The Information We Collect About You
How We Use Your Information
How We Share Your Information
Third-Party Ad Networks/Social Networks
Security of My Personal Information
Access to My Personal Information
What Choices Do I Have Regarding Promotional Emails?
Changes to this Policy
Please read the following carefully to understand our views and practices regarding your information and how we will treat it.
For the purposes of UK data protection law, SoulCycle, Inc. and SoulCycle London Limited will be joint data controllers in respect of our UK users. SoulCycle London Limited's registered office is at 5 New Street Square, London EC4A 3TW. Both controllers can be contacted at email@example.com
A. The Information We Collect About You
We collect information about you directly from you (both online and in store) and from third parties, as well as automatically through your use of our Website, App, or Services.
Information We Collect Directly From You.
We collect information from you when you contact us, register with our Website or App, reserve classes, make a purchase, or otherwise interact with our Website or our App. The type of information that we collect varies based on your interaction with us and may include: your name, email address, password, and phone number, and, if you make a purchase from us, payment information, purchase history, and shipping address. We also may collect information about your workout preferences, such as your bike size and settings, and your shoe size preferences. If you provide this information directly to one of our studio attendants, we may associate this information with your account (e.g., if you sign up for a class while you are in the studio).
Information We Collect from Third Parties.
To create an account and participate in one of our classes, we need emergency contact information for our customers. When a customer creates an online account with us, we will collect the name and phone number of their emergency contact. Our customers also may provide us information about their friends, e.g., so that we can invite others to try our classes.
We may also collect any information that you publicly share via social media, through your social media engagement with our fanpages and feeds. This will relate to sites such as Facebook, Twitter and Instagram and will relate to personal information about you as detailed above, including images you post and share, your likes, your favourites, and your engagement with our content. We may associate this information with your SoulCycle account.
Information We Collect Automatically.
We automatically collect information about your use of our Website and App through cookies, web beacons, and other technologies, including technologies designed for mobile apps. We combine this information with other information we collect about you as well as use this information to identify you across your multiple devices. Please see the section "Cookies and Other Tracking Mechanisms" below for more information.
· Domain name.
· Your browser type and operating system.
· Web pages you view; links you click; your IP address.
· The length of time you visit our Site and or use our Services.
· The referring URL or the webpage that led you to our Site.
· Mobile device ID; device name and model; operating system type, name, and version.
· Language information.
· Activities within the App; and the length of time that you are logged into our App.
· Location information. With your permission, we will collect location information from your mobile device to help you locate the nearest SOUL location and to send you push notifications, such as promotional notices when you are near a studio. You may turn off this feature through the location settings on your mobile device.
· Calendar. With your permission, we may access your mobile device's calendar to help you keep track of your upcoming classes.
· Contact list. With your permission, we may access your contacts to allow you to identify your emergency contact and upload their contact information.
Automatically Collected In-Store Information. Our studios are monitored 24 hours a day by closed circuit television. We use this information predominantly for loss prevention and safety purposes. We may share this information as permitted by law to protect our rights and interests, the rights and interests of others, and as otherwise permitted by law.
Performance Metrics in Connected Studios.
If you participate in certain classes in identified SoulCycle studios where we have installed connected equipment such as bicycles and wearable devices, we may also collect information about your performance in particular SoulCycle classes, including but not limited to your distance, power/effort, cadence and speed.
B. How We Use Your Information
We use your information, including your personal information, for the following purposes, and as otherwise permitted by law:
· To provide our services to you, to communicate with you about your use of our services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
· To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Website and App.
· For marketing and promotional purposes. For example, as permitted by applicable law, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third party products and services. We also may use the information that we learn about you to assist us in advertising our services on third party websites and social networking sites.
· To send you push notifications (you may opt-out through the settings in your device).
· To better understand how users access and use our Website and App, both on an aggregated and individualized basis.
· To evaluate, improve, or modify our Website, App, and Services, including our services offered in our studios.
· For research and analytical purposes.
· To administer our Spread the Soul and other customer loyalty programs.
· To administer surveys and questionnaires.
· To comply with applicable legal obligations, including responding to a subpoena or court order.
· For other business related purposes, including, for example, in the context of merger, acquisition, sale/purchase of assets, or bankruptcy.
· To protect us and others.
· To provide you with information, if you request it, regarding your performance in connected SoulCycle classes.
Lawful bases – UK users
Processing this information is necessary in order for the performance of our contract with you; for the provision of goods and services which you have requested from us; and for our legitimate interests in ensuring that content from our site is presented in the most effective manner for you and for your computer and to promote our business.
C. How We Share Your Information
We may share your information, including personal information, as follows:
We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf including in the United States. For example, we share your information, both on an individual basis or in the aggregate, with third parties to assist us in advertising our products and services and to assist us in determining relevant advertising. These third parties may include entities that assist us and other companies with communicating with you and serving advertisements to you, including advertisements on third party websites, social media platforms, as well as through push notifications and email. Please see E. Third-Party Ad Networks/Social Networks for additional information about Website and App advertising. We do not, however, share your personal information with third parties for their own direct marketing purposes.
We may also share information in the following circumstances:
We may disclose the information we collect from you with our partners, including for their own direct marketing purposes. For example, we disclose information to our partners in connection with offering co-branded services, selling or distributing products or services, or engaging in joint marketing activities or promotions.
If we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
In Response to Legal Process.
We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others.
We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or of this Policy, or as evidence in litigation in which SOUL is involved.
With Your Consent or at Your Request.
We may disclose the information we collect from you with your consent or to facilitate your requests.
Aggregate and De-Identified Information.
We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Cookies are alphanumeric identifiers that we transfer to your computer's hard drive or mobile device through your web browser for record-keeping purposes.
A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser or exit the App. Others are used to remember you when you return to the Website and will last for longer.
We use the following types of cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, or use a shopping cart.
• Functionality cookies. These are used to recognise you when you return to our Website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting / Advertising cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Website or App more relevant to your interests and to show you SoulCycle advertisements on other websites and apps and on social media platforms that you visit. We may also share this information with third parties for this purpose.
We use third-parties to serve advertisements targeted to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to the third-party (such as through Facebook Custom Audiences or Google Customer Match) or incorporating a pixel from the third-party on our Services, and the third-party matching common factors between our data and their data. We may also work with partners to deliver Matched Ads based on data about you and others in those partners’ own databases or match the partner’s data against our own customer lists. To opt-out of us using your data for Matched Ads, please contact us as at firstname.lastname@example.org and specify that you wish to opt-out of Matched Ads. We will request that the applicable third-parties not serve you Matched Ads based on information we provide to it. You may also contact the applicable third-party to opt-out. We are not responsible for such third-party’s failure to comply with our or your opt-out instructions.
We also use the following cookies and equivalent technologies in connection with our use of social media platforms:
Twitter Button: This enables visitors to engage with us via Twitter and allows us to show visitors relevant ads and personalized content on Twitter. To learn more about Twitter’s practices and to opt out, please visit https://twitter.com/privacy?lang=en and select “Do Not Track” in certain browser settings and you can find more information here: https://help.twitter.com/en/rules-and-policies/twitter-cookies#
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse certain areas of the Website, but some features may not function
Clear GIFs, pixel tags and other technologies.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Website and our App to, among other things, track the activities of our Website visitors and App users, help us manage content, and compile statistics about Website and App usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. We also use third party SDKs to, among other things, track our conversions, associate with your account how you use our Website and our App when you are not logged in to the account, and bring you advertising both on and off our Website and our App.
Cross Device Use.
We may use the information that we collect about you (whether directly from you from our Site, App, or in-store purchase activities, through your device(s), or from a third party) to help us and our third-party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We, and our third party service providers, also may use the cross-device tracking and other information we learn about you to serve targeted advertising on your devices, to send you push notifications, and to send you emails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Third Party Ad Network section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt-out each browser or device that you use.
Third Party Analytics.
There is no industry do-not-track standard; SOUL has processes in place that are designed to recognize web browser "do-not-track" signals. The Help portion of the toolbar on most browsers will tell you how to use your web browser's do-not-track feature. Please be advised that we cannot guarantee that our processes will capture all such do-not-track signals. You also may disable certain tracking as discussed in this section (e.g., by disabling cookies); you may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
E. Third-Party Ad Networks/Social Networks
Users in the United States may opt out of many third-party ad networks, including those we work with on our Website and App. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Users in Europe can visit https://www.youronlinechoices.eu/ .
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.
F. Third-Party Links
Our Website and App may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
G. Security of My Personal Information
We have implemented appropriate technical and organisational measures to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite these measures, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
How long we keep your information
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and after that to identify any issues and resolve any legal proceedings and generally for as long as we are legally entitled to do so . We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Your rights – UK users
· You have the right under certain circumstances:
• to be provided with a copy of your personal data held by us;
• to request the rectification or erasure of your personal data held by us;
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. The Information Commissioner - https://www.ico.org.uk - is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
H. Access to My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or App for a period of time.
I. What Choices Do I Have Regarding Promotional Emails?
We may send periodic promotional emails to you. You may opt-out of our promotional communications by following the opt-out instructions contained in the email or by emailing us at email@example.com. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us, as these will be necessary for the performance of our contract with you and the provision of our product and services.
J. Your California Privacy Rights
California’s “Shine the Light” law permits customers who reside in California to request, once per year, disclosure regarding how we share certain of their information with third parties and affiliates for those third parties’ and affiliates’ own direct marketing purposes.
We may share personal information as defined by “Shine the Light” with third parties and/or our affiliates for such third parties’ and affiliates’ own direct marketing purposes. If this law applies to you and you wish to obtain further information about our sharing, you may make one request each year by contacting us at firstname.lastname@example.org or 609 Greenwich Street, Attn: Legal Department, New York, NY 10014. Requests must state “California Privacy Rights Request” in the subject line or first line of the description and also include your name, street address, city, state, and ZIP code. We are not required to respond to requests made by means other than through the provided email or mail addresses.
K. Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at email@example.com.
L. Changes to this Policy
This Policy is current as of the Effective Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Website and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website and App.
EFFECTIVE DATE: 26 March 2019