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My Row Privacy Notice

Effective: May 6, 2024

OVERVIEWPERSONAL DATA WE COLLECT

How We Use Your Personal Data

How We Obtain Your Personal Data

Who We Share Your Personal Data With

YOUR RIGHTS REGARDING PERSONAL DATA

Accessing, Modifying, Rectifying, and Correcting Collected Personal Data

Your California Privacy Rights

Your Nevada Privacy Rights

Your Virginia, Colorado, Connecticut and Utah Rights

YOUR CHOICES

Communications Opt-Out

Cookies, Web Tracking, and Advertising

PROTECTING PERSONAL DATARETENTION OF PERSONAL DATAOTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES

Collection of Personal Data from Children

Third-Party Websites and Services

Business Transfer

Do Not Track

MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICEAPPLICABILITY OF THIS PRIVACY NOTICEADDITIONAL INFORMATION AND ASSISTANCE
  1. OVERVIEW
  2. Welcome to myrowTM. This website (this “Site”) is provided by The Rowing Company, Inc. (“we”, “us,” or “our” ). This Privacy Notice (this “Notice”) governs your use of the Site, all myrow apps and all content provided by us (collectively, the “Services”), and explains our practices with respect to personal data we collect and process about you. By accessing and using the Services, you are agreeing to be bound by this Privacy Notice and our Terms of Service (the “Terms”). If you do not agree to any of the terms in this Privacy Notice or the Terms, please discontinue use of the Site.

    If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us.

    Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our Site or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

  3. PERSONAL DATA WE COLLECT
  4. We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, including personal information that you provide to us (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, which is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

    1. How We Use Your Personal Data

    2. We collect and process your personal data as part of our business operations, which include:

      1. Providing customer service, processing or fulfilling orders and transactions, and verifying customer information.
      2. Marketing our products and services to you, including sending you messages about the products and services we offer, which may include contests, rewards, events, and special offers for products and services.
      3. Communicating with you by email and other methods of communication (such as telephone) about products, services, order status, and information tailored to your requests or inquiries.
      4. Facilitating your engagement with the Services, including sending comments and reviews.
      5. Analyzing your Performance Data (as defined below) to track and reflect your progress over time, as well as recommend new classes based on inferences derived from your Performance Data.
      6. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
      7. Debugging to identify and repair errors that impair existing intended functionality.
      8. Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
      9. Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
      10. Undertaking internal research for technological development and improving the myrow platform experience.
      11. Undertaking activities to verify or maintain the quality or safety of the services or devices owned or controlled by us, and to improve, upgrade, or enhance the services or devices owned or controlled by us.
      12. Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
      13. Enforcing our Terms of Service and other usage policies.
      14. As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.
    3. How We Obtain Your Personal Data

    4. We collect your personal data from the following categories of sources:

      • Directly from you.When you provide it to us directly, whether online, by email, or by phone. For instance, you will be asked to provide certain information to set up a myrow profile, which may include standard contact information, as well as personal characteristics, such as height, weight and gender. You will also be asked to provide certain information to purchase a subscription plan and/or extended warranty.
      • Automatically or indirectly from you.For example, through logging and analytics tools (such as Google Analytics, Meta, and Google Ads), cookies, pixel tags, and as a result of your use of and access to the Services (e.g., by using the myrow tablet and myrow content), or through your interactions with us on social media websites (such as Facebook, Instagram, Twitter, Pinterest, and LinkedIn). In addition, we may track your interactions with the Service during a workout using the myrow tablet, such as, without limitation, time spent on a particular screen or sequence of actions taken during a workout. We will collect information relating to your performance and/or workout, including without limitation, class selection, length of workout, distance rowed, calories burned, etc. (“Performance Data”), but we do not collect health or medical information.
      • From our Service Providers.For example, e-commerce and payment processing providers, order processing and fulfillment services, commercial email providers, security consultants, and other Service Providers we engage.
      • From Third Parties.For example, ad networks, such as Google Ads, Pixel, and Meta, to serve advertisements across the Internet. These advertisers use cookies, pixel tags, and other tracking technologies to collect information about your online activity and provide online behavioral advertising.
    5. Who We Share Your Personal Data With

    6. We may share personal data with the following categories of third parties:

      • Our Service Providers, further described in the section in this Privacy Notice captioned “How We Obtain Your Personal Data
      • Our affiliated entities, partners, prospective partners, and service providers in order to provide us and/or our affiliates and partners with information about the use of the Services and levels of engagement with the Services, to allow us to enter into new business relationships, and to allow us to market products or services on their behalf.
      • Government agencies or regulations when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.
  5. YOUR RIGHTS REGARDING PERSONAL DATA
  6. You have certain rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you.

    1. Accessing, Modifying, Rectifying, and Correcting Collected Personal Data

    2. We strive to maintain the accuracy of any personal data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.

      Depending on the laws that apply to you, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, please contact us at the information provided at the end of this Privacy Notice. We reserve the right to deny access as permitted or required by applicable law.

    3. Your California Privacy Rights

    4. California's “Shine the Light” law permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge.

    5. Your Nevada Privacy Rights

    6. Nevada law permits our users who are Nevada consumers to request that their personal data not be sold (as defined under applicable Nevada law), even if their personal data is not currently being sold. Requests may be sent to the email address below, and are free of charge.

    7. Your Virginia, Colorado, Connecticut and Utah Rights

    8. If you are located in Virginia, Colorado, Connecticut, and Utah, you have certain rights regarding your Personal Data. The section describes how we collect, use, and share your Personal Data under the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“PDPOM”), and the Utah Consumer Privacy Act (“UCPA”) and your rights with respect to that Personal Data.

      As a Virginia, Colorado, Connecticut, or Utah resident, you have some or all of the rights listed below. However, these rights are not absolute, and we may decline your request as permitted by law. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

      • Right to Access and Portability. You have right to access your Personal Data and/or receive a copy of the Personal Data that we have collected about you.
      • Right to Correct. You have the right to correct inaccurate Personal Data that we have collected about you.
      • Right to Delete. You have the right to delete the Personal Data we have obtained about you or that you have provided to us with certain exceptions.
      • Right to Opt-out of Tracking for Targeted Advertising Purposes. You have the right to opt-out of certain tracking activities for targeted advertising purposes.
      • Right to Opt-out of Profiling. If we process your Personal Data for profiling purposes as defined by the VCDPA, CPA, PDPOM, and/or UCPA you can opt-out of such processing.
      • Right to Non-discrimination. You have the right to be free from discrimination as prohibited by the VCDPA, CPA, PDPOM, and/or UCPA
  7. YOUR CHOICES
  8. You have choices about certain information we collect about you, how we communicate with you, and how we process certain personal data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.

    1. Communications Opt-Out.You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Notice, or by informing our customer service representatives of your desire to opt out. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email's subject line and include your name and the email address you used to sign up for communications in the body of the email. Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions.
    2. Cookies, Web Tracking, and Advertising.You may opt out of certain tracking technologies through your device's or browser's cookie and/or advertising settings (including by blocking, deleting, or restricting cookies, or resetting your device's applicable advertising ID). Consult your device and/or browser documentation for more information about how to do this.
    3. Please note that blocking, deleting, or restricting cookies may negatively affect the performance or certain functionality of the Services, and opting out of online behavioral advertising will not prevent the delivery of ads, but rather may result in more repetitive and/or less relevant advertisements.

      To opt out of many online behavioral advertising mechanisms, including Facebook, Google, and others, you can use the Network Advertising Initiative's Consumer Opt-Out service and/or the Digital Advertising Alliance's Consumer Choice Tool.

      If you would like to opt out of Google Analytics, and certain Google advertising functionality, you may do so using Google's opt-out tool.

  9. PROTECTING PERSONAL DATA
  10. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. Those safeguards include: (i) the encryption of personal data where we deem appropriate; (ii) monitoring the Services for anomalous activity and if we believe that your personal data may have been compromised, then we will notify you as required by applicable law; (iii) taking steps to ensure personal data is backed up and remains available in the event of a security incident; and (iv) periodic testing, assessment, and evaluation of the effectiveness of our safeguards.

    However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

  11. RETENTION OF PERSONAL DATA
  12. We retain your personal data pursuant to our records retention policy, as well as to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners' rights, property, or safety, and the rights, property, and safety of our users and other third parties.

  13. OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES.
    1. Collection of Personal Data from Children.We do not knowingly collect information from children under the age of 18. By using the Services, you represent that you are 21 years of age or older. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our servers.
    2. Third-Party Websites and Services.As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business (including, but not limited to, e-commerce service providers and payment processors). When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third- party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies for such third-party services for information about how they collect, use, and process personal data.
    3. Business Transfer.We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
    4. Do Not Track.We use analytics systems and providers and participate in ad networks that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser's “do not track” signal or similar mechanisms.
    5. You may exercise your choice regarding the use of cookies and other tracking technologies by modifying the settings of your web browsers across the devices you use.

  14. MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE
  15. This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice on the Site. We encourage you to check this page each time you visit the Site. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement and acceptance of the amended Privacy Notice.

  16. APPLICABILITY OF THIS PRIVACY NOTICE
  17. This Privacy Notice is subject to any agreements and other disclosures, including the Terms of Service that govern your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services.

    This Privacy Notice does not apply to information from or about you collected by any third- party services, applications, or advertisements associated with, or websites linked from, the S ervices. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party's compliance therewith.

  18. ADDITIONAL INFORMATION AND ASSISTANCE
  19. If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please send us an email at info@myrow.com.