1. January 2024

Privacy Policy for #AllAboutUs

Generel information

This document relates to PeakingPower ApS, VAT no. 39718944 with registered address House of Sports, Copenhagen, Denmark (“Infront”, “we” or “us”) and contains our privacy policy regarding the collection and processing of Personal Data (this “Privacy Policy”). The privacy policy applies when Infront processes Personal Information about participants in the app “#AllAboutUs”. Registration is done and a profile is created via the website , after which the app that contains the campaign can be downloaded. On the website, your profile and affiliation with teams can be edited.

Definitions

“Applicable personal data legislation” refers to the general regulation on data protection (Regulation No. 2016/679), which is supplemented and implemented by Act no. 502 of 23 May 2018 (the Data Protection Act) and related national legislation, as well as Directive 2002 and Council of the European Parliament / 58 / EC of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (the E-Privacy Directive) and national implementations thereof.

“Personal information” refers to any information about a natural person that can be directly or indirectly identified by an identifier such as name, address, location data or IP addresses.

“Processing” refers to any activity to which personal data is made, such as collection, organization, storage, deletion or disclosure.

"Data controller" refers to us, as we decide for what purposes and with what aids personal data may be processed.

Processing of personal information

We Process the following Personal Information when you register as a participant in the #AllAboutUscampaign and as a user of the #AllAboutUs app:

  • profile name;
  • name;
  • birthday;
  • sex;
  • Municipality/Country;
  • e-mailaddress;
  • Team name;
  • Transaction ID (if you do not use an employer paid promotional code);
  • User ID;
  • Profile photo;
  • at the start and end of the campaign: your answers to the digital health check;
  • if active in the campaign: how you collect your daily points through recording diet, exercise, and sleep and mental habits; as well as;
  • content that you post, upload and / or share in #AllAboutUs including images.

In relation to our Processing of your Personal Data, you must pay special attention to the following:

  • That your profile (profile name and profile picture) and all your social activities in #AllAboutUs will be visible to all other users of #AllAboutUs
  • The fact that all your social activities in #AllAboutUs will be visible means that all content that you post and / or share during the campaign, such as photos, written dialogue with other users and any questions you may ask the professional experts, could be seen by all other users in the campaign.
  • That your health data from digital health checks or daily reporting, will NOT be visible to anyone but yourself. Other users will only be able to see if you have reported for a given day, as well as if your reporting is above or below your personal point goal, illustrated purely as a percentage.

Automatic individual decisions, including profiling

Your Personal Information is not subject to automatic processing.

Purpose and legal basis for the processing of data

Below, you can see, for each processing purpose on what basis we process your Personal Data:

1. Personal information

Mandatory

  • Profile name
  • Name
  • Birthday
  • Sex
  • Municipality/Country
  • E-mail address
  • Team name

If you choose to enter this information:

  • Profile photo
  • your answers to the digital health check before and after the campaign
  • how you collect your daily points through recording diet, exercise, and sleep and mental habits; as well as;
  • content that you post and / or share in the #AllAboutUs app, including images.

Purpose

To make available and deliver #AllAboutUs, including being able to calculate your current state of health as well as improving your health during the campaign.

Legal basis

You have given your consent for the Processing of Personal Data to take place when you registered as a participant in #AllAboutUs

Payment

  • Transaction ID

Purpose

To be able to handle a refund upon cancellation of purchase.

Legal basis

The processing is necessary in order to pursue our legitimate interests in being able to repay an amount to you.

3. Competitions & Challenges

  • E-mail address
  • Profile name (to announce the winner of a given challenge)
  • To calculate winners we monitor the following data (a-c):
  • a) your answers to the digital health check;
  • b) your daily points through recording diet, exercise, and sleep and mental habits; as well as
  • c) content that you post, upload and / or share in #AllAboutUs including images.

Purpose

To be able to Process your Personal Information for the purpose of your participation in our competitions and the announcement of a winner of our competitions.

Legal basis

The processing is necessary to be able to pursue our legitimate interests in being able to run our business.

4. Notifications

  • Name;
  • User ID; as well as
  • E-mail Address.

Purpose

To be able to send you notifications about #AllAboutUs

Legal basis

The processing is necessary in order to pursue our legitimate interest in sending you service notifications in the form of notifications about:

  • Lack of reporting,
  • Messages on your wall,
  • Comments on your post or posts / responses from the experts or
  • Significant events in the #AllAboutUs universe such as the opening of health checks, or new initiatives in relation to the campaign.

5. Communication

  • Name; and
  • E-mail.

Purpose

To be able to send you notifications about new initiatives and campaigns from Infront

Legal basis

The processing is necessary in order to pursue our legitimate interest in sending you service notifications in the form of notifications about new initiatives.

General

You have an unconditional right to object to the Processing of Your Personal Data for the purposes of direct marketing. You also have the right to revoke your prior consent. The revocation of your consent has no consequences for the lawful processing of the Personal Data prior to the revocation.

If you object to the processing of your Personal Data, which is processed in the light of our legitimate interests, we will immediately stop processing your information for these purposes.

Recipients of personal information

We may share and pass on your Personal Information to relevant recipients such as:

  • External platform for managing user support;
  • External support team for shipping, where we can share your name, e-mail address and / or address;
  • External hosting center where all data is stored;
  • External people who are associated with the #AllAboutUs campaign in the form of the people who staff our expert panel in the app.
  • External payment service where we can share your transaction ID; and
  • Your workplace which allows you to participate in the campaign, where we can share your e-mail address, so the company can see how many of the employees have signed up using their campaign code.

The recipients below are established outside the EU / EEA, and we therefore use the security measures specified in the table below in connection with the data transfers. You are welcome to contact us for further information regarding the data transfers.

Cloudflare

Application security service in connection with firewall and encryption

Country & address

Address: 101 Townsend Street – San Francisco, CA 94107, USA

Safety precaution applied

Standard contractual clauses (standard contractual provisions for the transfer of personal data to registrars established in third countries)

Google LLC

App usage statistics

Country & address

Address: 1600 Amphitheatre Parkway – Mountain View, CA 94043, USA

Safety precaution applied

Standard contractual clauses (standard contractual provisions for the transfer of personal data to registrars established in third countries)

One Signal

Handling communication between platform and participants' smartphone

Country & address

Address: 2194 Esperanca Ave, Santa Clara, CA 95054, USA

Safety precaution applied

Standard contractual clauses (standard contractual provisions for the transfer of personal data to registrars established in third countries)

Mailchimp

Handling communication via newsletters

Country & address

Address: The Rocket Science Group, LLC 675 Ponce de Leon Ave NE Suite 5000, Atlanta, GA 30308 USA

Safety precaution applied

Standard contractual clauses (standard contractual provisions for the transfer of personal data to registrars established in third countries)

When you visit our website, you may be referred to other websites where the Processing of your Personal Information is not under our control. The privacy policies of the other websites govern the processing of your personal data on that website.

Answering legal inquiries and prevention of damage

We may access, retain and share your Personal Information in response to a legal inquiry (for example, search warrants, court orders, subpoenas or the like), or, if necessary to detect, prevent or prosecute fraud or other illegal activity, protect ourselves, you or other users, including as part of an investigation.

Storage of personal information

We retain your Personal Information for up to 12 months after we have completed the #AllAboutUs campaign. Your Personal Information will then be deleted in the form of profile information. Health information is stored anonymously so that it cannot be attributed to you. The information can then be passed on anonymously to:

  • For use in your workplace and ourselves in relation to marketing the results obtained; as well as
  • In special cases, the information can be donated to public bodies, educational institutions or research units in order to provide a better overview of the state of health or the development of health.

Children

#AllAboutUs is not aimed at persons under 17 years of age ("The Child"). We do not collect Personal Information about persons under this age with knowledge about it. Please contact allaboutus@7peaks.dk if you become aware that a child of whom you are a parent or guardian has given us access to Personal Information without your consent, in order to exercise your right to access, correct, delete, restrict the Processing of the Personal Data or object to the Processing.

Your Rights

You are entitled to request insight into and further information about the Processing of your Personal Data, or request that we correct, complete, delete or limit the Processing of your Personal Data. You are entitled to request a free copy of your Personal Information, which we process, twice (2) times a year. We are entitled to charge a reasonable fee based on our administrative costs if you require additional copies.

You are entitled to have the Processing of your Personal Data restricted if;

  • you have challenged the accuracy of the Personal Data,
  • the processing is illegal and you have requested to restrict processing,
  • we no longer need your Personal Information for the original purpose, but we require it to establish, exercise or defend rights, or
  • an assessment of which consideration weighs heaviest in connection with a request for deletion is ongoing.

Where our Processing is automatic and based on consent or fulfillment of an agreement, you have the right to data portability. Data portability means that you can receive the Personal Data that you have given us access to in a structured, commonly used and machine-readable format, and that you have the right to transfer the Personal Data to another data controller.

You can contact #AllAboutUs at any time via email at allaboutus@7peaks.dk to exercise your rights. You can also delete your data yourself by using delete functionality directly in the #AllAboutUs app or on www.walkoflife.dk.

Contact Information

If you wish to exercise your rights, or have questions regarding our Processing of your Personal Data, you may at any time contact #AllAboutUs by e-mail at allaboutus@7peaks.dk. In your e-mail, please indicate your profile name and the e-mail address used for the registration.

If you wish to complain about our processing of your Personal Data, you have the opportunity to submit your complaint to the competent local supervisory authority. You can read more about the local regulatory authorities at the following link: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Notice of change in this privacy policy

If we make changes to this Privacy Policy, we will notify you here via a notification in the #AllAboutUs app. If the changes require your consent, we will give you further, separate notice in the circumstances and request your consent in accordance with Applicable Personal Data Law.