Effective date: October 8, 2024
This Privacy Policy explains how Zing Coach Inc. (further will be referred as “we” or “us”) collects, stores, uses and protects your personal data in connection with your use of our website https://zing.coach/ (or its related pages such as, but not limited to, https://zing-gym.coach/) (the “Website”) and our application Zing Coach (the “App”, and together with the Website referred to as the “Services”). This policy also explains the rights you have in respect of your personal data and the practices we implement to protect your privacy.
We receive information from our trusted partners, such as security partners to protect against fraud, abuse, and other security threats to our Services or marketing vendors who provide us with information about potential customers of our business services.
All the information above is your personal data, and we call it this way throughout the privacy policy.
We process your personal data for the following purposes:
Aggregated or de-identified information. We aggregate or de-identify your personal data so that it can no longer be used to identify you and use this information to:
From time to time, we may share or publish aggregated information like general user statistics with third parties, including research institutions. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to re-identify the information unless required by law.
We will not sell or rent your personal data for monetary gain. We will not disclose your personal data except as otherwise described in this Privacy Policy. We will share your personal data with our service providers who support our services as described in this Privacy Policy. We will also not use information received through your use of the Apple HealthKit or Google Health Connect framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.
When we process your personal data for the purposes described above, we rely on the following legal bases:
3.1. Purpose of processing: To provide and maintain our Services
Type of personal data processed:
Legal basis:
Where necessary to perform a contract with you, such providing you with a personalized workout plan, or enabling communications with AI Assistant, or performing Body Scans for you. For processing of your health and wellbeing data, we rely on your consent.
3.2. Purpose of processing: To improve and develop our Services and features and conduct research
Type of personal data processed:
Legal basis: Where necessary for our legitimate interests, including in developing and improving, such as when we train our models or improve the App for your future experience. For use of your Body Scan photos, we reply on your consent.
3.3. Purpose of processing: To check if your age allows you to use the App
Type of personal data processed: General details
Legal basis: Where necessary to perform a contract with you, such providing you with our services only if you meet the age threshold.
3.4. Purpose of processing: To provide you with customer support and respond to your inquiries
Type of personal data processed:
Legal basis: Where necessary for our legitimate interests, in particular in supporting your customer journey.
3.5. Purpose of processing: To send you service emails, including security alerts or transaction confirmations
Type of personal data processed:
Legal basis: Where necessary to comply with an obligation arising out of a contract between us or out of applicable laws.
3.6. Purpose of processing: To send you marketing information about our Services, promotions, insights
Type of personal data processed:
Legal basis: Your consent where we ask for it to process your personal data for a specified purpose.
3.7. Purpose of processing: To integrate data between the Website and the App in connection with onboarding users
Type of personal data processed:
Legal basis: It’s our legitimate interest to ensure your smooth use of the Services.
3.8. Purpose of processing: To find audiences similar to our users
Type of personal data processed:
Legal basis: With your consent, we may share some of your non-health personal data with AppsFlyer or similar services to promote our Services.
3.9. Purpose of processing: To prevent misuse of our Services and to ensure the security of our IT systems, architecture, and networks
Type of personal data processed:
Legal basis: Where necessary to comply with a legal obligation. Where we are not under a specific legal obligation, where necessary for our legitimate interests and those of third parties, including in protecting our Services from abuse, fraud, or security risks, such as processing data from security partners to protect against fraud, abuse, and security threats in our Services.
3.10. Purpose of processing: To comply with legal obligations and protect the rights, privacy, safety, or property of our users, us, our affiliates, or any third party
Type of personal data processed:
Legal basis: Where necessary to comply with a legal obligation. Where we are not under a specific legal obligation, where necessary for our legitimate interests and those of third parties, including in protecting our Services from abuse, fraud, or security risks, such as processing data from security partners to protect against fraud, abuse, and security threats in our Services.
3.11. Purpose of processing: To anonymize your personal data
Type of personal data processed:
Legal basis: Where necessary for our legitimate interests, such as when we use it to:
4.1. Category of personal data: Identifiers, such as name, unique personal identifier, online identifier, IP address, email address, or account name
Categories of sources from which collected: Directly from you or automatically when you use the Services
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
4.2. Category of personal data: Characteristics of Protected Classifications, such as gender
Categories of sources from which collected: Directly from you
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
4.3. Category of personal data: Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories of tendencies
Categories of sources from which collected: Automatically when you use the Services
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
4.4. Category of personal data: Internet or other electronic network activity information, such as information regarding interaction with an app or advertisement
Categories of sources from which collected: Automatically when you use the Services
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
4.5. Category of personal data: Geolocation data, such as the state or country associated with your IP address
Categories of sources from which collected: Automatically when you use the Services
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
4.6. Category of personal data: Visual, information, such the photos you upload to the App
Categories of sources from which collected: Directly from you
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
4.7. Category of personal data: Inferences drawn from the information listed above to create a profile about a user reflecting their preferences, characteristics and other attributes
Categories of sources from which collected: Directly from you or automatically when you use the Services
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
4.8. Category of personal data: Information that may be sensitive personal data, such as gender, health and wellbeing information
Categories of sources from which collected: Directly from you or from such other sources that you connect to the Services
Business or Commercial Purpose for Collecting Personal Information:
Categories of Third Parties and Other Entities To Whom We May Disclose:
Sharing personal data for cross-context behavioral advertising. We may share the following categories personal information with third-party ad-tech providers and others throughout the online advertising ecosystem for purposes of cross-context behavioral advertising:
You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.
Other Rights: Notice to California Consumers. You have other rights under California’s “Shine the Light” law. California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. We do not disclose personal information to third parties for those third parties’ direct marketing purposes.
We retain your personal data for as long as your account is active or for as long as it is necessary for the purposes of its collection and processing (e.g., for resolving disputes, for safety and security reasons, or for complying with our legal obligations).
If you choose to deactivate your account, we retain your personal data for no longer than one month in case you decide to re-activate the Services. We also retain some of your information (General details, Details about in-app purchases, Communication information, your consent logs) as necessary to comply with our legal obligations, to resolve disputes and/or to enforce our agreements.
We may also anonymize your personal data (so that it can no longer be associated with you) for scientific research or statistical purposes, as well as for the purpose of Services improvement and development. In this case, we may use this information indefinitely without further notice to you.
We want to make sure that you are fully aware of all your data protection rights and the ways you can exercise them. These rights may differ across countries.
If you are EU, EEA or UK resident, you have the right to:
Note that these rights may be limited: for example, if you ask us to delete information that we are required to retain by law or where we have compelling legitimate interests to keep.
If you are a resident of countries other than EU, EEA or UK:
Depending on location, individuals may have certain statutory right in relation to their personal data. For example, you may have the right to:
How to exercise the rights:
You can exercise some of the rights above through the App settings. If you are unable to exercise your rights through the App, please submit your request through support@zing.coach.
If you make a request, typically we would perform it within one month. If we need any more time to help you exercise any of your rights, we will let you know.
If your request is vague or unclear, we may engage into a conversation with you to understand your request better. We may also refuse to act on manifestly unfounded and excessive requests.
We can ask you to prove your identity while exercising your data protection rights. This is made to ensure that you are indeed entitled to receive certain information and that no rights of third parties are violated by your request. If we can’t verify your request, we will not act on your request.
You may submit a request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may be required to independently verify your identity.
We take the protection of your personal data very seriously and we take reasonable and appropriate measures to protect them from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.
Among others, we utilize the following information security measures to protect your personal data:
Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the Services, or that your information won’t be intercepted while being transmitted to us. In case your personal data got compromised due to a security breach, we will act promptly to identify the cause and take all reasonable steps to remedy the breach. We will inform you of the incident, if necessary, in connection with the applicable legislation.
If you want to report a security incident related to our Services, please contact us at support@zing.coach.
Our Services are not directed at, or intended for, children under 18 years old.
If you are aware of anyone under 18 using the Services, please contact us at support@zing.coach and we will take the required steps to delete such information and/or delete the account.
In some situations, we engage other companies to process your personal data on our behalf. We refer to these companies or service providers as “processors.”
Processors are companies that help us run the Services, support our communication with you, or perform other App-related activities. They process certain personal data on our behalf to accomplish the goals related to the App functions and deliver the Services and associated activities. We remain responsible for any acts or omissions of our processors, and we enter into data processing contracts with them to the extent required by applicable law.
Here are some of the main processors we rely on:
Amazon Web Services, Inc. (USA)
Auth0, Inc. (USA)
Hetzner Online GmbH (Germany)
Firebase (USA)
SurveyMonkey, Inc. (USA)
TypeForm (Spain)
SendGrid (USA)
Braze, Inc. (USA)
OpenAI LLC (USA)
Amplitude, Inc. (USA)
Firebase (USA)
EPPO (USA)
Meta Events Manager (USA)
AppsFlyer, Inc. (USA)
AppsFlyer, Inc. (USA)
Zendesk, Inc. (USA)
Apple, Inc. (USA)
Adyen N. V. (the Netherlands)
Stripe, Inc. (USA)
Verify, Inc. (USA)
RevenueCat, Inc. (USA)
Google (USA)
Palta People Ltd. (Cyprus) – technical maintenance and customer support.
Palta UK Ltd. (UK) – technical maintenance and customer support.
Palta Poland sp. z o. o. (Poland) - technical maintenance and customer support
Palta Software Ltd (Cyprus) – data analytics, subscription management, AI models training.
Transfers of personal data outside of the European Union, the European Economic Area, and the United Kingdom. Where required under the EEA GDPR, in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.
Where required under the UK GDPR, in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on the UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.
When you use our Services, we and our service providers, vendors, and partners, including third parties, may use cookies (a small text file placed on your computer or mobile device to identify your computer and web browser) and other similar technologies to collect or receive certain information about you and/or your use of our Services. However, it’s not only cookies that can be used in this way. Functions performed by a cookie can be achieved by other means, too. This Section, therefore, also applies to any similar technology that stores or accesses information on your device. This could include, for example, HTML5 local storage, local shared objects, beacons, pixels, and plug-ins. We also use third-party analytics tools (such as, but not limited to, AppsFlyer, Meta Events Manager, Firebase) to help us measure traffic and usage trends of our Services, as well as for other analytics purposes. Such analytics tools collect information via third-party SDKs incorporated into the Services, which includes information about features of the App you visit or use, your actions in the App, and information about your subscription. Such information may be used to provide content, advertising, or functionality. Third parties may also use such information for their own purposes. For the avoidance of doubt, we do not use health and wellbeing data for advertising purposes.
Cookies. Generally, there are many different ways to classify cookies. Most common ways are classification by duration, by provenance and by purpose.
Software Development Kits (SDKs). SDKs are third-party software development kits that may be installed in our mobile application. SDKs help us understand how you interact with our App and collect certain information about the device and network you use to access the application. Our App is never used to present you with third-party advertising. You can browse with full confidence in the protection of your privacy. Access is requested with the purpose of enabling the use of our services and improving their functioning. Certain SDKs, where legally required, are subject to a prior consent request and the possibility of withdrawing this consent. Zing Coach services may still be used even in the event of refusal or withdrawal of consent.
You can deactivate this data processing at any time via https://www.appsflyer.com/optout. In order to do so, you must have the Identifier for Advertisers (IDFA) of your mobile device. You can also withdraw your consent for the collection of data for targeted advertising or sharing their data with third-party advertisers through your device’s settings.
Advertising ID. You can tailor your device settings to control your advertising ID:
Interest-based Advertising. We may partner with ad networks and other ad-serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your use of the App over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.
Your Choices. Most browsers and devices are configured to accept cookies and similar tracking technologies automatically. You may be able to set your browser and device options so as to limit such technologies. You can visit the Digital Advertising Alliance (“DAA”) Webchoices tool at www.aboutads.info to learn more about this interest-based advertising and how to opt out of this kind of advertising by companies participating in the DAA self-regulatory program, and http://www.aboutads.info/appchoices for information on the DAA’s mobile app opt-out program. You can also opt out of receiving interest-based ads from members of the Network Advertising Initiative (“NAI”) by visiting the NAI consumer opt-out page at http://optout.networkadvertising.org/?c=1#!/. Opting out of receiving interest-based ads does not mean that you will no longer receive ads from us, but rather that the ads will not be tailored to your perceived interests. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
For users in the European Economic Area, United Kingdom, and United States. You can manage the collection and processing of Personal Data via cookies, SDKs, and other tracking technologies by contacting us at support@zing.coach.
You may find that some parts of the App may not function properly if you have refused cookies or similar tracking technologies, and you should be aware that disabling cookies or similar tracking technologies may prevent you from accessing some of our content. Your choices are typically device and browser-specific.
If you are using our Services, you may receive electronic communications from us (e.g., by posting in-app notices, via push notifications or emails). We send some of these communications to you, such as those related to your subscriptions, technical and security notices, and updates to the Privacy Policy and Terms of Use, where necessary to perform our contract with you to provide the App or otherwise based on our legitimate interest in contacting you.
If required by law, we will ask for your consent to send you promotional and marketing emails, in-app communications, and push notifications about new products, features, or offers related to our Services.
Marketing & Promotional Emails. If you wish to stop receiving our promotional and marketing emails, you can do so by following the “Unsubscribe” links in any marketing email sent to you.
Push Notifications. If you wish to stop receiving push notifications, you can do so through your mobile device settings by tapping “Settings” -> “Notifications” -> Choose Zing Coach -> press the toggle to allow or forbid push notifications from the App.
The date this privacy policy was last reviewed is indicated at the top of the page. We may modify or update this privacy policy from time to time. Some changes do not require your consent: for example, when we add a new purpose of processing that is compatible with the existing purposes, or the new processing activity that falls under the users’ reasonable expectation. However, if the changes made may pose risk to your rights and freedoms (for example, by including a new purpose of the processing that is not compatible with the existing purposes of processing, a new legal basis, or a new category of personal data to be collected or a new data subject, all of which are not reasonably expected by the users), we will ask for your consent to those changes separately from this privacy policy. If you did not receive a request for your consent to the changes or refused to give consent, those changes will not apply to you. That fact can negatively affect some of our Services provided to you if those Services inevitably include consent to the changes.
Link to the privacy policy, May 30, 2024
Link to the privacy policy, March 15, 2024
Link to the privacy policy, March 1, 2024
Link to the privacy policy, Nov 6, 2023
Link to the privacy policy, June 12, 2023
Zing Coach, Inc.
Email: support@zing.coach
Our DPO: privacy@palta.com (please, indicate in the email subject that you are a Zing user).
EU representative:
DPOEU LTD
Email: info@dpoeu.eu
UK representative:
Palta UK Ltd
Email: privacy@palta.com (please indicate in the email subject that you are a Zing user).