Lupa Privacy Policy.
Privacy Policy
Introduction
Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our websites and the related mobile applications and services (collectively, the “Services”). Please also read our Terms of Service which sets out the terms governing the Services.
Lupa is headquartered in London and our Services are provided to you by Lupa Run Ltd. If you are a resident of the European Economic Area (“EEA”), Lupa Run Ltd is the controller of your personal data for the purposes of EEA data protection law.
This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.
Lupa Run Ltd.
Flat 38 Tudor Court,
King Henry’s Walk,
N1 4NT
London
UK
Information Lupa Collects
Lupa collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with Lupa. We receive information in a few different ways, including when you track, complete or upload activities using the Services. Lupa also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with Lupa. For example:
Account, Profile, Activity, and Use Information
We collect basic account information such as your name, email address, date of birth, gender, username and password that helps secure and provide you with access to our Services.
Profile, activity and use information is collected about you when you choose to upload a picture, activity (including date, time and geo-location information as well as your speed and pace and perceived exertion) or post, join a challenge, add your equipment usage, view others’ activities, or otherwise use the Services.
We use your contact information so we can respond to your support requests and comments.
Location Information
We collect and process location information when you sign up for and use the Services. We do not track your device location while you are not using Lupa, but in order to provide Lupa’s core Services, it is necessary for us to track your device location while you use Lupa. If you would like to stop the device location tracking, you may do so at any time by adjusting your device settings.
Content You Share
We gather information from the content you share on the Services, including when you participate in partner events.
Contacts Information
You can choose to add your contacts’ information by connecting your contacts from your mobile device or social networking accounts to Lupa. If you choose to share your contacts with Lupa, Lupa will, in accordance with your instructions, access and store your contacts’ information in order to identify connections and help you connect with them.
Connected Devices and Apps
Lupa collects information from devices and apps you connect to Lupa. For example, you may connect your Garmin watch or Flywheel account to Lupa and information from these devices and apps will be passed along to Lupa.
Health Information
Lupa may collect or infer health information. Certain health information may be inferred from sources such as heart rate or other measurements, including power, cadence, and weight or other indicators. Before you can upload health information to Lupa, you must give your explicit consent to the processing of that health information by Lupa. You can withdraw your consent to Lupa processing your health information at any time.
Third-Party Accounts
Lupa allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook, Google, or Apple (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences. This information is collected by the Third-Party Account provider and is provided to Lupa under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.
Technical Information and Log Files
We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information.
The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to session IDs, athlete IDs and device identifiers.
Other Information
We may collect information from you through third parties, such as when we collect your feedback through surveys.
We may also collect information about you from other members such as when they give you kudos or comment on your activities.
How Lupa Uses Information
Lupa uses the information we collect and receive to operate the Services and to customize them for you. For example, with your consent we use your heart rate information to provide you with interesting and useful performance analysis. Subject to your privacy controls, your information, including parts of your profile, username, photos, members you follow and who follow you, clubs you belong to, your activities, the devices you use, and kudos and comments you give and receive will be shared on Lupa so that you may be able to participate in the Services, for example to show your place on a leaderboard. Certain information (e.g., your name, and some profile information) is also available to non-members on the web. Your precise location information, such as a route or segment, may also be shared on Lupa or to non-members, in accordance with your privacy controls.
We use the information we collect about you, your followers, and your activities to customize your experience. For example, we may suggest segments, routes, challenges, or clubs that may interest you, or athletes that you may want to follow. We also use the information we collect to process payments, provide support related to the Services, protect members and enforce our Terms of Service, promote safety, and to communicate with you (including to send marketing and push communications) where you have not opted out of receiving such messages and notifications.
We also use the information we collect to analyze, develop and improve the Services. To do this, Lupa may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services.
We may also use the information we collect to market and promote the Services, activities on Lupa, and other commercial products or services. This includes customizing your Lupa experience. For example, if we know that you like to run, we may tell you about new running activities or show you sponsored content related to running. If we see that you run in a certain area, we may suggest a race in that area. Subject to your settings, we may also mention that you have used our partners’ products or services as part of your activities, which we refer to as Partner Integrations.
Aggregate Information
We do not sell your personal information. Lupa may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. Examples of the type of information we may aggregate include information about equipment, usage, demographics, routes and performance. Lupa may use, sell, license, and share this aggregated information with third parties for research, business or other purposes such as to improve walking, running or riding in cities or to help our partners understand more about athletes, including the people who use their products and services.
How Information is Shared
In addition to sharing aggregated data about our members as described above, we also share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below.
Service Providers
We may share your information with third parties who provide services to Lupa such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote Lupa or display information that may be relevant to your interests on the Services or other websites or services.
Publicly Available Information
When you join the Lupa community, your profile and your activities are set to be viewable by everyone by default. Your name and other profile information is viewable by other Lupa members and the public and, subject to your privacy controls, additional information and content you share may also be viewable. For example, your photos and routes may be accessed by other Lupa members and non-members or viewable on publicly accessible Lupa pages. We provide an array of settings to control the sharing of your information and encourage our members to adjust their controls to align with their desired experience.
Sharing Information and Activities
As a social network, we share your information with other Lupa members and the public in accordance with your privacy controls. You can change the visibility of the activities you upload to Lupa. You can also share your activities with your contacts via text, email, or on social media applications like Facebook, Instagram, and Twitter. If you link your Lupa account to other social networks and share your activities, they will be viewable on such third-party platforms, including your location information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties.
Third Party Business via API or Other Integrations
We enable you to share your information and content with third party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with Lupa to offer an integrated feature, such as a challenge sponsor or tracking watch. You can choose to share your profile data and activity data (including private activities). If you click on the link for a sponsored integration, you will leave our platform and the sponsor may be able to identify that you visited their platform from Lupa. Information collected by these third parties is subject to their terms and policies. Lupa is not responsible for the terms or policies of third parties.
Affiliates and Acquirors of our Business or Assets
We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Lupa becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction.
Legal Requirements
We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of Lupa or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.
How We Protect Information
We take several measures to safeguard the collection, transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity.
Managing Your Settings
Privacy Controls
Lupa offers several features and settings to help you manage your privacy and share your activities.
Adjust Notification and Email Preferences
Lupa offers various ways to manage the notifications you receive. You can choose to stop receiving certain emails and notifications by indicating your preference. You may also unsubscribe by following the instructions contained at the bottom of each email. Any administrative or service-related emails (to confirm a purchase, or an update to this Privacy Policy or our Terms of Service, etc.) generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.
Updating Account Information
You may correct, amend or update profile or account information at any time by adjusting that information in your account settings.
Deleting Information and Accounts and Downloading Your Data
You can delete your account. After you make a deletion request, we permanently and irreversibly delete your personal data from our systems, including backups. Once deleted, your data cannot be reinstated. Following your deletion of your account, it may take up to 90 days to delete your personal information and system logs from our systems. Additionally, we may retain information where deletion requests are made to comply with the law and take other actions permitted by law.
Note that content you have shared with others, such as photos, or that others have copied may also remain visible after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.
Your Rights and Our Legal Bases
We provide the same suite of privacy tools and controls to all of our members worldwide.
Your Legal Rights in the EEA
If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information.
Our Legal Bases
Lupa relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:
as necessary to provide the Services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide the Services unless we collect and use your location information;
where you have consented to the processing;
where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
to protect your vital interests, or those of others, such as in the case of emergencies; and
where necessary for the purposes of Lupa’s or a third party’s legitimate interests, such as our interests in protecting our members, our partners’ interests in collaborating with our members, and our commercial interests in ensuring the sustainability of the Services.
Transfers
The Services are operated from the United Kingdom. If you are located outside of the United Kingdom and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in the United Kingdom, as it is necessary to provide the Services and perform the Terms of Service. United Kingdom privacy laws may not be as protective as those in your jurisdiction.
Retention of Information
We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account. For example, where you withdraw your consent to Lupa processing your health-related information, Lupa will delete all health-related information you uploaded. Following your deletion of your account, it may take up to 90 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information where deletion requests are made to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.
Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Lupa, such as statistics of the use of the Services. For example, we may retain publicly available segments or routes and other depersonalized geolocation information to continue to improve the Services and we use aggregated information in Lupa Metro and our Global Heatmap. This information will be de-associated with your name and other identifiers.
Privacy Policy Information
Lupa reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Lupa makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.