Privacy Policy

Last updated: November 27th, 2024

At BPM Health Co. (“Boostcamp,” “we,” “us,” and “our”), our mission is to help you along your fitness journey and we want you to know how we collect and use the data that you provide to us over the course of that journey. Boostcamp is the boostcamp.app website (“Website”) and Boostcamp mobile applications (“Mobile App”) (which we collectively refer to in this Privacy Policy as the “Services”). We encourage you to read this Privacy Policy as well as our terms and conditions of use (referred to throughout as our “Terms”).

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY.

Boostcamp and all associated Services and systems, including registration, are stored on servers in the United States. If you are located outside of the United States, please be aware that information we collect (including cookies and device data) will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws and principles, including your data subject rights, may not offer the same level of protection as those in the country/region where you reside or are a citizen. By using our Services and providing information to us, you consent to the transfer to and processing of the information in the United States and, unless otherwise stated in this Privacy Policy, we use this consent as the legal ground for that data transfer. You may be asked for your explicit consent to this data transfer as part of account creation.

Please read this Privacy Policy carefully, as your access to and use of the Services signifies that you have read and understand this Privacy Policy. If you do not agree with any part of this Privacy Policy or our Terms, please do not access or continue to use any of the Services or otherwise submit your Personal Data (defined below) to us.

Note to Residents of the European Union: In order to comply with the requirements of the UK Data Protection Act 2018 and the European General Data Protection Regulation (GDPR) for our United Kingdom and European Union (collectively, “European”) consumers and users, this Privacy Policy outlines the legal bases on which we process your Personal Data and provides other information required by the GDPR. Further country/region specific information for our European consumers and users is outlined in the location-specific disclosures section.

Information About Your Personal Data

This Privacy Policy relates to data about you, your devices, and your interaction with our Services.

“Personal Data” is information that can be reasonably used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, device IDs, certain cookie and network identifiers, and “Fitness Data.”

Boostcamp collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business; for advertising and marketing; and to provide you with innovative fitness services, as further described in this Privacy Policy.

We may create de-identified or anonymous data from Personal Data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you, through obfuscation, or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

How We Collect and Use Personal Data

We may collect your Personal Data directly from you in a number of ways and for various business purposes, including:

1. When you register for an account or interact with our Services

We collect Personal Data when you use or interact with our Services, including when you register for a Boostcamp account, purchase a Boostcamp Pro subscription (including processing of payment), or otherwise use the Services (e.g., browse the content available on the Services), and when you ask us to customize our Services. This Personal Data may include name, photo, username and password, email address, date of birth, gender, payment information and general location data.

2. When you input Fitness Data within our Services or use our Services that collect or ingest data from mobile device sensors

“Fitness Data” includes data you provide related to your fitness goals, fitness level, body measurements and similar types of data. We collect this data in order to provide the Services and to tailor features, advertising, and services to your interests and goals, including providing workout programs, reporting and analytics, and other fitness related services, and product recommendations.

3. When you use or interact with a wearable or other connected device

We also collect Personal Data, including Fitness Data, when you use a device that is connected to the Internet, such as heart rate monitors, activity trackers, and other devices or wearables that integrate with the Services. When you use a wearable or connected device or product, we may also collect certain information about the device or product such as serial number, Bluetooth address, UPC, or other device- or purchase-related information.

Note on Apple HealthKit Data

You can choose to connect and share your information with HealthKit and your HealthKit information with Boostcamp. The information you provide to HealthKit is then governed by the Apple Terms and Conditions and Privacy Policy. The unique information you choose to send from HealthKit is not used by Boostcamp for marketing and advertising or transferred by Boostcamp to third parties for marketing and advertising.

Note on Google Health Connect

You can choose to connect and share your information with Health Connect and your Health Connect information with Boostcamp. The use of information received from Health Connect will adhere to the Health Connect Permissions Policy, including the Limited Use requirements.

4. When you communicate with us or sign up for promotional materials

We collect Personal Data when you communicate with us or sign up to receive promotional materials or information (“Messages”) via email and push notifications.

If you consent to receive Messages, we may use your Personal Data and other information to communicate with you about the Boostcamp Services you have purchased or used; provide you with promotional messages and personalized advertising; to notify you of other features; to notify you of contests, challenges, sweepstakes, and other promotions (“Promotions”); to notify you of Services we think may be of interest to you; and, for other marketing purposes. You can manage your communication preferences in your account settings.

Please note that regardless of your email settings, we may send you Messages pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to Services you have purchased or used.

We may use your Personal Data to respond to and address your requests for technical support, questions or complaints about the Services, or any other communication you initiate. This includes accessing your account to address technical support requests.

5. When you participate in special activities, offers, or programs

We may request or otherwise collect Personal Data, including Fitness Data when you participate in Promotions, when you participate in surveys, or when you participate in research activities or initiatives (“Research”). This includes Personal Data, such as name, address, email address, and age and other information that may be appropriate in order to participate in the Research. If you win a Promotion, we also may need to collect certain tax information, waivers and releases, depending on the prize.

We may also launch Promotions and surveys that ask you to answer questions about a range of topics from Personal Data to brand and product preferences. Promotions or surveys may be run by a Boostcamp service provider or co-branded with one of our business partners. In such instances, Personal Data may be collected directly by and/or shared with Boostcamp, the service provider, and/or business partner, including for marketing purposes. Each Promotion or survey that treats your Personal Data in a way that differs from this Privacy Policy will identify the privacy policy governing that collection of information in connection with that Promotion or survey.

6. When you engage with our online communities or advertising

We may collect your Personal Data when you engage with our online communities. This includes when you click on advertisements, interact with our social media pages, submit content, or otherwise enter information into comment fields, blogs, or community forums sponsored by or affiliated with Boostcamp. Please note that our community forums are public, so we recommend that you exercise care in deciding what information and content you wish to disclose.

7. When you access third party products and services

We may allow you to register and pay for third-party products and services or otherwise interact with another website, mobile application, or Internet location (collectively “Third Party Sites”) through our Services, and we may collect Personal Data that you share with Third Party Sites through our Services. When we do so, we will inform you of the further details of how we use your Personal Data.

8. When you connect with us through social media

You may choose to enable, log into, or sign on to the Services through various social media or social networking services, such as Facebook (“Social Networking Service” or “SNS”). When you connect using your SNS accounts, we may collect Personal Data that you have provided to that SNS. For example, when you log in with your Facebook credentials, with your consent, we may collect Personal Data from your Facebook profile that is permitted under Facebook’s Terms of Service - such as your email address, profile picture, and friend list. We use this data to provide, enhance, and personalize the Services (e.g., to help connect you with or suggest friends within our Services). If you do not want to provide us with this data, you can adjust the privacy settings on your SNS account.

9. When we collect data from third parties or publicly-available sources

We may obtain certain data about you from third party sources to help us provide and improve the Services and for marketing and advertising. We may combine your Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the Services.

10. When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies

We may collect certain Personal Data using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.

11. When we aggregate or centralize data

We aggregate and centralize Personal Data and Fitness Data for purposes of analytics, innovation, and to provide enhanced services to our customers and end-users.

12. When we link you to friends across platforms

Our Services consist of social sharing and communication with others. We use your Personal Data to enable sharing as described in the Services, including to enable you to find and link to friends on the Services.

13. Share content or achievements; or invite friends

With your permission, we access your contacts to enable you to share content or achievements, including videos, with friends or other members, and to invite friends to use the Services.

14. When we provide you geographically relevant Services, offers, or advertising

We may use general location data to provide you with Services, offers or advertising that are relevant to your general location.

15. When you ask us to customize our Services

We use photos, videos, or other data you provide to us to customize our Services.

16. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes

We may use Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

How We Disclose Personal Data

We may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy, in the Location-Specific Disclosures section, and in the following ways:

1. Operation and Improvement of Services and User Experience

Internally to relevant departments within Boostcamp, in order to provide and improve Services, for marketing purposes, and for advertising.

2. To Service Providers and Vendors

With business partners, marketing partners, and vendors to provide, improve, and personalize the Services.

Notice for Apple Users

For Apple users, our iOS mobile apps share personal data with third parties as described in this Privacy Policy. We take measures to ensure such third parties provide privacy protections identical to or equal to those required under this Privacy Policy and apple’s developer guidelines.

3. To Social Network Providers

With social network providers when we use social network widgets, buttons, or plug-ins in our Services.

4. To other Boostcamp Registered Users

With other users of the Services in the context of specific features that are social in nature. Additionally, any information you post or disclose in our community forums (e.g., Facebook, sponsored pages on the Boostcamp Blog) is public.

5. For Advertising and Marketing

With advertising and marketing partners for advertising and marketing purposes on Boostcamp’s behalf and on behalf of third parties, including but not limited to Facebook.

6. For Certain Analytics and Improvement

With certain companies for purposes of analytics and improvement of the Services.

7. For Legal Compliance, Law Enforcement, and Public Safety Purposes

With law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

8. In the event of an actual or contemplated sale.

With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.

Legal Basis for Processing (Europe)

This section addresses the legal basis for processing the Personal Data of natural persons located in the United Kingdom, European Union, and European Economic Area (collectively, “Europe”). Some processing activities may be addressed in multiple sections because more than one legal basis may apply depending on the circumstances or service.

For the purposes of applicable data protection laws, BPM Health Co. is the controller of the Personal Data you provide to us (“Data Controller”). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy.

We may collect and process Personal Data of European data subjects on the following lawful basis:

1. Performance of a Contract

To perform our contractual obligations to you in connection with the Services, including but not limited to account registration, fulfilling purchases you have made via the Services (including processing of payment), and contacting you in relation to any issues with the Services.

2. Legal Obligations

To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.

3. Legitimate Interests

To operate our business and provide the Services, other than in performing our contractual obligations to you for Boostcamp’s “legitimate interests” for the purposes of applicable law - except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.

For example, the following areas include processing covered by Legitimate Interests, subject to applicable law:

Communication. To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms and also to address your requests, inquiries, and complaints. We may send strictly necessary communications, including emails, even if you have opted out of receiving other Boostcamp emails or communications. These types of communications do not require consent. We also process your Personal Data for our legitimate interests when you communicate with us, including when you sign up for promotional materials and we have not asked you for your consent in that regard.
Respond to Your Requests. To respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.
Promotional Messages. We process your non-sensitive Personal Data to provide you with promotional messages and personalized marketing, including: when you communicate with us or sign up for promotional materials; when you participate in offers or programs; when you engage with our online communities or advertising; to provide you geographically relevant Services, offers, or advertising; when we aggregate and centralize data; and when we share Personal with our service providers and vendors.
Surveys. To send you surveys in connection with our Services, unless commercial in nature. In those cases, a survey request may be sent to you if you have given us your consent to receive marketing from us.
Compliance with Law and Public Safety. To assist in the investigation of suspected illegal or wrongful activity, including sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend our rights and property, or the rights or safety of third parties.
Improvement and Development. To develop, provide, enhance, and improve our Services and your experience, including to enable you to use the full range of our Services (e.g., processing of non-sensitive Personal Data related to your use or interaction with a wearable or other connected device that integrates with the Services; when you access third party products and services; when we collect, use, or otherwise leverage cookies, device IDs, general location data, data from the environment, and other tracking technologies; when you connect with us through social media; when we collect data from third parties or publicly-available sources; when we aggregate and centralize data; and when we share Personal Data with our service providers and vendors). For internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
Enforcing Terms and Notice. To enforce our Terms or this Privacy Policy, or agreements with third parties.
Merger or Acquisition. To support a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.

4. Consent

In some cases, we may ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our Services or a form (including enrolling in Promotions); or (ii) registering or creating an account with us. Due to different countries’ laws governing consent for the collection and use of Personal Data, the requirements for consent will differ across regions. We may request your consent for a number of activities including:

Boostcamp Marketing and Communication

We may ask for your consent to contact you by email or push notifications about other offers, products, Promotions, or services that we think may be of interest to you and for other marketing purposes.

Sharing with Third Parties

We may also ask for your consent to share your Personal Data with certain Third Party business partners in order to offer certain goods, services, or programs. To withdraw consent, please go to the preferences of the specific third party service or app.

Third Party Marketing

We may ask for your consent to provide Personal Data to allow third parties to contact you regarding their products, services, Promotions, or offers. Typically this is in conjunction with a sweepstakes or challenge (your consent for third party marketing is generally not a pre-requisite to participation. To withdraw consent, please go to the preferences of the specific third party.

Collecting Mobile Device IDs, Advertising IDs, and Data from Sensors

When you use our Mobile Apps we may ask for your consent to collect these (this consent may be captured at the operating system level). To change your consent status for this data, please go to the preferences of the Mobile App. If you choose not to provide this information, certain Services features may be unavailable or not function properly.

Processing Sensitive Personal Data

We may request your consent to process sensitive Personal Data. The Website or Mobile App may require this data to provide the Services, including when you use or interact with a wearable or other connected device that integrates with the Services. If you choose not to provide sensitive Personal Data, certain features or Services may be unavailable or not function properly.

Research

We may request your consent to use your Personal Data for Research purposes. We may also request your consent to contact you to determine your interest to participate in certain Research initiatives and to share identifying results. For market research, we may ask questions on behalf of business partners and share your response with business partners.

Transfer of Data

We transfer data to the United States and to other countries/regions for processing. We may request your consent for this transfer or the transfer, in other cases, may be justified by a legal basis other than consent.

Automated Processing

We may use some automated processing to provide our Services and to make recommendations in the context of specific services. This processing is strictly necessary for providing certain Services (and, in some cases, is the service itself) and is not covered by consent. Other automated processing is not significant either due to the nature of the data or the decisions being made or recommended, and so consent is not required. However, for automated processing that is significant and related to sensitive Personal Data, prior to sharing or using such data, we will first seek your consent.

To Enable Social Sharing and Connect with Us on Social Media

Our Services consist of social sharing and communication with others. If you sign up for these Services, we may ask for your consent to use your information to enable sharing as described in the Service. We may also ask for your consent when you connect with us through Social Media.

Promotions

We may ask you for permission to use your Personal Data and Fitness Data for special offers, events, sweepstakes, and other Promotions. We may use the Personal Data we collect during Promotions, to administer the Promotion, verify identity and age, and to communicate with you about the Promotion.

Managing Your Preferences and Consent

Based on the laws applicable to you, you may manage your preferences and update your consent to certain processing as described in this section.

Cookie Use and Controls

Our Services may utilize cookies and similar types of technologies described in this section. Cookies serve a wide variety of purposes. Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. Cookies are used to personalize your web experience and for security, analytics, and marketing. Our cookies are placed and read by our web servers, while other cookies are placed and read by other companies’ web servers. Information on specific cookies is found on our website. You can block and control cookies by toggling OFF all non-Necessary categories of cookies in our CookieBot Management Center. By consenting to cookies, you acknowledge and agree that your Personal Data, including any relevant communications, may be collected and received by third parties.

Please note: If you block all non-Necessary cookies, certain functionality on our Services may not work.

One way to think about cookies is based on their function. The following settings will control our use of browser cookies, the use of IP address for tracking, and the collection and use of data.

Necessary Cookies. Necessary cookies are crucial for the website's functionality, ensuring basic operations and security features. These cookies do not store any personal information. Without these cookies, some functionality on our Website may fail. You can block these cookies in your browser preferences.

Non-Necessary Cookies. Non-necessary cookies are used to collect personal data through analytics, ads, and embedded content. These cookies are not essential for the website's core functions. User consent is required before activating these cookies.

IP Address Use

An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Privacy Policy, include “public” IP addresses, such as the IP address for a home router that is visible to the Internet, as well as “local” IP addresses, which are IP addresses assigned to computers and mobile devices “behind” a router (such as a home router). Our advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency.

You can choose not to have an IP address used for purposes of advertising or analytics by using the cookie controls for “Advertising Cookies,” and “Performance/Analytics,” above.

Web Pixels or Beacons Use

Pixels are extremely small image files that, when loaded by your web browser, cause the browser to make a network request to the party corresponding to the pixel. If that party’s cookies are currently stored in your browser, those cookies will be transmitted with the request. Beacons can be used on web pages for advertising or to confirm the opening of a marketing email. When used in conjunction with cookies for interest-based-advertising, the cookie controls above can be used to control the purpose for which they are used.

HTML5 Local Storage

HTML5 Local Storage in the browser is different from cookies, but can be used for the same purpose (to pair a tracking ID to a particular web server with your web browser so that the web server can identify your web browser over time). You can control the purpose for which HTML5 Local Storage is used by using the cookie controls outlined above.

Social Network Interaction and Widgets

Social network widgets, buttons, and plug-ins on our Website passively transmit data regarding a social network’s members to that social network, even when a button is not clicked. These technologies may allow a social network (e.g., Facebook) to personally identify its members and to know the web pages its members have visited. This is true wherever social network buttons are embedded, regardless of whether a button is “clicked” or “pressed.” If you belong to a social network or use these categories of web services, you should review the privacy policies of those services to understand the nature of the data that they collect and what, if any, options the service offers to control how data is collected and used. If you disable advertising cookies, the passive tracking associated with these buttons will be blocked on our sites.

Mobile Device Advertising IDs, Location, Sensor Data, and In-Range Device Data Use

Our Services may transmit Device IDs, general location data, and data from sensors to us and our partners, including our advertising partners.

Device IDs include IDs associated with your mobile device carrier such as IMEI, MEID, IMSI; platform-specific IDs such as Android ID, Google AID, and Apple’s IDFA; and IDs that are part of your device hardware, such as WiFi MAC address, and serial number. Exactly which Device IDs are transmitted can depend on your mobile device platform and the version of your operating system.
General Location Data. Our Services may transmit general location data. General location data may be obtained from GPS services, cell tower triangulation, or known location of nearby WiFi access points.
Sensor and In-Range Device Data. Our apps and Services may also collect Device IDs and network addresses (including IP addresses, MAC addresses, and SSIDs) from other, in-range or networked devices and WiFi Access Points.
How We Use Mobile Device Data. We may use Device IDs, coarse location and general location data, and data from sensors, including the local network, (together with app usage data and Fitness Data) for strictly necessary purposes; improving our apps and analytics; and personalization and preferences.

Change Consent Settings for Communication Preferences

Consent for Email Communication: After signing up for email communications, you can choose to unsubscribe using the unsubscribe link in any commercial email we send. Please note that if you unsubscribe from “all emails” this means “all emails other than strictly necessary emails.” You will still receive email communications from us if they are strictly necessary to provide the Services or to confirm or validate a transaction, recover accounts, etc.

Mobile Push Notifications: You can manage the type of push notifications you receive from Boostcamp by modifying the settings within the App. You can modify your push notification settings on the App’s Train tab > Settings (Gear Icon) > Notifications. You may also set your mobile device settings to not allow push notifications from us.

Transfers of Your Personal Data to Other Countries

The Personal Data Boostcamp processes, and all associated Services and systems, including registration, is housed on servers in the United States. If you are located outside of the United States, please be aware that Personal Data we collect will be processed and stored in the United States (the data protection and privacy laws in the United States may offer a lower level of protections than in your country/region).

By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the United States. Where and as required, we will seek your explicit consent as outlined in this Privacy Policy.

Data Retention

We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

Where permissible, we will also delete your Personal Data upon your direction to delete your account. Information on how to make a deletion request can be found here or by contacting our support team.

If you have further questions about our data retention practices or would like to make a deletion request, please contact us through our support team.

Security

We implement technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. We will notify you in accordance with applicable law if your Personal Data is subject to a personal data breach.

Links to Other Websites. Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide a link or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third Party Sites that you interact with.

Children

We do not knowingly collect Personal Data online from individuals under 18. If you become aware that a child has provided us with Personal Data without parental consent, please contact us through our support team. If we become aware that an individual under 18 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel that individual’s account.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through our support team or write to us at:

BPM Health Co.
ATTN: Privacy/Legal
77 Sands Street, Floor 8
Brooklyn, NY 11201

You can also go to our location-specific disclosures to find a contact for the Data Protection Officer in your region, if applicable.

Location-Specific Disclosures

Residents of Australia

If you reside in Australia, you may have the following rights:

Know why your Personal Data is being collected, how it will be used and to whom it may be disclosed
Not identifying yourself or using a pseudonym in certain circumstances
Request access to your Personal Data
Stop receiving unwanted direct marketing
Request inaccurate Personal Data to be corrected
Make a complaint if you think your Personal Data is being mishandled

To make a request, please contact us through our support team or at the address listed above. We may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

If you have any complaints regarding how we handle your Personal Data, please contact our support team or write to us at the address above with a detailed description of the complaint. We respond to complaints as soon as practicable, and in any event, within the time limits prescribed by law.

Residents of the United Kingdom, European Union, and European Economic Area (collectively, “Europe”)

Exercising Your Data Protection Rights

If you reside in Europe, you may have certain data protection rights to the Personal Data that we have collected about you. To exercise your rights to your Personal Data, please contact us through our support team or at BPM Health Co. Inc, 77 Sands, 8th Floor Attention: Privacy/Legal Brooklyn, NY 11201. We respond to qualified requests as soon as practicable, and in any event, within the time limits prescribed by law.

Subject to applicable limitations, residents of Europe may have the following rights:

Right of access to your Personal Data: You have the right to ask us for confirmation on whether we are processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved).
Right to correction: You have the right to have your Personal Data corrected if it is inaccurate and to have incomplete Personal Data about you completed, as permitted by law.
Right to erasure: You have the right to ask us to delete your Personal Data, as permitted by law.
Right to restriction of processing: You have the right to request the limiting of our processing under limited circumstances, including: (i) when the accuracy of your Personal Data is contested; (ii) when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead; or (iii) when you have objected to processing.
Right to data portability: You have the right to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible and as permitted by law.
Right to object: You have the right to object to our processing of your Personal Data, as permitted by law. THow we may disclose your Personal Data

Transfers of Your Personal Data to Other Countries

The Personal Data Boostcamp processes, and all associated Services and systems, including registration, are housed on servers in the United States. If you are located outside of the United States, please be aware that Personal Data we collect will be processed and stored in the United States (the data protection and privacy laws in the United States may offer a lower level of protections than in your country/region).

In order to use our Services, we may require you to agree to the transfer, storage, and/or processing of your Personal Data in the United States. In other situations where Personal Data is transferred outside of Europe, Boostcamp leverages other mechanisms for international data transfer including the European Commission-approved standard contractual clauses and consent. You have the right to request a copy of the applicable measure or further information by contacting us through our support team or at BPM Health Co., 77 Sands, 8th Floor Attention: Privacy/Legal Brooklyn, NY 11201.

Marketing Communications

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information. You may revoke your consent at any time (this will not affect the processing of your Personal Data undertaken until the revocation). If you want to stop receiving promotional materials, etc., you can do so at any time by changing your communication preferences for emails and App.

Right to Lodge a Complaint Before the Data Protection Authority

European residents have the right to lodge a complaint with a competent data protection authority, i.e., the particular data protection authority in the EU Member State in which you reside, work, or in the place of the alleged infringement. For residents of the UK, you may lodge a complaint with the UK Information Commissioner’s Office.

Changes to this Privacy Policy

In order to enhance our Services it might be necessary to change this Privacy Policy from time to time. We therefore reserve the right to modify this Privacy Policy in accordance with the applicable data protection laws. Please visit our Website from time to time for information on updates to this Privacy Policy.

How to Contact Us or Our Privacy Office

BPM Health Co. is the data controller responsible for the processing of your Personal Data in connection with the Services. In case of questions about the processing of your Personal Data please contact us at:

BPM Health Co.
ATTN: Privacy/Legal
77 Sands Street, 8th Floor
Brooklyn, NY 11201

Residents of South Korea

Boostcamp Personal Data Items Collected

Mandatory: Email Address, Account Password, Billing Address, Gender, Date of Birth, postal code, IP address, browser history information, and cookies.

Optional: Email Address, Billing Address, Gender, Date of Birth, postal code, order history, IP address, browser history information, and cookies. Login and interaction information from social media and online communities.

Access Requests

Boostcamp takes steps to keep your Personal Data accurate and up to date. If you reside in South Korea, you may request access to, and modification, opposition and deletion of the Personal Data that we have collected about you. To access your Personal Data, please contact us through our support team or at the address listed below. Subject to applicable law, we may charge for this service and will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

Data Retention and Destruction

Under applicable Korean law, your Personal Data must be retained for the following periods:

Records regarding contracts or the cancellation of contracts, and records on payment and provision of goods:
- Reason of retention: Act on Consumer Protection in Electronic Commerce Transactions, etc.
- Retention period: five years
Records on customer complaints or dispute resolution:
- Reason of retention: Act on Consumer Protection in Electronic Commerce Transactions, etc.
- Retention period: three years
Communications confirmation data
- Reason of retention: Communications Privacy Protection Act
- Retention period: three months
Records on electronic financial transactions:
- Reason of retention: Electronic Financial Transaction Act
- Retention period: five years

Method and Procedure for the Destruction of Personal Data

Boostcamp retains your Personal Data (i) for as long as you maintain an account or as needed to provide you the Services and/or (ii) as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Personal Data is destroyed when it is no longer necessary for these purposes. The specific destruction process and method are as follows: (i) Personal Data printed on the paper is shredded, burned, pulped, pulverized, or incinerated; and (ii) Personal Data stored in electronic form is deleted using technology designed to prevent the recovery of the Personal Data.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through our support team, write to us or call us at:

BPM Health Co.
ATTN: Privacy/Legal
77 Sands Street, 8th Floor
Brooklyn, NY 11201

Residents of California and Other U.S. States

We may collect the categories of Personal Data described in the How We Collect and Use Personal Data section of this Privacy Policy, which may be collected from you, directly (i.e., in the case of user inputted information), indirectly (i.e., from our use of cookies and information obtained from your device), and from third parties (i.e., social network profile information and partner referral information).

We may share Personal Data with the categories of third parties for the purposes described in the How We Disclose Personal Data section of this Privacy Policy.

To the extent our Services are subject, qualifying residents of California and certain other U.S. states may have the following rights:

Access/Right to Know. You may have the right to access the Personal data collected about you, the sources from which such information was obtained, the categories of information that have been sold or disclosed for a business purpose, and the commercial purpose for which the information was collected or sold, provided to you in a reasonably portable format.
Deletion. You may have the right to request that we delete any of the Personal Data we have collected or maintained about you.
Correction. You may have the right to correct inaccuracies in your Personal Data.
Opt-out of the “Sale” and “Sharing” of Personal Data or its use for Targeted Advertising. You may have a right to opt-out of the “sale” and “sharing” of your Personal Data or its use for targeted advertising.
Sensitive Personal Data. You may have the right to opt-out of the use and disclosure of your sensitive Personal Data in certain circumstances.
Restrict Profiling. You may have the right to restrict the use of your Personal Data for the purposes of profiling.
Portability. You may have the right to obtain a copy of certain personal information in portable (e.g., machine readable) format.
Opt-out of Automated Decision-making. You may have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.
Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your California privacy rights, such that you will not be denied goods or services, charged a higher rate, or provided with lower quality products or services.

Exercising your rights under the California and other U.S. State Consumer Privacy Laws

You, or an authorized agent, may exercise your rights by submitting a request to our support team. Unless otherwise required by law, we will allow two disclosure requests per 12-month period at no cost to you. For subsequent requests, we may charge a fee if we determine that the request is excessive, repetitive, or manifestly unfounded, but will not do so without providing you with a cost estimate before processing your request.

We respond to legitimate privacy requests within 10 days of receipt and process requests within 45 days unless there is cause for an extension. We will notify you with further information if any extension is necessary. Except with respect to requests to “opt-out” of the sale or sharing of personal information, all privacy requests are subject to proper prior verification before processing. Typically, this means you will be required to verify certain pieces of information we maintain about you, such as name, phone number, date of birth, transaction details, or other information. Requests involving a high risk to personal information may require completion of a Sworn Declaration.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Do not sell or share my Personal Data

We may “sell” or “share,” and have sold or shared in the preceding 12-months, Personal Data, such as, email address, internet or electronic activity information, cookie data, and unique device identifiers, to referral partners and for targeted advertising purposes. You may exercise your right to opt-out of the sale and sharing of your personal information by using the methods provided below.

Opt-out of the sale and sharing of personal information or its use for targeted advertising

To opt-out of the sale of your Personal Data, please contact our support team.

To opt-out of the sharing of your Personal Data or its use for targeted advertising, you may toggle OFF all non-Necessary cookies in the Cookiebot Management Center.

Please note that your opt-out choices may apply only to this specific web browser and persist only until the opt-out Cookie is removed or “cleared” from your web browser, e.g., by clearing cookies in your browser settings.

California “Shine the Light” Law: Your Privacy Rights

We may share Personal Data (as defined by Cal. Civ. Code § 1798.83) including name and email address, with third parties, including our referral partners, for their direct marketing purposes. Please contact our support team to exercise your rights.

Do Not Track Signals

Under the California Online Privacy Protection Act (“CalOPPA”), we want to inform you about our “Do Not Track” (“DNT”) request policy. DNT is a feature that some web browsers offer to allow users to send signals to websites so that no information about their browser session will be shared. While we take all reasonable steps to protect your online privacy, we cannot promise that our current Services will address every browser setting or preference. In particular, we have not implemented the necessary programming changes to honor “DNT” browser signals. Please return to this Privacy Notice for further updates on this topic. You can learn more about DNT here: https://www.eff.org/issues/do-not-track

Opt-out preference signals

Our Services have been configured to respond to web browser universal opt-out mechanisms, including Global Privacy Control. While we are using industry-standard technologies to comply with universal opt-out mechanisms, given the newness of this technology, including potentially different protocols adopted by web browsers, we encourage you to double check that your opt-out requests are being properly processed by our Services and to notify us at support team if you believe that our Services are not responding to your browser request.

Sale of Personal Data under Nevada Law

We don’t sell Personal Data as defined by Nevada law.

Changes to this Privacy Policy

How to Contact Us or Our Privacy Office

In case of questions about the processing of your Personal Data please contact us at:

BPM Health Co.
ATTN: Privacy/Legal
77 Sands Street, 8th Floor
Brooklyn, NY 11201