Krew Privacy Notice

Last updated: March 21, 2022

We are Krew (“Krew”, “we”, “us”, and “ours”). This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights when you visit our website (Krew.live) and our mobile applications (collectively, the “Site”).

We collect and use your information slightly differently depending on whether you are a Customer or a Krew Pro.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

The Site is not intended for or directed to persons under the age of 18, and we will not knowingly collect information from persons under 18. To provide information to us through registration or in any other manner on the Site, you must be 18 years of age or older.

Index

We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you want to access a particular section of this Privacy Notice, please refer to the index below so you know what section to read.

1.    What does Krew do?

2.    What personal information does Krew collect and why?

3.    What does Krew do with the personal information it collects?

4.    What is the legal basis for processing personal information?

5.    How does Krew use cookies and similar technology?

6.    How does Krew keep my personal information secure?

7.    International data transfers

8.    Data retention

9.    Your data protection rights

10. Third party sites

11. Updates to the privacy policy

12. How to contact us

1. What does Krew Do?

Krew enables consumers to find, book and attend a wide range of fitness, recreational and wellness classes, services or products offered and operated by independent fitness professionals, fitness studios, gyms, trainers, physiotherapists, nutritionists, venues or other third parties through our platform.

Krew Live Ltd is located in the U.K. and is the parent and only company of the Krew group.

2. What personal information does Krew collect?

We collect or receive personal information in a few different ways via the Site. Often, you choose what information to provide, but sometimes we require certain information in order for you to use, and for us to provide you with, the Site and the experiences you reserve or access through the Site.

-Data you provide to Krew:

There are a variety of different ways you may provide personal information to us, such as:

·To create an account, you need to provide data including your name, username, email address, phone number and a password.

·To make a purchase or sign up for a subscription, you will need to provide payment and billing information. Krew uses credit card information, Apple Pay, or Google Pay in order to take payments. We process those payments through Stripe.

·To synchronise your contacts, we will need to process their phone number in order to offer you the possibility to follow your contacts who already have a Krew account or invite others who do not have it to create an account.

If you make a payment via our Site, your payment information will be provided directly to our payment provider, Stripe. We won't see your bank account or payment card details. Information you supply to Stripe is not within our control and is subject to their own privacy policy and terms and conditions.

·To complete your profile, you may provide other information, such as a photo, birthdate, and location (e.g. city or town).

·When you register for a class, you provide information in our booking form, including any comment you include for the Krew Pros.

·When you participate in a class:

·You can choose whether your video and audio will be on or off during the class.

·You may also opt-in to motion tracking, and if you would like to include your age, gender, height and weight to improve the automated feedback. Motion tracking data may be saved after a class finishes in order to provide you information about your progress over time.

·We may also use your username, generic location, photo and performance score to display leader boards for live and recorded classes.

·When you provide, post or upload it to our Site, such as when you respond to a survey or provide a class rating or review.

·If you are a Krew Pro, you can choose whether to record yourself when running classes, or create other media for your profile and to share with Customers.

You may not provide information to us about someone else unless you have obtained their prior consent to Krew receiving and using their information (such as for emergency contact or referral purposes), or you have an alternative lawful basis for doing so (for example, if you are a Krew Pro using our services to run classes based on agreements with your customers, or to send emails to your own mailing list which individuals have consented to).

-Data collected automatically through your use of the Site:

·Motion capture data during a class (this includes your underlying pose coordinates, and aggregate metrics, for example overall effort score, or form and technique accuracy).

·We log usage data when you visit or otherwise use our Site, such as when you view or click on content or ads (on or off our Site), perform a search, browse, schedule a reservation and install or update one of our mobile apps. The information we collect automatically may include information like internet protocol (“IP”) address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.

·We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked.

·We may also collect precise geolocation data pertaining to your mobile device, if you have consented to providing this to us through your device settings. We may use this information to provide, promote, and improve our services (for example, by showing you classes in your timezone) and for related reasons, such as fraud prevention and security purposes. Please note that if you do not consent to providing your geolocation data, certain features of the mobile application may not work.

The information we collect automatically enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. This enables us to improve the quality and relevance of our Site to our visitors.

-Cookies, web beacons and other similar technologies:

·We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across the Site, including when you use different devices. To learn more, including how to change your cookie settings, please see our Cookie Notice.

-Data from others.

From time to time, we may receive personal information about you from third party sources to assist us in providing, evaluating and improving our Site and offerings, but only where these third parties represented that you gave your consent or are otherwise legally permitted or required to disclose your personal information to us.

·Krew Pros may provide information to us in connection with a reservation you make or a class that you take, for example if there is an issue with your reservation.

·We may collect information from third-party services like Facebook if you use one of these services to log into or integrate with our Site. This information may include your name, email address, gender, city, and state or your friends or contacts on such sites. Logging in through these third-party services may allow you to interact with other users that maintain accounts through those services.

·If you choose to integrate your Krew account with your iOS HealthKit or similar application, we may receive certain sensitive personal information such as heart rate and calorie information (collectively, "Health Data") to help track your activity, personalize your experience and improve our service.

·If you choose to synchronise your contacts, we will need to process their phone number in order to offer you the possibility to follow your contacts who already have a Krew account or invite others who do not have it to create an account. We do not store this information and it will be deleted from our servers after the synchronisation is over.

Krew Pros may also provide information to us if they use to Krew to manage their own subscribers (for example, offering public or private classes). In this instance, the Krew Pro is responsible for your personal information and how they use Krew to manage it. If you have any questions, please contact the Krew Pro who provided your data to us.

3. What does Krew do with the Personal Information it collects?

Krew uses personal information it receives for several purposes:

·To operate and maintain our Site and the products and services offered through our Site. For example, we use personal information to fulfill your reservation and purchase requests, including processing payments, and to customize your experience on our Site, such as by tailoring the content or experiences we show you.

·To provide classes and other services via the Site, including sharing your username, booking form information, and any injury flag, with Krew Pros, and to connect you with partners during a class (including, optionally, audio and video).

·To help you track your progress, including your class attendance and, if you share this information, your performance metrics (for example, your leader board scores or form and technique motion capture-derived data).

·To contact you through email, phone, postal mail, notices posted on our websites or apps, and other ways.

·We will send you service messages about the availability of our Site, security, customer service, or other service-related issues.

·We also send messages about the Site, updates, reminders, and promotional messages in accordance with your communications preferences.

You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

·In connection with customer service inquiries and matters, such as to investigate, respond to and resolve complaints and service issues.

·For marketing purposes, such as to develop our marketing strategy and offer contests, sweepstakes, or other promotions and to fulfill any related awards or discounts;

·Research and Development: For research, analytical, recordkeeping, and reporting purposes; to develop and test new products, features and ideas (including improving our motion tracking and pose correction features, as further set out in section 5 (Who does Krew share my personal information with?)); to learn about our customer base and Site and to evolve and improve our Site, products and services.

·Security and investigations: We use your information to maintain the security of our Site, including to verify your identify, to investigate or prevent possible fraud or other violations of our Terms of Use or this Privacy Notice and/or in connection with possible attempts to harm our members, visitors, Krew Pros or other third parties.

·Other: For any other purpose identified at the point of collection or otherwise with your consent.

4. What is the legal basis for processing personal information (UK and EEA visitors only)?

If you are in the United Kingdom or the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (for example, our Terms of Use or, if you are a Krew Pro our Partner Terms of Use) , where the processing is in our legitimate interests (balanced against your interests, rights and freedoms), or where we have your consent to do so (for example, any direct marketing.

In exceptional circumstances, we or a Krew Pro may need to use your personal information if it is essential for someone's life (for example, responding to a serious health emergency during a class). It is unlikely Krew will need to rely on this reason, and we will try to ask for consent first.

If we you share Health Data with us (for example, via your iOS HealthKit or if you share an injury flag), we will ask for your specific consent. You can change your mind at any time.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

If we are storing your personal information only on behalf of a Krew Pro who uses our services, the Krew Pro is responsible for reasons they use your information and the legal basis for each reason. If you have any questions, please contact the Krew Pro who provided your data to us.

5. Who does Krew Share my personal information with?

We may disclose your personal information to the following categories of recipients or in the following circumstances:

·within Krew, to other Site visitors if you voluntarily share information about yourself in a public area on our Site, such as a public profile, class ratings or workout highlights. You should be aware that any content or information you choose to disclose in these areas can be read, collected and used by other users, the general public and other sites (including search engines).

·to Krew Pros (including any venue, studio, instructor or other provider) that makes available a class, activity or experience that you reserve or use through our Site, and their third-party providers, so that they can process the applicable reservation or activity and provide classes and services to you. You may also choose to share your profile, performance statistics, and video recordings or workout highlights with a Krew Pro as part of any personal coaching.

·to your employer (or similar entity), if you participate in any enterprise solutions or corporate programs.

·if a Krew Pro consents to sharing video recordings of themselves, we will also share these recordings with Krew Partners for to improve our motion tracking and pose correction features.

·third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site, payment card processors, customer support vendors, hosting vendors, scheduling providers and market research and marketing vendors), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.

·to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person.

·in connection with an actual or potential merger, sale, acquisition, investment, assignment, reorganization, joint venture, or transfer of all or part of Krew’ business, assets, affiliates, including if Krew should ever file for bankruptcy or a related proceeding, provided that we inform the relevant third party it must use your personal information only for the purposes disclosed in this Privacy Notice.

·to our group companies, to provide, develop, improve, and analyze the Site and our offerings.

·to any other person with your consent to the disclosure.

6. How does Krew keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We monitor our systems for possible vulnerabilities and attacks. However, we cannot guarantee 100% security of any information that you send us.

7. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Our Site servers are in the United Kingdom, and third-party service providers and partners operate around the world. This means that if you are in the UK, we may transfer your personal information outside the UK (or, if you are in the European Union ("EU") or European Economic Area ("EEA"), outside of the EU/EEA):

●to store it, and so we can provide our Site and services to you.

●where we are legally required to do so.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so. We will usually keep personal information:

●       for as long as necessary for the original reasons we collected it (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements), and

●       for up to six years after that to identify any issues and resolve any legal proceedings.

We may keep your personal information for longer:

●if you complain (so we keep our complaint records for long enough),

●if we know about pending or current legal proceedings, or reasonably believe there is a chance of legal proceedings,

●in some circumstances, if applicable law says we are required to.

If you opt-in to marketing from Krew (generally and/or from any specific Krew Pro) and later change your mind (or object to any other use of your personal information), we may keep a record of your opt-out or objection for longer so we can demonstrate we respect your preferences.

When we no longer need to use your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further use until deletion is possible.

Anonymised data

Anonymised data is no longer personal data, and you cannot be identified (or re-identified) from it. We may share anonymised motion capture information with third party organisations we work with ("Krew Partners"), so we can develop and improve motion tracking and pose recognition and correction features. We may keep anonymised information indefinitely.

9. Your data protection rights

You have the following data protection rights:

·If you wish to access, correct, update or request deletion of your personal information, you can do so by contacting us as explained below.

·In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us.

·You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or via our preference center. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us.

·If we use your personal information with your consent, then you can withdraw your consent at any time. This won't affect how we used your personal information prior to your withdrawal, nor will it affect how we use your personal information for reasons other than consent (for example, if we need to use it for manage our contract with you).

·You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

·If you are in the UK, the supervisory authority is the Information Commissioner's Office (ICO). You can visit their website at www.ico.org.uk.

·If you are in the EU, you can find your local data protection authority here.

These rights are not absolute – if a right doesn't apply, or only applies to some of your information or some of the things we do with it, we'll let you know as part of our reply to you.

You may contact us as explained in the “How to contact us” heading below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10. Third party Sites

Our Site may contain links to third-party websites or mobile apps, including social sharing features and other related tools.

Krew does not control these linked websites or apps and that this Privacy Notice does not apply to any information you give to the owner of these websites or apps. We encourage you to read the privacy policy of any third-party website or app that you visit before you provide them with any information.

11. Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

If we need to (under applicable data protection laws), we will obtain your consent to any material Privacy Notice changes.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

12. How to contact us

If you have any questions or concerns about our use of your personal information, please contact Krew UK Ltd (the data controller) by writing to team@krew.live.

Cookie Notice

Last updated: Sept 23 2021

This Cookie Notice explains how Krew and its subsidiaries (collectively “Krew”, “we”, “us”, and “ours”) use cookies and similar technologies to recognise you when you visit our websites and use our mobile applications (“Site”). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Krew) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Sites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites. Third parties serve cookies through our Sites for advertising, analytics and other purposes. This is described in more detail below.

First and third-party cookies served through our Sites and the purposes they perform are described below:

·Essential website cookies: These cookies are strictly necessary to provide you with services available through our Sites and to use some of its features, such as access to secure areas.

·Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Sites but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

·Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our Sites are being used or how effective are marketing campaigns are, or to help us customise our Sites for you.

·Advertising cookies: These cookies are used to make advertising messages more relevant to you and they perform functions like preventing the same ad from continuously reappearing and in some cases selecting and displaying advertisements to you across the internet that are based on your interests.

·Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Sites through third party social networking and other websites. These cookies may also be used for advertising purposes too.

What about other tracking technologies?

Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Sites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Sites to another, to deliver or communicate with cookies, to understand whether you have come to our Sites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Our mobile applications may include third-party application software development kits that provide mobile performance and analytics data, bug reporting features, and APIs to third parties that help provide the Site, for social media functionality, and for marketing and advertising.

Does Krew serve targeted advertising?

As described above, third parties may serve cookies on your computer or mobile device through the Sites to serve advertising. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.

We use the following types of cookies:

Strictly necessary cookies

These are cookies that are required for the operation of our Site and under our agreement(s) with you. They include, for example, cookies that enable you to log into secure areas of our Sites or (on other sites) or add subscriptions or trials to your cart to checkout.

Functionality cookies

These may be used to recognise you when you return to our Site. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, choice of language or region).

Analytical/performance cookies

These allow us to recognise and count the number of visitors and to see how visitors move around our Sites when they are using them. This helps us improve the way our Sites work, for example, by ensuring that users are easily finding what they are looking for.

Targeting/Advertising cookies

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

Social networking cookies

These cookies help us manage our social media, including enabling you to share content and enabling us to understand how you interact with us. We will use this information subject to your choices and preferences to improve our Site, Membership and Products. We may also share this information with third parties for this purpose.

We may also work with advertising networks that gather information about the content on our Site you visit and on information on other websites and services you visit. This may result in you seeing advertisements through our Site or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see 'How can I control cookies?' below or visit http://www.youronlinechoices.co.uk.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences for certain third-party cookies by clicking on the appropriate opt-out links provided above. You can also set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Site though your access to some functionality and areas of our website may be restricted, you may worsen your overall user experience, since it will no longer be personalized to you and it may also stop you from saving customized settings like login information. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. To revoke consent, users may disable cookies by modifying their browser settings. The links listed below provide more information about what cookies are installed, how to allow, block or remove installation from your computer. Depending on which browser you use, the user may follow these links:

·Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies

·Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647

·Safari: http://support.apple.com/kb/ph5042

·Explorer: http://windows.microsoft.com/es-es/windows7/how-to-manage-cookies-in-internet-explorer-9

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ , https://www.networkadvertising.org/, or http://www.youronlinechoices.com. Please bear in mind that there are many more networks listed on that site than those that we use on our Website.

We use Google cookies for analytics and marketing purposes. You can opt-out of Google tracking through Google Ads Settings, Ad Settings for mobile apps, or any other available means. Google also provides a Google Analytics opt-out plug-in for the web.

What is Do Not Track (DNT)?

DNT is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites by using browser settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a DNT technology standard. While some progress has been made, it has been slow. No standard has been adopted to this date. As such, Krew does not generally respond to "do not track" signals.

How often will this Cookie Notice be updated?

We may update this Cookie Notice from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore revisit this Cookie Notice regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Notice indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please contact us by writing to team@krew.live.