Last Updated: March 18, 2024

This Privacy Policy (“Policy”) explains how JRNY Club, Inc. (the “Company” or “JRNY Club”) may gather, collect, record, hold, distribute, share, disclose or otherwise use your personal information and the rights and choices you have in relation to your personal information.

This Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline (collectively, the “Services”), including our website at https://jrny.club/, and all corresponding webpages, software applications or mobile applications that link to this Policy (collectively, the “Site”), when you interact with our accounts and fan pages on social media platforms (the “Social Media Accounts”), and when you interact with our advertising and applications on third-party websites and services, if the advertising and applications include links to this Policy.

Please read this Policy before accessing or using our Services. By using our Services, you agree to the collection and use of your personal information in accordance with this Policy and our Terms of Use.  If you do not agree to all of the terms of this Policy or the Terms of Use, then you should not use or access our Services.

We may change this Policy from time to time, to reflect how we are processing your personal information, and if we make changes, we will notify you by revising the effective date or last modified date at the top of this Policy. We encourage you to look for updates and changes to this Privacy Policy by checking this date when you access our Service.  If we make changes that materially affect your privacy rights, we will provide advanced notice so that you can review the changes before you continue to use the Services. Your continued access or use of our Services after receiving notice of the changes, constitutes your acknowledgement that you accept the updated Policy.

Please note that our Site may contain links to third-party websites, such as delivery services and social media pages. These links are intended for your convenience only. These third-party websites and services are not related to the Company and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage you to read the privacy policies of all websites you visit.

1. Information We Collect

JRNY Club collects certain personal information about you and your use of our Service. Personal information is generally any information that identifies you or makes you identifiable. Personal information does not include anonymized or aggregated information. The types of personal information that we may collect falls into two primary categories: (1) information you voluntarily provide to us; (2) information we collect from you automatically; and (3) information we receive from third parties.

Information You Voluntarily Provide. To use our Service you  will need to provide us with certain personal information that can be used to contact or identify you such as your name, email address, mailing address, phone or mobile number.

2. How We Use Your Personal Information

In general, we use personal information to create, develop, operate, deliver, and improve our Services. The Company may use personal information for the following purposes:

a) To provide the Service and manage your account. We process your personal information to provide the Service to you, including to monitor the usage of our Service. We process your personal information also  to manage your registration as a user of the Service. The personal information you provide can give you access to different functionalities of the Service that are available to you as a registered user.

b) For the performance of a contract.  We process your personal information as part of the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract that you may enter into with us through the Service.

c) To contact you. We may process your personal information to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted Services, including the security updates, when necessary or reasonable for their implementation.

d) To maintain legal compliance.  We may process your personal information to comply with our legal obligations, resolve any disputes we may have with you or other member, and to enforce our agreements with third parties.

e) Security and fraud detention. We may use the information we collect to prevent and detect potentially fraudulent or unauthorized transactions, breach of policies or terms, and threats of harm.

f) For research and development of our Services. We may use the information we collect to understand how our members use the Service, and improve our Service. For example, we may also improve usability of the Service by analyzing how you interact with our Service (such as analyzing how you use tools made available to you or which links you click).

g) To provide marketing communications. We may use the information we collect through the Service to develop and send advertising, direct marketing, and communications about our and other entities' products, offers, promotions, rewards, events, and services.

h) To respond to your requests. We may process your personal information when you contact us, such as with questions, concerns and feedback.

i) For business transfers. We may process your personal information as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.

j) For other purposes. We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, and marketing.  We may also process your personal information to personalize your experience. (See the Cookies and Other Similar Tracking Technologies section for some examples).

k) With your consent. We may process your personal information for any other purpose which is reasonably necessary to provide the Services or other related services requested, with your permission or upon your direction.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by law or contractual obligation applicable to us.

3. Sharing and Disclosure of Information

We share information we collect as needed to fulfill the purposes described in this Policy and as permitted by applicable law. We may share your personal information in the following situations:

a) With service providers. We may share your personal information with service providers to monitor the use of our Service, for payment processing, cloud or other data storage, and to contact you.

b) Analytics partners. We may use analytics services provided by a third-party analytics service provider or by using one of their tools, such as but not limited to Google Analytics, to collect and process certain analytics data. These services may also collect data about your use of other websites, apps, and online resources. Google Analytics is a web analytics service offered by Google LLC, a corporation domiciled in the USA (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: policies.google.com/privacy. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: tools.google.com/dlpage/gaoptout.

c) Advertising partners. We may work with third-party advertising companies (collectively, “Advertising Partners”) to provide you with advertisements or other information that we believe may interest you. These partners may set or access their own cookies, pixel tags or similar technologies on our Service or they may otherwise collect or have access to data about you which they may collect over time and across different online services.

d) Social media features.  Our Service may offer social media features, including certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let you share actions that you take on our social media pages. Your use of such features enables the sharing of personal information with the public, depending on the settings you establish with the entity that provides the social sharing feature.

e) With other users.  When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see you name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

f) With affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

g) With business partners. We may share your information with our business partners to offer you certain products, services or promotions.

h) During corporate transactions. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information. We will provide you with notice before your personal information is transferred and becomes subject to a different Privacy Policy.

i) As required by law. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of JRNY Club or our users.

j) Outside professional advisors. We may share or disclose your personal information with any of the Company’s outside professionals to facilitate the professional advice from those outside professionals.

k) With notice to you and your consent. We may disclose your personal information for any other purpose with your consent.

4. Cookies and Similar Tracking Technologies

We, and third parties acting on our behalf, may employ various tracking technologies, such as cookies and similar technologies (collectively, “Tracking Technologies”) to collect additional personal information as you interact with our Services. This additional information helps us to personalize your experience with our Service and helps us better manage content on our Service by informing us what content is effective.

A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse cookies, our Service may use cookies.

Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how you can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available here.

Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies.  These cookies are essential to provide you with Services available through the Site and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Performance/Analytics Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Sites. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functionality Cookies: These cookies allow us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid your having to re-enter your preferences every time you use the Site.

Tracking and Performance Cookies: These cookies are used to track information about traffic to the Site and how users use the Site. The information gathered via these cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Site. We may also use these cookies to test new pages, features or new functionality of the Site to see how our users react to them.

You can also use the browser with which you are viewing this website to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings), or review the instructions provided by the browsers listed here: Internet ExplorerGoogle ChromeMozilla FirefoxSafari DesktopSafari Mobile, and Android browser. Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Sites and Services. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at allaboutcookies.org.

There are also additional tools available to manage third party cookies. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where individuals can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at optout.aboutads.info/, the DAA of Canada’s opt-out portal available at youradchoices.ca/en/tools, or visit the NAI’s opt-out portal available at optout.networkadvertising.org/?c=1. Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting youronlinechoices.eu/.

Mobile Advertising: You can opt out of having your mobile advertising identifiers used for certain types of advertising by accessing the appropriate settings in your mobile device and following the instructions. If you opt-out, we will remove all data about you and will not collect any further data. The random ID previously assigned to you will be removed. Thus, if at a later stage, you decide to opt-in, we will be unable to continue and track you using the prior ID and you will for all practical purposes be a new user. For iOS devices, to limit interest-based ad tracking, go to Settings > Privacy > Advertising > Turn on “Limit Ad Tracking.” For Android devices, go to Settings > Google services > Ads > Turn on "Opt out of Ads Personalization." For iOS and Android, you can also reset the advertising identifier that is currently assigned to you.

To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering here: youradchoices.com/appchoices.

Flash Cookies. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the website storage settings panel here. You can also control Flash Cookies by going to the global storage settings panel and following the instructions. Setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Do Not Track: Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our Sites do not currently process or respond to "DNT" signals.

5. Children’s Personal Information

Our Services are not directed towards children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information that we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

6. Retention of Your Information

The Company will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information 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, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

7. Data Security

The security of your personal information is important to us. We maintain our Service and all associated data with technical, administrative and physical safeguards to protect against loss, unauthorized access, destruction, misuse, modification and improper disclosure.

Unfortunately, no method of transmission over the Internet, or method of electronic storage can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail (and please do not send us sensitive information, such as payment card information or information contained in government-issued IDs). We are not responsible for circumvention of any privacy settings or security measures contained on the Site. If you have any questions about the security of your personal information, you may contact us at [email protected].

8. Your Rights and Choices

You may, depending on your location, have the right to access, correct, or update your personal information that has been previously provided to us through our Service.  We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You are solely responsible for correcting, updating, or modifying any and all of your personal information as it appears in, and as otherwise stored by Our Service. In order to do so, you may contact us by logging into your account and making the appropriate changes or by email us at [email protected].  In your request, please make clear what personal information you would like to have changed or removed from our database. For your protection, we may need to verify your identity before implementing your request.

To provide our Service to you we may send you communications related to your transactions, security, or the administration of the Site. From time to time we may also send you other messages or updates about the Company, our Site, and promotions or other activities. If you do not wish to receive non-transaction/non-security related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication you received from Us, or send an email message to [email protected] stating that you no longer want to receive these communications directly from Us (“Opt-Out”). Users from the EEA, the UK, Switzerland, Singapore, South Africa, Saudi Arabia, the United Arab Emirates, or Canada will, if required by applicable law, receive such communications only after having consented hereto. Please note that Opt-Out and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior Privacy Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to Opt-Out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

9. International Transfer of Personal Information

Your information, including personal information, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may 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 than those from your jurisdiction.  We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are appropriate safeguards in place as required under the applicable data protection laws and ensuring the security of your personal information maintained. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Site or Service.

10. Notice to California Residents

This section applies only to California residents (“consumers” or “you”) and is intended to inform you, at or before the time of collection of your personal information, about our data collection practices,  your privacy rights under California law, including, until December 31, 2022, the California Consumer Privacy Act of 2018, as amended (“CCPA”) and, beginning on January 1, 2023, the California Privacy Rights Act (“CPRA”). As used in this section only, the term “personal information” is defined as it is used in the CCPA and CPRA.

Categories of Personal Information Collected. We collect  personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or device. e generally collect the following categories of personal information about you when you use Our Site or Services:We generally collect the following categories of personal information about you when you use our Site or Service:

- Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices.

- Commercial information such as records of services purchased, obtained, or considered by you.

- Internet or other electronic information regarding your browsing history, search history, the web page visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.

- Inferences about your preferences, characteristics, behavior and attitudes.

We generally do not collect biometric, or education-related information. For more information about the personal information we collect and how we collect it, please refer to Section 1, above..

We collect your personal information for the business purposes described in Section 2, above. The CCPA defines a “business purpose” as the use of personal information for the business’s operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected.

The categories of third-parties with whom we may share your personal information are listed in Section 2, above.

Your Rights.  If you are a California resident, you may be entitled to the following rights subject to certain exceptions.

Access to Specific Information and Data Portability Rights. You have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose the following to you:

The categories of personal information that we have collected about you;

The categories of sources for the personal information we have collected about you;

Our business or commercial purpose for the collection of your personal information;

The categories of third parties with whom we share your personal information; and

The specific pieces of personal information that we collected about you.

Right to Opt-out of Sale of Personal Information. To the extent that we sell your personal information to third parties, you have the right to request that we disclose the following to you: (1) the categories of your personal information that we sold; and (2) the categories of third parties to whom your personal information was sold.  Additionally, you have the right to direct us not to sell your personal information.  We do not sell your personal information.

Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions.

Non-Discrimination. We will not discriminate against you (by, for example, denying you goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a request to us by emailing [email protected]. Please ensure that your request contains sufficient detail to allow us to properly understand, evaluate, and respond to your request. Before fulfilling your request, we may request additional information to verify your identity in order to ensure that you are the individual from whom we have collected the personal information subject to your request.  Only you, or a person that you formally authorize to act on your behalf, may make a request related to your personal information. If you designate an authorized agent to submit such a request, we will require written proof that the agent has been authorized to act on your behalf or a copy of a power-of-attorney granting such right. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

11. Notice to Users Located in the European Economic Area, Switzerland, and the United Kingdom

This Section provides additional information to individuals located in the EEA, the United Kingdom (UK) or Switzerland at the time their personal information is collected by us.

Legal Basis of Our Processing. The legal basis of our processing within the scope of application of the GDPR, the UK-GDPR or the Swiss Data Protection Act is as follows:

- Contract (Art. 6 (1) b GDPR).  Where we provide our Service and answer your support and customer service requests the legal basis for processing your information is for the performance of our contract with you.

- Legitimate Interests (Art. 6 (1) f GDPR).  We have a legitimate interest in processing your personal information: (1) to provide a secure website user experience; (2)  for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; (3) to protect our financial interests or to otherwise protect ourselves against fraud or unauthorized transactions; (4) to  in promote our Service by facilitate any contests, sweepstakes, or promotions and process and deliver entries and rewards; and (5) to protect our rights and interests (e.g. protect the Company against legal claims) , such as when we share your information with any of the Company’s professional advisors such as attorneys or accountants in order to facilitate their professional advice.

- Consent (Art. 6 (1) a GDPR). Unless consent is not required under applicable law,  the legal basis for processing when we send you promotional communication about our products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you only after you have consented to such communication is your consent. You can withdraw your consent at any time with future effect, e.g. by clicking the unsubscribe-link in each promotional email.

- Compliance with Legal Obligations (Art. 6 (1) c GDPR).  We process your personal information for compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested e.g. under any subpoena or court order.

Your Data Protection Rights.  If you reside in the European Economic Area, Switzerland, or the United Kingdom, you may have the right to exercise the following privacy rights available to you under applicable law. However, we may limit these requests under the applicable law when: (1) denial of access is required or authorized by law; (2) granting access would have a negative impact on another’s privacy; (3) necessary for the protection of our rights and properties; and (4) the request is frivolous or burdensome. To assert your privacy rights, please contact us at [email protected]. We may seek to verify your identity when we receive your privacy rights request to ensure the security of your personal information.

- Right to Access. You may have the right to obtain a copy of your personal information that we hold about you, as well as other supplementary information, such as the purpose of processing, the categories of personal information that we process, and the entities to whom we disclose your personal information.

- Right to Rectification. You may have the right to request that we correct any of your personal information in our files.

- Right to Erasure. Under certain circumstances, you may have the right to request the erasure of your personal information that we hold about you. Note, however, that the right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your information.

- Right to Restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances. For example, this right is available if you contest the accuracy of the personal information that we hold about you or if you objected to our processing of your personal information.

- Right to Object. You have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of consent or legitimate interests as detailed in Section 4, above. However, we may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

- Right to Portability. Under certain circumstances, you may have the right to receive personal information that we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another controller.

If you believe that we have infringed your rights, we encourage you to first submit a request to us directly so that we can try to resolve the issue or dispute informally. Without prejudice to any other administrative or judicial remedy, you may have the right to lodge a complaint with a supervisory authority in a specific region and according to applicable law. You can find details of EEA Supervisory Authorities at: https://edpb.europa.eu/about-edpb/board/members_en.

International Transfers. We may share your personal information  with recipients (including our group members, service providers or business partners, as described in this Policy), located in the United States and/or otherwise in countries outside the EEA, the UK and Switzerland which do not provide for an adequate level of data protection from an EU, UK or Swiss law perspective. For such transfers, we will ensure that the recipients are subject to appropriate safeguards as permitted under the applicable data protection laws, e.g. by entering into appropriate data transfer agreements on the basis of EU standard contractual clauses issued by the EU Commission, or by reliance upon the Article 49 GDPR derogations or corresponding derogations under the Swiss Data Protection Act, as applicable.

12. How To Contact Us

If you have any questions or concerns about this Policy, or if you have a complaint, you can contact us via email at [email protected].