# Privacy Policy Last updated: November 27th, 2024 At BPM Health Co. (“Boostcamp,” “we,” “us,” and “our”), our mission is to help you along your fitness journey and we want you to know how we collect and use the data that you provide to us over the course of that journey. Boostcamp is the [boostcamp.app](https://boostcamp.app/) website (“ **Website**”) and Boostcamp mobile applications (“ **Mobile App**”) (which we collectively refer to in this Privacy Policy as the “ **Services**”). We encourage you to read this Privacy Policy as well as our [terms and conditions of use](https://www.boostcamp.app/terms-conditions) (referred to throughout as our “ **Terms**”). **BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY.** _Boostcamp and all associated Services and systems, including registration, are stored on servers in the United States. If you are located outside of the United States, please be aware that information we collect (including cookies and device data) will be processed and stored in the United States._ _Please read this Privacy Policy carefully, as your access to and use of the Services signifies that you have read and understand this Privacy Policy._ ## **Information About Your Personal Data** This Privacy Policy relates to data about you, your devices, and your interaction with our Services. “ **Personal Data**” is information that can be reasonably used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, device IDs, certain cookie and network identifiers, and “Fitness Data.” Boostcamp collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business; for advertising and marketing; and to provide you with innovative fitness services. ## **How We Collect and Use Personal Data** We may collect your Personal Data directly from you in a number of ways and for various business purposes, including: ### **1. When you register for an account or interact with our Services** We collect Personal Data when you use or interact with our Services, including when you register for a Boostcamp account, purchase a Boostcamp Pro subscription (including processing of payment), or otherwise use the Services. ### **2. When you input Fitness Data within our Services** “Fitness Data” includes data you provide related to your fitness goals, fitness level, body measurements and similar types of data. We collect this data in order to tailor features, advertising, and services to your interests and goals. ### **3. When you use or interact with a wearable or connected device** We also collect Personal Data, including Fitness Data, when you use a device that is connected to the Internet, such as heart rate monitors and activity trackers. ### **4. When you communicate with us or sign up for promotional materials** We collect Personal Data when you communicate with us or sign up to receive promotional materials via email and push notifications. ### **5. When you participate in special activities, offers, or programs** We may request Personal Data, including Fitness Data when you participate in Promotions, surveys, or research activities. ### **6. When you engage with our online communities or advertising** We may collect your Personal Data when you engage with our online communities, including when you click on advertisements or interact with our social media pages. ### **7. When you access third party products and services** We may allow you to register and pay for third-party products and services or otherwise interact with another website through our Services. ### **8. When you connect with us through social media** You may choose to enable, log into, or sign on to the Services through various social media services. ### **9. When we collect data from third parties** We may obtain certain data about you from third party sources to help us provide and improve the Services and for marketing and advertising. ### **10. When we leverage and/or collect cookies and other tracking technologies** We may collect certain Personal Data using cookies and other technologies such as web beacons, device IDs, and IP addresses. ### **11. When we aggregate or centralize data** We aggregate and centralize Personal Data and Fitness Data for purposes of analytics and innovation. ### **12. When we link you to friends across platforms** We use your Personal Data to enable sharing, including to enable you to find and link to friends on the Services. ### **13. Share content or achievements; or invite friends** With your permission, we access your contacts to enable you to share content with friends or invite friends to use the Services. ### **14. When we provide you geographically relevant Services, offers, or advertising** We may use general location data to provide you with Services, offers or advertising that are relevant to your general location. ### **15. When you ask us to customize our Services** We use photos, videos, or other data you provide to us to customize our Services. ### **16. When we comply with Legal Requirements** We may use Personal Data to comply with laws, regulations, court orders, or other legal obligations. ## **How We Disclose Personal Data** We may disclose your Personal Data for the purposes as described as: ### **1. Operation and Improvement of Services** Internally to relevant departments within Boostcamp, in order to provide and improve Services. ### **2. To Service Providers and Vendors** With business partners, marketing partners, and vendors to provide, improve, and personalize the Services. ### **3. To Social Network Providers** With social network providers when we use social network widgets, buttons, or plug-ins. ### **4. To other Boostcamp Registered Users** With other users of the Services in the context of specific features that are social in nature. ### **5. For Advertising and Marketing** With advertising and marketing partners for advertising and marketing purposes on Boostcamp’s behalf. ### **6. For Certain Analytics and Improvement** With certain companies for purposes of analytics and improvement of the Services. ### **7. For Legal Compliance and Public Safety** With law enforcement or other authorized third parties to comply with laws and regulations. ### **8. In the event of an actual or contemplated sale.** With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization of our business. ## **Legal Basis for Processing (Europe)** This section addresses the legal basis for processing the Personal Data of natural persons located in Europe. We may collect and process Personal Data of European data subjects on the following lawful basis: ### **1. Performance of a Contract** To perform our contractual obligations in connection with the Services. ### **2. Legal Obligations** To comply with laws, regulations, court orders, or other legal obligations. ### **3. Legitimate Interests** To operate our business and provide the Services. ## **Managing Your Preferences and Consent** Based on the laws applicable to you, you may manage your preferences and update your consent to certain processing as described in this section. ## **Transfers of Your Personal Data to Other Countries** The Personal Data Boostcamp processes, including registration, is housed on servers in the United States. By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the United States. ## **Data Retention** We will retain your Personal Data for as long as you maintain an account or as necessary to provide you the Services. ## **Security** We implement technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data. ## **Children** We do not knowingly collect Personal Data online from individuals under 18. If you become aware that a child has provided us with Personal Data without parental consent, please contact us. ## **How to Contact Us** If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us.