ClassPass Privacy Notice (HK)
Last updated: October 1, 2018
ClassPass respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice only applies to personal information that we collect through our website at classpass.com and our mobile applications (collectively, the “Site”). This Privacy Notice applies to you if you use our Site in Hong Kong.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
1. What Does ClassPass Do?
ClassPass enables consumers to find, book and attend a wide range of fitness, recreational and wellness classes, services or products offered and operated by fitness studios, gyms, trainers, venues or other third parties through our platform. ClassPass Singapore subsidiary, ClassPass Hong Kong Limited is located in Hong Kong and our parent company, ClassPass Inc., is headquartered in the United States. ClassPass group companies operate all around the world.
2. What Personal Information Does ClassPass Collect?
We collect or receive personal information in a few different ways via the Site. Often, you choose what information to provide, but sometimes we require certain information in order for you to use, and for us to provide you with, the Site and the experiences you reserve or access through the Site. Please note that if you do not provide or we cannot access the personal information as indicated, then we may not be able to process your application and register you as a member, and you may not be able to participate in certain activities, features and/or to obtain certain services or information offered on or through the Site.
- Data You Provide To Us.
There are a variety of different ways you may provide data to us, such as:
- Account Creation. To create an account, you need to provide data including information such as your name, email address, phone number and a password. If you make a purchase or sign up for a subscription, you will need to provide payment and billing information.
- Profile. To complete your profile, you may provide other information, such as a photo or birthdate.
- Posting and Uploading. We collect personal information from you when you provide, post or upload it to our Site, such as when you respond to a survey or provide a class rating or review.
- Third Party Data. You may not provide information to us about someone else unless you have obtained the prior consent of the other person for us to receive and use their information, such as for emergency contact or referral purposes.
You should ensure that all Personal Information provided to us is complete, accurate, true and correct. Failure on your part to do so may result in inability to provide you with the products and services you have requested, or delays in providing you with products and services you have requested, or processing your applications.
- Data Collected Automatically Through Your Use of the Site.
- We log usage data when you visit or otherwise use our Site, such as when you view or click on content or ads (on or off our Site), perform a search, browse, schedule a reservation and install or update one of our mobile apps. Specifically, the information we collect automatically may include information like internet protocol (“IP”) address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked.
- We may also collect precise geolocation data pertaining to your mobile device, if you have consented to providing this to us through your device settings. We may use this information to provide, promote, and improve our services (for example, by showing you classes that are close to your location) and for related reasons, such as fraud prevention and security purposes. Please note that if you do not consent to providing your geolocation data, certain features of the mobile application may not work.
The information we collect automatically enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. This enables us to improve the quality and relevance of our Site to our visitors.
- Cookies, Web Beacons and Other Similar Technologies.
- Data From Others.
- From time to time, we may receive personal information about you from third party sources to assist us in providing, evaluating and improving our Site and offerings, but only where these third parties represented that you gave your consent either or are otherwise legally permitted or required to disclose your personal information to us. For example, studio partners may provide information to us in connection with a reservation you make or a class that you take, for example if there is an issue with your reservation. We may also collect information from third-party services like Facebook if you use one of these services to log into or integrate with our Site. This information may include your name, email address, gender, city, and state or your friends or contacts on such sites. Logging in through these third-party services may allow you to interact with other users that maintain accounts through those services. Further, if you choose to integrate your ClassPass account with your iOS HealthKit or similar application, we may receive certain sensitive personal information such as heart rate and calorie information to help track your activity, personalize your experience and improve our service.
3. What Does ClassPass Do with the Personal Information it Collects?
ClassPass uses personal information it receives for several purposes:
- Site: To operate and maintain our Site and the products and services offered through our Site. For example, we use personal information to fulfill your reservation and purchase requests, including processing payments, and to customize your experience on our Site, such as by tailoring the content or experiences we show you.
- Communication: Subject to applicable law, to contact you through email, phone (including calls and/or texts), postal mail, notices posted on our websites or apps, and other ways. We will send you messages about the availability of our Site, security, customer service, or other service-related issues. We also send messages about the Site, updates, reminders, and marketing and promotional messages in accordance with your communication preferences. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
- Customer Support: In connection with customer service inquiries and matters, such as to investigate, respond to and resolve complaints and service issues.
- Marketing: For marketing and promotional purposes, such as to develop our marketing strategy and offer contests, sweepstakes, or other promotions and to fulfill any related awards or discounts;
- Research and Development: For research, analytical, recordkeeping, and reporting purposes; to develop and test new products, features and ideas; to learn about our customer base and Site and to evolve and improve our Site, products and services.
- Other: For any other purpose identified at the point of collection or otherwise with your consent.
4. Who does ClassPass Share My Personal Information With?
We may disclose your personal information to the following categories of recipients or in the following circumstances:
- third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site, payment card processors, customer support vendors, hosting vendors, scheduling providers and market research and marketing vendors), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- to our group companies, to provide, develop, improve, and analyze the Site and our offerings this includes our parent company, ClassPass Inc. and its subsidiaries including but not limited to ClassPass Europe Limited, ClassPass Australia Pty Ltd, ClassPass Canada Ltd., ClassPass Singapore Pte Ltd., ClassPass Malaysia Sdn. Bhd.
- any venue, studio, instructor or other provider that makes available a class, activity or experience you reserve or use through our Site and their third-party providers, so that they can process the applicable reservation or activity and make available classes and services to you;
- to anyone who visits our Site if you voluntarily share information about yourself in a public area on our Site, such as a public profile or class ratings. You should be aware that any content or information you choose to disclose in these areas can be read, collected and used by other users, the general public and other sites (including search engines).
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person;
- to any actual or proposed assignee, transferee, or successor of or to ClassPass’s rights in respect of your personal data (including to their representatives, investors, directors, employees and consultants and advisors) in connection with an actual or potential merger, sale, acquisition, investment, assignment, reorganization, joint venture, or transfer of all or part of ClassPass’ business, assets, affiliates, including if ClassPass should ever file for bankruptcy or a related proceeding, provided that we inform the relevant third party it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to your employer (or similar entity), if you participate in any enterprise solutions or corporate programs;
- to any other person with your consent to the disclosure.
5. How does ClassPass Keep My Personal Information Secure?
We are committed to protecting Personally Identifiable Information from unauthorized or accidental access, processing, erasure, loss or use. We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We monitor our systems for possible vulnerabilities and attacks. However, we cannot guarantee 100% security of any information that you send us.
6. International Data Transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, our Site servers are located in the United States, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.
7. Your data protection rights
You have data protection rights including:
- If you wish to access, correct, update or request withdrawal of consent for your personal information, you can do so by contacting us as explained below.
- Please note that we cannot use your Personally Identifiable Information for direct marketing without your consent. You have the right to opt-out of marketing communications we send you at any time.
- You may contact us as explained in the “How to contact us” heading below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
8. Third Party Sites
9. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
10. How to contact us
If you have any questions or concerns about our use of your personal information, please contact ClassPass Hong Kong Limited, attn Legal Office here. In response to your data requests (other than for removing you from our direct marketing lists), we may charge you a reasonable fee for doing so.
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner (in this case, ClassPass) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.
We use first party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Sites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites. Third parties serve cookies through our Sites for advertising, analytics and other purposes. This is described in more detail below.
First and third-party cookies served through our Sites and the purposes they perform are described below:
- Essential website cookies: These cookies are strictly necessary to provide you with services available through our Sites and to use some of its features, such as access to secure areas.
- Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Sites but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
- Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our Sites are being used or how effective are marketing campaigns are, or to help us customise our Sites for you.
- Advertising cookies: These cookies are used to make advertising messages more relevant to you and they perform functions like preventing the same ad from continuously reappearing and in some cases selecting and displaying advertisements to you across the internet that are based on your interests.
- Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Sites through third party social networking and other websites. These cookies may also be used for advertising purposes too.
What about other tracking technologies?
Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Sites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Sites to another, to deliver or communicate with cookies, to understand whether you have come to our Sites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
Our mobile applications may include third-party application software development kits that provide mobile performance and analytics data, bug reporting features, and APIs to third parties that help provide the Site, for social media functionality, and for marketing and advertising.
Does ClassPass serve targeted advertising?
As described above, third parties may serve cookies on your computer or mobile device through the Sites to serve advertising. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.
How can I control cookies?
- Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies
- Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647
- Safari: http://support.apple.com/kb/ph5042
- Explorer: http://windows.microsoft.com/es-es/windows7/how-to-manage-cookies-in-internet-explorer-9
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ , https://www.networkadvertising.org/, or http://www.youronlinechoices.com. Please bear in mind that there are many more networks listed on that site than those that we use on our Website.
We use Google cookies for analytics and marketing purposes. You can opt-out of Google tracking through Google Ads Settings, Ad Settings for mobile apps, or any other available means. Google also provides a Google Analytics opt-out plug-in for the web.
What is Do Not Track (DNT)?
DNT is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites by using browser settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a DNT technology standard. While some progress has been made, it has been slow. No standard has been adopted to this date. As such, ClassPass does not generally respond to “do not track” signals.
How often will this Cookie Notice be updated?
The date at the top of this Cookie Notice indicates when it was last updated.
Where can I get further information?