GDPR Data Retention Policy & Schedule

Last updated May 23, 2018

We keep your personal data only as long as necessary to provide you with the Exercise.com Service and for legitimate and essential business purposes, such as maintaining the performance of the Exercise.com Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Exercise.com Service. For example, we keep your workout history, exercise history, logged workout and health data, and account information.

If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:

  • If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
  • Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
  • Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
Categories of personal data Description of category
Account Registration Data

This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Exercise.com Service. This includes your email address, birth date, gender, postal code, and country.

Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized.

The exact personal data we will collect depends on the type of Exercise.com Service plan you sign up for and whether or not you use a Third Party Service (as defined in the Terms of Service , such as Facebook) to sign up and use the Exercise.com Service. If you use a Third Party Service to create an account, we will receive personal data via that Third Party Service but only when you have consented to that Third Party Service sharing your personal data with us.

Personal data collected through your use of the Exercise.com Service
Categories of personal data Description of category
Exercise.com Service Usage Data

This is the personal data that is collected about you when you are using the Exercise.com Service - this may include:

  • Information about your type of Exercise.com Service subscription or membership.
  • Information about your interactions with the Exercise.com Service which includes the date and time of any requests you make, content ( workouts, workout plans, exercises, groups, resources, assessments, videos, etc.) you create, content you've accessed, and your interactions with other Exercise.com users. This also may also include details of your use of Third Party Applications and advertising you receive.
  • User Content you post to Exercise.com including messages you send and/or receive via Exercise.com and your interactions with the Exercise.com Support team.
  • Technical Data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Exercise.com Service, unique device IDs, device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Exercise.com application version. Further details about the technical data that is processed by us can be found in our Cookie Policy.
  • Any motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Exercise.com Service to you.
Voluntary Mobile Data

In addition to the mobile data we collect to provide you with the Exercise.com Service (outlined above), you also have the option to give us your consent to collect additional personal data from your mobile device to provide you with features/functionality that will enhance your Exercise.com Service experience.

We will not access any of the personal data listed below without first obtaining your consent:

  • Your photos - If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll;
  • Your precise mobile device location - If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Exercise.com Service. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements;
  • Your contacts - If you give us permission to access your contacts, this enables us to access individual contacts stored on your device to help you find friends who use Exercise.com.
Payment Data

We may collect such personal data if you sign up for a Trial or purchase any Paid Subscriptions or make other purchases through the Exercise.com Service. The exact personal data collected will vary depending on the will include information such as:

  • Name;
  • Date of birth;
  • Credit or debit card type, expiration date, and certain digits of your card number;
  • Postal code;
  • Mobile phone number; and
  • Details of your transaction history.

If you choose to pay by invoice, we will provide your personal data to our payment processors to enable them to complete a credit check and to send you invoices.

Contests, Surveys and Sweepstakes Data
This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion.
Marketing Data

This personal data is used to enable Exercise.com and our partners/service providers to send you marketing communications either:

  • Via email;
  • Whilst using the Exercise.com Service; and/or
  • Direct from the third party.

You can find out more about the personal data collected and the controls you have in relation to the marketing communications you receive via the Privacy Policy.

What do we use your personal data for?

When you use or interact with the Exercise.com Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data used for these purposes:

Description of why Exercise.com processes your personal data ('processing purpose') Legal Basis for the processing purpose Categories of personal data used by Exercise.com for the processing purpose
To provide, personalize, and improve your experience with the Exercise.com Service and other services and products provided by Exercise.com, for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside of the Exercise.com Service (including for third party products and services).
  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Service Usage Data
To understand how you access and use the Exercise.com Service to ensure technical functionality of the Exercise.com Service, develop new products and services, and analyze your use of the Exercise.com Service, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Exercise.com Service.
  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Service Usage Data
To communicate with you for Exercise.com Service-related purposes.
  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Service Usage Data
To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Exercise.com Service.
  • Performance of a Contract
  • Compliance with legal obligations
  • Legitimate Interest
  • Payment Data

To communicate with you, either directly or through one of our partners, for:

  • marketing,
  • research,
  • participation in contests, surveys and sweepstakes,
  • promotional purposes,

via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your Account Settings page).

  • Consent
  • Legitimate Interest
  • Contests, Surveys and Sweepstakes Data
  • Marketing Data
To provide you with features, information, advertising, or other content which is based on your specific location.
  • Consent
  • Voluntary Mobile Data
Sharing your personal data

We have set out the categories of recipients of the personal data collected or generated through your use of the Exercise.com Service.

Publicly available information

The following personal data will always be publicly available on the Exercise.com Service: your name and/or username, profile picture, who you follow and who follows you on the Exercise.com Service, and any public workouts, exercises, and records.

Personal data you may choose to share

The following personal data will only be shared with the categories of recipients outlined in the table below if:

  • you choose to make use of a specific Exercise.com Service feature where sharing of particular personal data is required for the proper use of the Exercise.com Service feature; or
  • you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Exercise.com Service.
Categories of Recipients Reason for sharing
Third Party Applications you connect to your Exercise.com Account
If you connect your Exercise.com account to a Third Party Application, such as, for example, social media, audio, television, or automotive platforms, Exercise.com may share your Service Usage Data so you can connect to your Exercise.com account.
Third Party Applications you use to log into Exercise.com

If you log into a Third Party Application using your Exercise.com account credentials, then that Third Party Application may have access to certain Service Usage Data such as your exercise or workout history, saved content, and activity.

You will receive a notification before connecting to the Third Party Application to let you know what personal data will be shared/accessible to that Third Party Application.

Your Exercise.com Followers

There also may be times when you want us to share certain Service Usage Data, specifically information about your use of Exercise.com, with other Exercise.com users known as 'Your Exercise.com Followers'.

For example, when you log workouts, you might want those workouts to be visible to others on the Exercise.com Service, but you can also make your workouts private at any time.

Information we may share

Categories of Recipients Reason for sharing
Service Providers and Others

We use technical service providers which may operate the technical infrastructure that we need to provide the Exercise.com Service, in particular providers which host, store, manage, and maintain the Exercise.com application, its content and the data we process.

We use technical service providers to help us communicate with you.

We use marketing and advertising partners to show you more tailored content, or to help us understand your use of the Exercise.com Service, to provide you with a better service. We also may also share personal data with certain marketing and advertising partners to send you promotional communications about Exercise.com.

Exercise.com Partners

If you access the Exercise.com Service through a third party such as another website, we share personal data with that third party about your use of the Exercise.com Service, such as activating an Exercise.com account, or actively used the Exercise.com Service.

Depending on how you sign up for the Exercise.com Service (e.g. through a third party service or a social media account), we share your Exercise.com username or other Account Registration Data as necessary to enable your account.


Academic Researchers
We will share your personal data for activities such as statistical analysis and academic study, but only in a pseudonymized format.
Law Enforcement and Data Protection Authorities

We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.

We also will also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party's legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

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