated calories burned, and, if you use a heart rate monitor during your workout, your heart rate data.

2.2 How we share your information

We may share your information, including personal information, as follows:

- Workout Sessions and Challenges. During a workout session, participants may share their name and heart rate information with other session participants on our in-studio display screens. If you participate in a workout challenge, you may share your name and workout information with other challenge participants. You may also share information about your workouts and the challenges you participate in with your social media accounts. - Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.

- Service Providers. We disclose the information we collect from you to our vendors, service providers, contractors, and agents who perform functions on our behalf. In particular, the workout sign-up portal is hosted by Mindbody; as noted above, when you register for a workout, your information is available to the owner of that particular location.

We will store the personal information provided by the Customers on our internal systems during providing services to the Customers or until the purpose of collection is fulfilled or when the Customers request to cancel the information provided.

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site and App. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and App, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and App.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web or mobile application pages. We may use clear GIFs (aka web beacons, web bugs or pixel tags), in connection with our Site and App to, among other things, track the activities of Site visitors and App users, help us manage content, and compile statistics about usage of our Site and Apps. We and our service providers also use clear GIFs in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Analytics. We use automated devices and applications, such as Adobe Analytics and Google Analytics, to evaluate usage of our Site, to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To opt-out of Adobe Analytics, please visit https://www.adobe.com/privacy/opt-out.html. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do Not Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt out of targeted advertising by following the instructions in the Ad Networks section.

Ad Networks. We use network advertisers to serve advertisements on unaffiliated websites or other media (e.g., social networking platforms). This enables us and network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors, and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you.

We may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audience go here or to opt-out, go to the Facebook ad preferences page)—so that we can better target ads and content to you and others with similar interests on other websites or media (“Custom Audiences”). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.

Links: Our Site and Apps may contain links to unaffiliated entities’ websites. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.

Business name: Sport Strength Company Limited

Established and operated under business license number 0317167181 issued on 23rd February 2022 by the Department of Planning and Industry of Ho Chi Minh City.

Address: 13 Nguyen Duy Hieu, Thao Dien Ward, Thu Duc City, Ho Chi Minh City

Email: [email protected]

You may modify the personal information that you have submitted by logging into your account and updating your profile information. You may also update your information by visiting the Primal Studio. Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Site or App for a period of time.

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

In accordance with applicable law, we will send periodic promotional communications to you. You may opt-out of such communications by following the opt-out instructions contained in the communication, or if you have opted-in to our promotional text messages, replying STOP. We will process opt-out requests in accordance with applicable law. If you opt-out of receiving promotional communications about recommendations or other information we think may interest you, we may still send you communications about your account or any services you have requested or received from us. App users may enable or disable push notifications by adjusting their App or device settings.

Children under the age of 13: Our Site, Apps, and services are not designed for children under the age of 13. If we discover that a child under the age of 13 has provided us with personal information, we will delete such information from our systems.

When your information is used in wrong purposes or violate with our privacy policy, customers inform us at our compaint handling center:

13 Nguyễn Duy Hiệu, Phường Thảo Điền, TP Thủ Đức, TP. HCM

Email: [email protected]

Hotline: 0965000342