Hydrow, Inc. Privacy Policy

Last Updated: [October 7, 2020]

Hydrow, Inc. (“Hydrow” or “us” or “we” or “our”) provides a variety of fitness products, services, content and features through our website (www.hydrow.com) (the "Website"), the interface on tablets connected to Hydrow, Hydrow's Live Outdoor Reality Rower (LOR)™, and mobile device application (including Android and IOS applications) (the “App”), and through certain Hydrow-controlled social media pages (including Facebook, Instagram, Twitter and YouTube) (all such products, services, content and features collectively described herein as the “Services”).

This privacy policy (the “Privacy Policy”) has been complied to better serve those who are concerned with how our policies regarding the collection, use and disclosure of information, including information that can be used to identify you (directly or indirectly) (“Personally Identifiable Information” or “PII”) when you use our Services and the choices you have associated with that data is being used online, as described in U.S. privacy laws and regulations. If you do not accept this Privacy Policy, then please do not access or use the Services.

We will not use or share your PII with anyone except as described in this Privacy Policy. By using the Services, you agree to the collection and use of information in accordance with this policy. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website.

Information Collection

While you use the Services, contact us directly, or engage in certain activities such as registering for an account, we collect several different types of information for various purposes, including to provide and improve those Services as described below.

User Profile Data

When you use the Services, you may choose to create a “User Profile” and provide PII about yourself such as your username, first name, last name, phone number, address, email address, weight, height, gender, age, birthday, and/or image or avatar.

Once you create your User Profile, anytime you log-in to participate in a Hydrow workout, we will also collect additional information relating to your account, such as the total number of workouts you participated in, the dates you took the workouts, and fitness performance history i.e. leaderboard rank, achievement badges earned, speed, distance, and calories burned.

User Provided Information

We also collect information when you provide us with feedback, contact us with a question or comment, or provide information in public forums through the Services.

Payment Information

We do not collect, store, or maintain your financial information. When you make purchases through the Services, we process your payments through a third-party payment processor (e.g., Stripe). In these instances, the third-party application collects financial information from you to process a payment on behalf of Hydrow, including your name, email address, address, and other billing information in which case the use and storage of your financial information is governed by the third-party terms, conditions, and privacy policies.

Usage Data

We also collect information that your browser or the app sends whenever you access our Services through a rower, app, desktop, mobile device, or other method ("Usage Data"). You may also elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more. These messages may use Usage Data and may prompt messaging such as cart reminders. To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages.

For more information about text messages, see our Terms of Use: https://support.hydrow.com/hc/en-us/articles/360030733452-Hydrow-Terms-of-Use.

This Usage Data includes information such as your computer's Internet Protocol address (e.g. IP address), cookie identifier, MAC address, IMEI, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Services with a mobile device, this Usage Data includes information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information.

Cookies are files with a small amount of data which include a unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.

We use this information to understand traffic and the usage of the Services, enabling us to improve the Services, provide the best online experience possible, and improve our customer service.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Services.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Advertising Cookies. Advertising Cookies are used to serve you with advertisements designed to be relevant to you and your interests.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. Check the help menu in your browser’s or device’s help or support menu for further information. Remember that if you disable cookies, you may not be able to use some portions of the Services. Unless you have adjusted your browser settings so that it will refuse cookies, our system Services will place cookies when you log on to the Services.

Sweepstakes Registration Data

Periodically, Hydrow runs sweepstakes. We ask those who enter the sweepstakes to provide contact information i.e. phone number, email address, or other relevant information pertaining to the sweepstakes. If you participate in a sweepstakes, your information will be used to reach out to you about the sweepstakes, and, to the extent permitted by law, for other promotional, marketing and business purposes.

Data Provided via Third Parties.

We receive information about you from third parties. For example, to the extent that we offer access to the Services through a third party platform or log-in, we also collect your email address and other information associated with that third party, and any information you have made public in connection with that service or which the third party shares with partner services. Our treatment of the information you provided to them, which they provided to us, is subject to the terms of this Privacy Policy. See also the “THIRD PARTY WEBSITES AND LINKS” section below.

Third Party Analytics

We use third parties’ analytic and tracking tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content, and to help those parties serve more targeted advertising to you across the Internet or help us serve more targeted advertising to you. Those third party companies may use cookies, pixel tags or other technologies to collect and store Non-PII such as time of visit, pages visited, time spent on each page of the Service, device identifiers, type of operating system used and other website(s) you may have visited. They might combine data they collect from your interaction with Services with PII they collect from other sources. We do not have access to, nor control over, third parties' use of cookies or other tracking technologies.

Heart Rate Monitor Data

If you choose to connect a heart rate monitor to your rower, we will collect the heart rate data provided by your monitor. We use this information to display your heart rate to you during your workout and to improve the accuracy of the information we provide to you about your session rowing, in particular the number of calories burned.

Use of Data

It is in our legitimate interests to process your PII to provide effective Services and useful content to you. We may also in certain circumstances process your PII because it is necessary pursuant to a contract with you or where you have given your consent to such processing.

Hydrow uses the collected data for the following purposes:

To provide you with and to maintain our Services
To administer your User Profile.
To notify you about changes to our Services
To allow you to participate in interactive features of our Services when you choose to do so.
To provide customer support and communicate with you about your User Profile or transactions with us.
To gather analysis or valuable information so that we can improve our Services
To monitor the usage of our Services
To detect, prevent and address technical issues.
To personalize and improve the Services and user experiences, to increase the functionality and user friendliness of the Services, to deliver content or features that match User Profiles or interests.
To detect, investigate and prevent activities that violate our policies or be illegal.
To provide you with news, special offers, marketing messages, and general information about other goods, services and events which we offer that may be of interest to you, including, with your consent, marketing text messages. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Retention of Data

Hydrow will retain your PII only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your PII to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, establish legal defenses, conduct audits, pursue legitimate business purposes, and to continue to develop and improve our Services.

Hydrow will also retain Usage Data for internal analysis purposes. This data is used to strengthen the security of our Services, to improve the functionality of our Services, to satisfy legal obligations, and other uses. Information is not retained when otherwise prohibited by law or regulation.

Transfer of Data

Your information, including PII, will be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the information, including PII, to the United States. Your PII is also processed by staff operating in the United States who work for us or for one of our suppliers. Such staff are engaged in, among other things, proving the Services, the fulfilment of your order, the processing of your payment details and the provision of support services.

Disclosure of Data

Hydrow will not share your PII outside Hydrow except in the following limited circumstances, which you consent to:

When you allow us to share your PII with another company, such as directing us to share your PII with third-party platforms or log-ins.
When we contract or partner with third party companies and individuals to facilitate the Services ("Service Providers"), provide the services on our behalf, to perform complementary services and /or to assist us in analyzing how the Services are used. Such Service Providers include:

Cloud storage providers located in the United States, to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
IT Services Providers that provide us with SaaS services, including Shopify, who we use for eCommerce purchases, and Stripe, who we use for payment processing, etc.;
Provided you have consented, advertisers and advertising networks located in the United States that require the data to select and serve relevant adverts to you and others;
Analytics and search engine providers located in the United States that assist us in the improvement and optimization of the Website; and
Warranty and service providers that provide you with the extended warranty services that you elect to purchase.
We may share your personal information with third-party vendors, consultants and other service providers that perform services on our behalf, in order to carry out their work for us.

We may also share your PII and other information with third parties in the following circumstances: In connection with the sale of a business (including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings).
To comply with law enforcement and legal processes, such as a court order, or subpoena.
To prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity.
To protect and defend yours, ours or others’ rights, property, and safety.
To enforce Hydrow’s policies or contracts.
To prevent or investigate possible wrongdoing in connection with the Services.
To protect against legal liability.

In addition, we share anonymized and aggregated data sets with third parties.

Security of Data

The security of your data is important to us and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the Internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the PII we have collected from you.

Our Policy on "Do Not Track" Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform such websites and services that they do not want certain information about their website visits collected over time and across websites, platforms, or online services. Please note that we do not respond, support, or honor DNT signals or similar mechanisms transmitted by web browsers.

Third Party Websites and Links

Hydrow’s website contains links to other websites or online platforms operated by third parties and other websites may reference or link to the Services. These other domains and websites are not controlled by us, and Hydrow does not endorse or make any representations about Third-Party websites or social media platforms. We do not control such other websites or online platforms and are not responsible for their content, their privacy policies, or their use of your PII. We encourage you to read the privacy policies of each and every website, platform, and application with which you interact. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications.

Please keep in mind that data you post on public or semi-public venues, including data you share on third party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. When you provide data to a third-party online platform, the data you provide may be separately collected by that third-party. The data the third-party online platform collects is subject to the third-party online platform’s privacy practices. Privacy choices you make on the third-party online platform will not apply to our use of the data we collect directly through the Services.

Visiting other websites, platforms, and applications is at your own risk. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. We expressly disclaim any and

all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of PII by third parties.

Analytics

We use third-party Services Providers to monitor and analyze the use of our Services.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Advertising

We use third-party Services Providers to show advertisements to you to help support and maintain our Services.

Google AdSense DoubleClick Cookie

Google, as a third-party vendor, uses cookies to serve ads on our Services. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Services or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Behavioral Remarketing

Hydrow uses remarketing services to advertise on third party websites to you after you visited our Services. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Services.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

AdRoll

AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1nt=1nw=false. For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

Children Online Privacy Protection (COPPA) Act

Our Services are not directed to children under 13 years of age. In addition, you are not permitted to use our Services if you do not meet the minimum age requirements to our Services in your jurisdiction. We do not knowingly collect PII from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with PII, please contact us at support@hydrow.com. If we learn that we have collected PII of a child under 13 years of age, we will take steps to delete such PII from our files as soon as possible.

California Privacy Rights

This Privacy Policy describes how we share your PII for marketing purposes. It applies to all users of the Services, including California residents. California law additionally permits California residents to request and obtain from us once per year, free of charge, a list of third-parties to whom we have disclosed their PII (if any) for direct marketing purposes in the prior calendar year, as well as the type of PII disclosed to those parties. See How to Contact Us below.

If you are a California resident under the age of 18, you may request to have your posted content or information removed from the publicly-viewable portion of these Services by changing your privacy settings in your User Profile page or contacting us directly by emailing support@hydrow.com. In certain situations not all information can be removed from our systems or databases.

EU Privacy Rights

Individuals residing in the EU have the following rights:

You have the right to ask us to access the PII we hold about you and be provided with certain information about how we use your PII and who we share it with. You also have the right to ask us to correct your PII where it is inaccurate or incomplete.

In certain circumstances, you have the right to ask us to delete the PII we hold about you:

where you believe that it is no longer necessary for us to hold your PII;
where we are processing your PII on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
where you have provided your PII to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your PII; or
where you believe the PII we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your PII:

where you believe the PII we hold about you is inaccurate and while we verify accuracy;
where we want to erase your PII as the processing is unlawful but you want us to continue to store it;
where we no longer need your personal data for the purposes of our processing but you require us to retain the data for the establishment, exercise or defence of legal claims; or
where you have objected to us processing your PII based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your PII based on our legitimate interests and we will no longer process your PII unless we can demonstrate an overriding legitimate ground.

To exercise any of these rights above, please contact our Data Protection Officer at privacy@hydrow.com. In addition, you have the right to complain to the Information Commissioner’s Office or other applicable data protection supervisory authority.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals, where there are overriding public interest reasons or where we are required by law to retain your personal data.

Objection to Marketing

At any time you have the right to object to our processing of data about you in order to send you promotions and special offers, including where we build profiles for such purposes, and we will stop processing the data for that purpose.

Complaints

In the event that you wish to make a complaint about how we process your PII, please contact us in the first instance at eurep@bmdataservices.co.uk or BM Data Services Limited, 40 Oxford Road, High Wycombe, Buckinghamshire, HP11 2EE United Kingdom and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the Information Commissioner’s Office or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

Contacting Us

If you have any questions about our privacy policies, this Privacy Policy, or how to submit a complaint with the appropriate authority, please contact Hydrow at privacy@hydrow.com or by mail at the address below. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Hydrow, Inc.

14 Arrow Street, 4th Floor Cambridge, MA 02138

Changes to This Privacy Policy

We may update our Privacy Policy from time to time in which case we will update the “Updated Date” at the top of this Privacy Policy. We will use reasonable efforts to provide notice to you and obtain your consent as required by applicable law. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.