PRIVACY POLICY
Last updated May 22, 2024
This privacy notice for Fitizen Inc ("Company," "we," "us," or "our"), describes how and why we might
collect, store, use, and/or share ("process") your information when you use our services ("Services"),
such as when you:
Download and use our mobile application (Fitizen), or any other application of ours that links to this
privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices.
If you do not agree with our policies and practices, please do not use our Services. If you still have any
questions or concerns, please contact us at info@fitizenapp.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these
topics by clicking the link following each key point or by using our table of contents below to find the section
you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you
interact with Fitizen Inc and the Services, the choices you make, and the products and features you use. Click
here to learn more.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your information for other
purposes with your consent. We process your information only when we have a valid legal reason to do so.
Click here to learn more.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties. Click here to learn
more.
How do we keep your information safe?
We have organizational and technical processes and procedures in place to protect your personal information.
However, no electronic transmission over the internet or information storage technology can be guaranteed to
be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Click here to learn more.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain
rights regarding your personal information. Click here to learn more.
How do you exercise your rights?
The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to learn more about what Fitizen Inc does with any information we collect? Click here to review the notice
in full.
TABLE OF CONTENTS
1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely on to Process Your Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. What Is Our Stance on Third-Party Websites?
6. Do We Use Cookies and Other Tracking Technologies?
7. How Long Do We Keep Your Information?
8. How Do We Keep Your Information Safe?
9. What Are Your Privacy Rights?
10. Controls for Do-Not-Track Features
11. Do California Residents Have Specific Privacy Rights?
12. Do Virginia Residents Have Specific Privacy Rights?
13. Do Vietnam Residents Have Specific Privacy
14. Do We Make Updates to This Notice?
15. How Can You Contact Us About This Notice?
16. How Can You Review, Update, or Delete the Data We Collect From You?
1. What Information Do We Collect?
Personal Information You Disclose to Us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Fitizen app, express
an interest in obtaining information about us or our products and services, participate in activities on the app, or
otherwise when you contact us.
Personal Information Provided by You
The personal information that we collect depends on the context of your interactions with us and the Fitizen
app, the choices you make, and the products and features you use. The personal information we collect may
include the following:
Name
Email address
Contact information
Profile information
Payment information
Geolocation data
Health and fitness data
Sensitive Information
We do not process sensitive information.
Payment Data
We may collect data necessary to process your payment if you make purchases, such as your payment
instrument number and the security code associated with your payment instrument. All payment data is stored
by Apple Pay and Google Pay. You may find their privacy notice links here:
Google Pay
Application Data
If you use our application(s), we may also collect the following information if you choose to provide us with
access or permission:
Mobile Device Access: We may request access or permission to certain features from your mobile
device, including your mobile device’s contacts, storage, and other features. If you wish to change our
access or permissions, you may do so in your device’s settings.
Mobile Device Data: We automatically collect device information (such as your mobile device ID,
model, and manufacturer), operating system, version information, and system configuration information,
device and application identification numbers, browser type and version, hardware model, Internet
service provider, and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you use
our application(s), we may also collect information about the phone network associated with your
mobile device, your mobile device’s operating system or platform, the type of mobile device you use,
your mobile device’s unique device ID, and information about the features of our application(s) you
accessed.
Push Notifications: We may request to send you push notifications regarding your account or certain
features of the application(s). If you wish to opt out of receiving these types of communications, you
may turn them off in your device’s settings.
This information is primarily needed to maintain the security and operation of our application(s), for
troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of
any changes to such personal information.
Information Automatically Collected
In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device
characteristics – is collected automatically when you visit our app.
We automatically collect certain information when you visit, use, or navigate the Fitizen app. This information
does not reveal your specific identity (like your name or contact information) but may include device and usage
information, such as your IP address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about how and when you use our
app, and other technical information. This information is primarily needed to maintain the security and
operation of our app, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our app and which we record in
log files. Depending on how you interact with us, this log data may include your IP address, device
information, browser type, and settings and information about your activity in the app (such as the
date/time stamps associated with your usage, pages and files viewed, searches, and other actions you
take such as which features you use), device event information (such as system activity, error reports
(sometimes called “crash dumps”), and hardware settings).
Device Data: We collect device data such as information about your computer, phone, tablet, or other
device you use to access the app. Depending on the device used, this device data may include
information such as your IP address (or proxy server), device and application identification numbers,
location, browser type, hardware model, Internet service provider, mobile carrier, operating system, and
system configuration information.
Location Data: We collect location data such as information about your device’s location, which can be
either precise or imprecise. How much information we collect depends on the type of settings of the
device you use to access the app. For example, we may use GPS and other technologies to collect
geolocation data that tells us your current location (based on your IP address). You can opt out of
allowing us to collect this information either by refusing access to the information or by disabling your
Location setting on your device. Note, however, if you choose to opt out, you may not be able to use
certain aspects of the app.
2. How Do We Process Your Information?
In Short: We process your information to provide, improve, and administer our services, communicate with
you, ensure security and fraud prevention, and comply with legal requirements. We may also process your
information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with the Fitizen
app, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may
process your information so you can create and log in to your account, as well as keep your account in
working order.
To deliver and facilitate delivery of services to the user. We may process your information to
provide you with the requested service.
To fulfill and manage your orders. We may process your information to fulfill and manage your
orders, payments, returns, and exchanges made through the Fitizen app.
To enable user-to-user communications. We may process your information if you choose to use any
of our offerings that allow for communication with another user.
To deliver targeted advertising to you. We may process your information to develop and display
personalized content and advertising tailored to your interests, location, and more.
To protect our services. We may process your information as part of our efforts to keep our services
safe and secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our services to better
understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process
your information to better understand how to provide marketing and promotional campaigns that are
most relevant to you.
To save or protect an individual's vital interest. We may process your information when necessary
to save or protect an individual's vital interest, such as to prevent harm.
3. What Legal Bases Do We Rely on to Process Your Information?
In Short: We only process your personal information when we believe it is necessary and we have a valid
legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with laws, to
provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU, UK, or Southeast Asia, this section applies to you.
The General Data Protection Regulation (GDPR) and similar regulations in Southeast Asia require us to
explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:
Consent
We may process your information if you have given us permission (i.e., consent) to use your personal
information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
Performance of a Contract
We may process your personal information when we believe it is necessary to fulfill our contractual obligations
to you, including providing our services or products, or at your request prior to entering into a contract with you.
Legitimate Interests
We may process your information where we believe it is reasonably necessary to achieve our legitimate
business interests and those interests do not outweigh your fundamental rights and freedoms. For example,
we may process your personal information for some of the purposes described in order to:
Develop and display personalized content and advertising for our users
Analyze how our services are used so we can improve them to engage and retain users
Support our marketing activities
Diagnose problems and/or prevent fraudulent activities
Legal Obligations
We may process your information where we believe it is necessary for compliance with our legal obligations,
such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or
disclose your information as evidence in litigation in which we are involved.
Vital Interests
We may process your information where we believe it is necessary to protect your vital interests or the vital
interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Southeast Asia, including Vietnam, this section applies to you.
In addition to the GDPR, we also comply with applicable digital privacy laws and regulations in Southeast Asia,
including the Law on Cybersecurity and the Law on Information Technology in Vietnam. These laws require us
to ensure the security and confidentiality of personal information and to protect the rights of individuals in
relation to their personal data. We may process your information based on the following legal bases:
Consent
We may process your information if you have given us explicit consent to use your personal information for a
specific purpose. You can withdraw your consent at any time.
Performance of a Contract
We may process your information to fulfill our contractual obligations to you, such as providing our services or
products.
Legal Obligations
We may process your information to comply with our legal obligations under the laws of Vietnam and other
Southeast Asian countries, including responding to requests from government authorities and ensuring data
security.
Legitimate Interests
We may process your information to pursue our legitimate business interests, provided these interests do not
override your fundamental rights and freedoms.
Vital Interests
We may process your information to protect your vital interests or those of another person, especially in
emergency situations.
Public Interest
We may process your information when it is necessary for the performance of a task carried out in the public
interest or in the exercise of official authority vested in us.
In some exceptional cases, we may be legally permitted under applicable law to process your information
without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an
insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial
abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the
accuracy of the information and the collection is reasonable for purposes related to investigating a
breach of an agreement or a contravention of the laws of Vietnam or other applicable jurisdictions
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to
the production of records
If it was produced by an individual in the course of their employment, business, or profession and the
collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. When and With Whom Do We Share Your Personal Information?
In Short: We may share information in specific situations described in this section and/or with the following
categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers
We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who
perform services for us or on our behalf and require access to such information to do that work. We have
contracts in place with our third parties, which are designed to help safeguard your personal information. This
means that they cannot do anything with your personal information unless we have instructed them to do it.
They will also not share your personal information with any organization apart from us. They also commit to
protecting the data they hold on our behalf and to retain it for the period we instruct. The categories of third
parties we may share personal information with are as follows:
Ad Networks
Cloud Computing Services
Payment Processors
Website Hosting Service Providers
Business Transfers
We may share or transfer your 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.
Business Partners
We may share your information with our business partners to offer you certain products, services, or
promotions.
Offer Walls
Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers
to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an
advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on
certain data, such as your geographic area or demographic information. When you click on an offer wall, you
will be brought to an external website belonging to other persons and will leave our application(s). A unique
identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly
credit your account with the relevant reward.
5. What Is Our Stance on Third-Party Websites?
In Short: We are not responsible for the safety of any information that you share with third parties that we may
link to or who advertise on our Services, but are not affiliated with, our services.
The Fitizen app, including our offer wall, may link to third-party websites, online services, or mobile applications
and/or contain advertisements from third parties that are not affiliated with us and which may link to other
websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third
parties, and we will not be liable for any loss or damage caused by the use of such third-party websites,
services, or applications. The inclusion of a link towards a third-party website, service, or application does not
imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third
parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the
content or privacy and security practices and policies of any third parties, including other websites, services, or
applications that may be linked to or from the Fitizen app. You should review the policies of such third parties
and contact them directly to respond to your questions.
6. Do We Use Cookies and Other Tracking Technologies?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and how you can refuse certain cookies
is set out in our Cookie Notice.
7. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy
notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this
privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or
other legal requirements). No purposes in this notice will require us keeping your personal information for
longer than six (6) months past the termination of the user’s account.
When we have no ongoing legitimate business need to process your personal information, we will either delete
or anonymize such information, or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal information and isolate it from any
further processing until deletion is possible.
8. How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical
security measures.
We have implemented appropriate technical and organizational security measures designed to protect the
security of any personal information we process. However, despite our safeguards and efforts to secure your
information, no electronic transmission over the Internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information, transmission of personal
information to and from the Fitizen app is at your own risk. You should only access the services within a secure
environment.
9. What Are Your Privacy Rights?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Canada, and
Southeast Asia, including Vietnam, you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Canada, and Southeast Asia), you have certain rights under applicable
data protection laws. These may include the right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information,
and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by contacting us by using the contact
details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA, UK, or Southeast Asia, and you believe we are unlawfully processing your
personal information, you also have the right to complain to your local data protection supervisory authority.
For the EEA, you can find their contact details here: https://ec.europa.eu/justice/data-
protection/bodies/authorities/index_en.htm.
If you are located in Vietnam, you can contact the Ministry of Information and Communications, which
oversees data protection regulations.
Withdrawing Your Consent
If we are relying on your consent to process your personal information, which may be express and/or implied
consent depending on the applicable law, you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when
applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you
can:
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from
our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal
requirements.
Cookies and Similar Technologies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your
browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could
affect certain features or services of our services. To opt out of interest-based advertising by advertisers on our
services, visit https://optout.aboutads.info/.
If you have questions or comments about your privacy rights, you may email us at info@fitizenapp.com.
10. Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track
(“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online
browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or
any other mechanism that automatically communicates your choice not to be tracked online. If a standard for
online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
11. Do California Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your
personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are
California residents to request and obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the
names and addresses of all third parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would like to make such a request, please submit
your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Fitizen, you have the
right to request removal of unwanted data that you publicly post on the services. To request removal of such
data, please contact us using the contact information provided below and include the email address associated
with your account and a statement that you reside in California. We will make sure the data is not publicly
displayed on the services, but please be aware that the data may not be completely or comprehensively
removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as: (1) Every individual who is in the State of California
for other than a temporary or transitory purpose and (2) Every individual who is domiciled in the State of
California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your
personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real name, alias, postal address,
telephone or mobile contact number, unique personal identifier,
online identifier, Internet Protocol address, email address, and
account name
YES
B. Personal information
categories listed in the California
Customer Records statute
Name, contact information, education, employment,
employment history, and financial information
YES
C. Protected classification
characteristics under California
or federal law
Gender and date of birth
NO
Category
Examples
Collected
D. Commercial information
Transaction information, purchase history, financial details, and
payment information
YES
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar
network activity
Browsing history, search history, online behavior, interest data,
and interactions with our other websites, applications, systems,
and advertisements
NO
G. Geolocation data
Device location
YES
H. Audio, electronic, visual,
thermal, olfactory, or similar
information
Images and audio, video or call recordings created in
connection with our business activities
NO
I. Professional or employment-
related information
Business contact details in order to provide you our services at
a business level or job title, work history, and professional
qualifications if you apply for a job with us
NO
J. Education Information
Student records and directory information
NO
K. Inferences drawn from other
personal information
Inferences drawn from any of the collected personal information
listed above to create a profile or summary about, for example,
an individual’s preferences and characteristics
NO
L. Sensitive Personal
Information
NO
We will use and retain the collected personal information as needed to provide the services or for:
Category A - 6 months
Category B - 6 months
Category D - 6 months
Category G - 6 months
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we
will respect your request and delete your personal information, subject to certain exceptions provided by law,
such as (but not limited to) compliance with a legal obligation, or as may be required to protect against illegal
activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business
purpose; and
the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-
identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about
whom we have the information in our system. These verification efforts require you to provide information so
that we can match it with the information you have previously provided us. For instance, depending on the type
of request you submit, we may ask you to provide certain information so that we can match the information you
provide with the information we already have on file, or we may contact you through a communication method
(e.g., phone or email) that you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the
request. To the extent possible, we will avoid requesting additional information from you for the purposes of
verification. If, however, we cannot verify your identity from the information already maintained by us, we may
request that you provide additional information for the purpose of verifying your identity and for security or
fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying
you.
Other privacy rights
you may object to the processing of your personal information
you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict
the processing of the information
you can designate an authorized agent to make a request under the CCPA on your behalf. We may
deny a request from an authorized agent that does not submit proof that they have been validly
authorized to act on your behalf in accordance with the CCPA.
you may request to opt out from future selling of your personal information to third parties. Upon
receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than
15 days from the date of the request submission.
To exercise these rights, you can contact us by email at info@fitizenapp.com, or by referring to the contact
details at the bottom of this document. If you have a complaint about how we handle your data, we would like
to hear from you.
We will use and retain the collected personal information as needed to provide the services or for:
Category A - As long as the user has an account with us
Category B - As long as the user has an account with us
Category D - As long as the user has an account with us
Category G - As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you
interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in surveys or contests; and
Facilitation in the delivery of our services and to respond to your inquiries.
How do we use and share your personal information?
Fitizen collects and shares your personal information through:
Targeting cookies/Marketing cookies
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at info@fitizenapp.com, or by referring to the contact details at the bottom of this
document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized
agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between
us and each service provider. Each service provider is a for-profit entity that processes the information on our
behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal
research for technological development and demonstration. This is not considered to be "selling" of your
personal information.
Fitizen has not sold or shared any personal information to third parties for a business or commercial purpose in
the preceding twelve (12) months. Fitizen has disclosed the following categories of personal information to
third parties for a business or commercial purpose in the preceding twelve (12) months:
Category A. Identifiers
Category B. Personal information categories listed in the California Customer Records statute
Category D. Commercial information
Category G. Geolocation data
The categories of third parties to whom we disclosed personal information for a business or commercial
purpose can be found under WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we
will respect your request and delete your personal information, subject to certain exceptions provided by law,
such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be required to protect against illegal
activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a
business purpose; and
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-
identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer’s sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about
whom we have the information in our system. These verification efforts require you to provide information so
that we can match it with information you have previously provided us. For instance, depending on the type of
request you submit, we may ask you to provide certain information so that we can match the information you
provide with the information we already have on file, or we may contact you through a communication method
(e.g., phone or email) that you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the
request. To the extent possible, we will avoid requesting additional information from you for the purposes of
verification. However, if we cannot verify your identity from the information already maintained by us, we may
request that you provide additional information for the purpose of verifying your identity and for security or
fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying
you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict
the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may
deny a request from an authorized agent that does not submit proof that they have been validly
authorized to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties.
Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no
later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at info@fitizenapp.com, or by referring to the contact
details at the bottom of this document. If you have a complaint about how we handle your data, we would like
to hear from you.
12. Do Virginia Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use
of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or
household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable
natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your
personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with Fitizen
and our Services. To find out more, please visit the following links:
Personal data we collect
How we use personal data
When and with whom we share your personal data
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt-out of the processing of personal data if it is used for targeted advertising, the sale
of personal data, or profiling in furtherance of decisions that produce legal or similarly
significant effects ("profiling")
Fitizen has not sold personal data to third parties for business or commercial purposes. Fitizen will not sell
personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at info@fitizenapp.com or by referring to the contact details at the bottom of this
document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent
does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your
consumer’s request. If you submit the request through an authorized agent, we may need to collect additional
information to verify your identity before processing your request.
Upon receiving your request, we will respond within forty-five (45) days of receipt. The response period may be
extended once by an additional forty-five (45) days when reasonably necessary. We will inform you of any
such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it.
If you wish to appeal our decision, please email us at info@fitizenapp.com. Within sixty (60) days of receipt of
an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney
General to submit a complaint.
13. Do Vietnam Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of Vietnam, you may be granted specific rights regarding access to and use
of your personal information under the Law on Cybersecurity and the Law on Information Technology.
Vietnam Privacy Notice
Under the Law on Cybersecurity and the Law on Information Technology:
"Personal data" refers to any information that is linked or reasonably linkable to an identified or identifiable
natural person. This includes data that is collected, processed, stored, and shared by electronic means.
If you are a resident of Vietnam, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to withdraw consent to the processing of your personal data
Right to restrict or object to the processing of your personal data
Exercise your rights provided under Vietnam's privacy laws
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at info@fitizenapp.com, or by referring to the contact details at the bottom of this
document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent
does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your
consumer’s request. If you submit the request through an authorized agent, we may need to collect additional
information to verify your identity before processing your request.
Upon receiving your request, we will respond within the timeframes specified by the applicable laws. We will
inform you of any extensions or delays in our response and provide the reason for the delay.
14. Do We Make Updates to This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated
"Revised" date and the updated version will be effective as soon as it is accessible. If we make material
changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of
how we are protecting your information.
15. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), by
email at info@fitizenapp.com, or by post to:
Fitizen Data Protection Officer 123 Fitness Commons Ct. Suite 124 Hanoi, Vietnam
16. How Can You Review, Update, or Delete the Data We Collect From You?
Based on the applicable laws of your country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it. To request to review, update, or delete
your personal information, please fill out and submit a data subject access request form.
