Privacy Policy

At POLSE, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your data when you use our mobile application, website, and services.

Effective Date: 23 August 2025

1. Introduction & Scope

This Privacy Policy applies to all information collected by POLSE ("we," "our," or "us") through:

  • Our mobile application (iOS)
  • Our website at polse.co.uk
  • Email communications
  • Customer service interactions
  • Product purchases and delivery

Data Controller: POLSE is the data controller for all personal information collected through our services.

Contact Information: For any privacy-related questions or requests, please contact us at info@polse.co.uk

Data Collection & Usage

Personal Information We Collect

Account Information

  • Contact Details: Name, email address, phone number
  • Account Credentials: Username, encrypted password
  • Profile Information: Profile picture, fitness goals, preferences
  • Demographic Data: Age, location (general), fitness level

Purchase & Billing Information

  • Billing Details: Name, billing address, payment method details
  • Shipping Information: Delivery address, contact phone number
  • Transaction History: Purchase details, order history, refund records
  • Payment Processing: We do not store full credit card details - these are processed securely by our payment partners

App Usage Data

  • Activity Data: Workout sessions, progress tracking, app usage patterns
  • Device Information: Device type, operating system, app version
  • Performance Data: Crash reports, error logs, feature usage

Automatically Collected Information

Technical Data

  • Device Information: IP address, device ID, browser type, operating system
  • Usage Analytics: Pages visited, time spent, click patterns, feature usage
  • Location Data: General location based on IP address (not precise GPS)
  • Cookies & Tracking: Session cookies, preference cookies, analytics cookies

Communication Data

  • Customer Service: Support tickets, chat logs, email correspondence
  • Marketing Communications: Email open rates, click-through rates
  • Feedback & Reviews: Product reviews, app ratings, survey responses

Third-Party Integrations

  • Apple App Store: Purchase data, subscription status, device information
  • Analytics Services: App performance data, user behavior patterns
  • Payment Processors: Transaction verification, fraud prevention data

How We Collect Your Data

Direct Collection

  • Account Registration: When you create an account or sign up for our services
  • App Usage: Information you provide while using our app features
  • Purchases: Data collected during checkout and payment processing
  • Communications: Information you provide when contacting customer service

Automatic Collection

  • Cookies & Tracking: Data collected through cookies and similar technologies
  • Analytics: Usage data collected through analytics tools
  • Device Data: Technical information from your device and app

Third-Party Sources

  • Apple Services: Subscription and purchase data from the App Store
  • Payment Partners: Transaction verification and fraud prevention data
  • Social Media: Public information if you connect social media accounts

How We Use Your Information

Service Provision & Operations

Core Services

  • Account Management: Creating and maintaining your account, authentication, profile management
  • Content Delivery: Providing access to fitness videos, workout plans, and premium content
  • Subscription Management: Processing subscriptions, renewals, and billing
  • Progress Tracking: Storing and displaying your workout history and fitness progress

E-commerce Operations

  • Order Processing: Managing product orders, inventory, and fulfillment
  • Payment Processing: Processing payments, handling refunds, managing billing
  • Shipping & Delivery: Coordinating product delivery and tracking
  • Customer Service: Providing support, handling inquiries, resolving issues

Product Improvement

  • Analytics: Understanding user behavior to improve our app and services
  • Performance Monitoring: Identifying and fixing technical issues
  • Feature Development: Developing new features based on usage patterns

Communications & Marketing

Essential Communications

  • Service Updates: Important announcements, policy changes, security alerts
  • Transaction Notifications: Purchase confirmations, shipping updates, billing notices
  • Account Security: Login alerts, password resets, security notifications
  • Customer Support: Responses to inquiries, troubleshooting assistance

Marketing Communications (With Consent)

  • Promotional Emails: New product announcements, special offers, fitness tips
  • Personalized Recommendations: Suggested workouts, products based on your interests
  • Educational Content: Fitness guides, wellness tips, exercise tutorials

Opt-Out Options

  • You can unsubscribe from marketing emails at any time
  • Essential service communications cannot be opted out of while using our services
  • Marketing preferences can be managed in your account settings

Legal & Compliance Purposes

Legal Obligations

  • Regulatory Compliance: Meeting legal requirements in jurisdictions where we operate
  • Tax Obligations: Processing VAT and other applicable taxes
  • Consumer Protection: Complying with consumer rights and protection laws
  • Data Protection: Meeting requirements under GDPR, CCPA, and other privacy laws

Security & Fraud Prevention

  • Account Security: Protecting your account from unauthorized access
  • Fraud Detection: Identifying and preventing fraudulent transactions
  • System Security: Protecting our systems and infrastructure
  • Risk Assessment: Evaluating and mitigating security risks

Business Operations

  • Business Analytics: Understanding business performance and trends
  • Quality Assurance: Monitoring service quality and customer satisfaction
  • Legal Disputes: Defending against legal claims or proceedings

Data Sharing & Third Parties

Service Providers & Partners

Essential Service Providers

  • Payment Processors: Stripe, PayPal, Apple Pay for secure payment processing
  • Cloud Services: Secure data storage and app infrastructure hosting
  • Email Services: Email delivery and marketing automation platforms
  • Analytics Providers: App analytics and performance monitoring services

E-commerce Partners

  • Shipping Partners: Logistics companies for product delivery and tracking
  • Suppliers: Product manufacturers and drop-shipping partners
  • Customer Service: Third-party support tools and platforms

Data Protection Measures

  • All third-party providers are bound by strict data protection agreements
  • We conduct due diligence on all partners' security practices
  • Data sharing is limited to what's necessary for service provision
  • We regularly review and audit third-party data practices

Legal & Regulatory Sharing

Legal Requirements

  • Law Enforcement: When required by law, court order, or legal process
  • Regulatory Authorities: Compliance with government agencies and regulators
  • Tax Authorities: Meeting tax reporting and compliance obligations
  • Consumer Protection: Cooperating with consumer protection investigations

Business Transactions

  • Mergers & Acquisitions: In the event of business sale, merger, or acquisition
  • Asset Transfer: When transferring business assets or operations
  • Restructuring: During business reorganization or restructuring

Protection of Rights

  • Terms Enforcement: Enforcing our Terms of Service or policies
  • Legal Defense: Defending against legal claims or litigation
  • Safety & Security: Protecting user safety and system security

Our No-Sale Commitment

We Do Not Sell Your Data

  • POLSE does not sell, rent, or lease your personal information to third parties
  • We do not share your data with advertisers or marketing companies
  • Your information is not used for third-party advertising purposes
  • We maintain full control over how your data is used

Marketing & Advertising

  • Any marketing communications come directly from POLSE
  • We do not allow third-party advertising in our app
  • We do not participate in ad networks or data broker services
  • Your data remains private and is not monetized through advertising

Anonymized Data

  • We may use anonymized, aggregated data for business analytics
  • This data cannot be linked back to individual users
  • Anonymized data may be shared for industry research or benchmarking
  • All anonymization follows industry best practices

Data Protection & Security

Technical Security Measures

Data Encryption

  • In Transit: All data transmission uses SSL/TLS encryption
  • At Rest: Stored data is encrypted using industry-standard encryption
  • Payment Security: Payment data is processed using PCI DSS compliant systems
  • Password Protection: Passwords are hashed and salted using secure algorithms

Access Controls

  • Employee Access: Strict access controls and need-to-know basis
  • Multi-Factor Authentication: Required for all administrative access
  • Regular Audits: Periodic security audits and vulnerability assessments
  • Access Logging: All data access is logged and monitored

Infrastructure Security

  • Secure Hosting: Data hosted on secure, compliant cloud infrastructure
  • Network Security: Firewalls, intrusion detection, and monitoring systems
  • Backup Systems: Regular, encrypted backups with disaster recovery plans
  • Security Updates: Regular security patches and system updates

Data Retention & Deletion

Retention Periods

  • Account Data: Retained while your account is active and for 2 years after deletion
  • Purchase History: Retained for 7 years for tax and legal compliance
  • Support Communications: Retained for 3 years for quality assurance
  • Marketing Data: Retained until you opt out or for 2 years after last interaction

Automated Deletion

  • Inactive accounts are automatically reviewed after 3 years
  • Marketing data is automatically purged based on retention schedules
  • Temporary data and logs are automatically deleted after specified periods
  • We regularly review and update retention policies

Manual Deletion

  • You can request immediate deletion of your account and data
  • Some data may be retained for legal compliance even after deletion requests
  • Anonymized data may be retained for analytics purposes
  • Deletion requests are processed within 30 days

Data Storage & International Transfers

Data Storage Locations

  • Primary Storage: Data is primarily stored in secure data centers within the UK/EU
  • Backup Storage: Encrypted backups may be stored in multiple geographic locations
  • Cloud Services: We use reputable cloud providers with strong data protection measures

International Transfers

  • Transfer Safeguards: All international transfers use appropriate safeguards
  • Adequacy Decisions: Transfers to countries with adequate data protection
  • Standard Contractual Clauses: Used for transfers to other jurisdictions
  • Third-Party Processors: International processors must meet our data protection standards

Your Rights Regarding Location

  • You have the right to know where your data is stored
  • You can request information about international transfers
  • You can object to transfers in certain circumstances
  • We will inform you of any significant changes to data locations

Your Privacy Rights

Access & Information Rights

Right to Access

  • Data Overview: Request a copy of all personal data we hold about you
  • Data Categories: Information about what types of data we collect
  • Processing Purposes: Details about why and how we use your data
  • Third-Party Sharing: Information about who we share your data with

Right to Information

  • Collection Notice: Clear information when we collect your data
  • Processing Details: Transparent communication about data use
  • Contact Information: How to reach us with privacy questions
  • Legal Basis: The legal justification for processing your data

How to Exercise These Rights

  • Submit requests via email to info@polse.co.uk
  • Include verification information to confirm your identity
  • We will respond within 30 days of receiving your request
  • Access requests are provided free of charge

Control & Correction Rights

Right to Rectification

  • Data Correction: Request correction of inaccurate or incomplete data
  • Profile Updates: Update your account information at any time
  • Contact Details: Ensure your contact information is current
  • Verification: We may verify accuracy before making corrections

Right to Erasure ("Right to be Forgotten")

  • Account Deletion: Request complete deletion of your account and data
  • Selective Deletion: Request deletion of specific data categories
  • Legal Limitations: Some data may need to be retained for legal compliance
  • Processing Time: Deletion requests are completed within 30 days

Right to Restrict Processing

  • Processing Suspension: Request that we stop processing your data
  • Dispute Resolution: Restrict processing while disputes are resolved
  • Objection Period: Temporary restriction while we consider objections
  • Essential Services: Some processing may be required for service provision

Portability & Objection Rights

Right to Data Portability

  • Data Export: Receive your data in a structured, machine-readable format
  • Transfer Assistance: Help with transferring data to other services
  • Scope: Applies to data you provided and data processed based on consent
  • Format: Common formats like JSON or CSV for easy use

Right to Object

  • Marketing: Object to processing for direct marketing purposes
  • Legitimate Interests: Object to processing based on legitimate interests
  • Automated Decision-Making: Object to purely automated decision-making
  • Response Time: We will stop objected processing immediately unless legally required

Consent Management

  • Withdrawal: Withdraw consent at any time for consent-based processing
  • Granular Control: Control different types of processing separately
  • Easy Withdrawal: Withdrawal should be as easy as giving consent
  • No Penalties: No negative consequences for withdrawing consent

Complaint & Remedy Rights

Right to Complain

  • Direct Contact: Contact us first at info@polse.co.uk for fastest resolution
  • Supervisory Authority: File complaints with your local data protection authority
  • UK ICO: Information Commissioner's Office for UK residents
  • EU Authorities: Relevant DPA in your EU member state

Supervisory Authority Contact

  • UK ICO: ico.org.uk or 0303 123 1113
  • Response Time: Authorities typically respond within 3 months
  • No Cost: Filing complaints with authorities is free
  • Legal Support: You may seek legal advice or representation

Effective Remedies

  • Judicial Remedies: Right to effective judicial remedy against decisions
  • Compensation: Right to compensation for damages in certain circumstances
  • Legal Action: Right to take legal action for privacy violations
  • Class Actions: Ability to join collective actions where available

Cookies & Tracking Technologies

Types of Cookies We Use

Essential Cookies

  • Authentication: Keep you logged in and maintain session security
  • Security: Protect against fraud and ensure system security
  • Functionality: Remember your preferences and settings
  • Shopping Cart: Maintain items in your cart during shopping

Analytics Cookies

  • Usage Analytics: Understand how you use our app and website
  • Performance Monitoring: Track app performance and identify issues
  • Feature Usage: Measure which features are most popular
  • Improvement Insights: Data to help improve user experience

Marketing Cookies (With Consent)

  • Email Tracking: Track email opens and click-through rates
  • Campaign Attribution: Understand which marketing campaigns are effective
  • Personalization: Deliver relevant content and recommendations
  • Retargeting: Show relevant ads on other platforms (if applicable)

Other Tracking Technologies

Mobile App Tracking

  • App Analytics: Firebase Analytics for app usage insights
  • Crash Reporting: Automatic crash reports to improve app stability
  • Performance Monitoring: App performance and loading time tracking
  • Feature Flags: A/B testing and feature rollout management

Website Technologies

  • Pixel Tags: Small images that track email opens and website visits
  • Local Storage: Browser storage for preferences and temporary data
  • Session Storage: Temporary data storage during your browser session
  • Fingerprinting: We do not use device fingerprinting techniques

Third-Party Tracking

  • Social Media: No social media tracking pixels are used
  • Advertising Networks: We do not use third-party advertising trackers
  • Cross-Site Tracking: We do not track you across other websites
  • Data Brokers: We do not work with data broker companies

Managing Cookies & Preferences

Browser Cookie Controls

  • Browser Settings: Disable or delete cookies through your browser preferences
  • Cookie Categories: Most browsers allow you to block specific types of cookies
  • Third-Party Cookies: Disable third-party cookies while keeping essential ones
  • Regular Clearing: Set your browser to automatically clear cookies periodically

App Tracking Controls

  • iOS Settings: Use iOS "Ask App Not to Track" and "Limit Ad Tracking" features
  • App Permissions: Control app permissions in your device settings
  • Analytics Opt-Out: Contact us to opt out of analytics tracking
  • Location Services: Disable location services for our app if desired

Impact of Disabling Cookies

  • Essential Functions: Some features may not work without essential cookies
  • Personalization: Your preferences may not be remembered
  • Performance: We may not be able to optimize your experience
  • Support: It may be harder to troubleshoot issues

Special Categories & Children's Privacy

Health & Fitness Data

Types of Health Data

  • Fitness Tracking: Workout sessions, exercise duration, progress metrics
  • Goals & Preferences: Fitness goals, exercise preferences, difficulty levels
  • Physical Measurements: Any measurements you choose to input (optional)
  • Health Conditions: We do not collect sensitive health condition data

Special Protections

  • Explicit Consent: Clear consent required for processing health-related data
  • Limited Use: Health data used only for fitness tracking and app functionality
  • No Medical Advice: We do not provide medical advice or diagnosis
  • Secure Storage: Enhanced security measures for health-related information

Third-Party Health Apps

  • Integration: Optional integration with Apple Health and other fitness apps
  • User Control: You control what data is shared with third-party apps
  • Revocable: You can revoke health app permissions at any time
  • No Sharing: We do not share your health data with other companies

Children's Privacy Protection

Age Restrictions

  • Minimum Age: Our services are intended for users 18 years and older
  • Age Verification: We ask users to confirm they meet age requirements
  • Parental Supervision: Users under 18 must have parental supervision when using fitness equipment
  • Account Creation: We do not knowingly allow children under 18 to create accounts

COPPA Compliance

  • No Collection: We do not knowingly collect data from children under 13
  • Immediate Deletion: Any child data discovered is immediately deleted
  • Parental Rights: Parents can request deletion of any child's data
  • Verification: We implement measures to verify user age

If You Are Under 18

  • Parental Consent: Parental consent required for use of our services
  • Supervision: Adult supervision required when using fitness equipment
  • Limited Features: Some app features may be restricted
  • Contact Parents: We may contact parents for consent verification

Other Sensitive Information

Data We Do Not Collect

  • Medical Records: We do not collect medical history or health records
  • Financial Details: Full payment card details are not stored (processed by payment partners)
  • Biometric Data: We do not collect fingerprints, facial recognition, or other biometric data
  • Personal Documents: We do not collect ID documents, passports, or similar

Optional Information

  • Profile Pictures: Optional profile photos you choose to upload
  • Location: General location based on IP address, not precise GPS
  • Preferences: Dietary preferences, fitness interests (for personalization)
  • Social Connections: We do not access your contacts or social networks

Data Minimization

  • Necessary Only: We collect only data necessary for our services
  • Regular Review: We regularly review what data is needed
  • Purpose Limitation: Data is used only for stated purposes
  • Retention Limits: Data is not kept longer than necessary

Policy Updates & Contact Information

Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make significant changes, we will:

  • Update the "Last Updated" date at the top of this policy
  • Notify active users via email or app notification
  • Highlight material changes in our communications
  • Provide a reasonable notice period before changes take effect

Your Continued Use: Continued use of our services after policy updates constitutes acceptance of the changes.

Privacy Contact Information

Data Protection Officer: info@polse.co.uk

Privacy Inquiries: For all privacy-related questions, requests, or complaints

Response Time: We aim to respond to privacy requests within 30 days

Address: POLSE, United Kingdom

Website: https://www.polse.co.uk

Last Updated: 23 August 2025