Privacy policy

PRIVACY POLICY Updated: January 2024

Preamble

★ What are we talking about?

Personal data (or personally identifiable information) refers to all information that allows your direct or indirect identification.

For example, personal data includes your contact details (e.g., name, surname, postal address), as well as your location, an identifier number (e.g., IP address), a photograph, etc.

In this regard, this Privacy Policy applies only to individuals, hereinafter referred to as "Users".

These Users benefit from various features for nutrition advice, sports activities, emotional management, and personalized assessments, offered by Platinum Age Management through its platform (mobile - iOS and Android - and web), hereinafter referred to as "Services".

At Platinum Age Management, we only collect personal data that is strictly necessary for the fulfillment of specific, explicit, and legitimate purposes. The purpose of this Privacy Policy is to describe how we proceed.

★ What regulations apply?

This Privacy Policy is mainly based on two texts:

- Monaco Law No. 1.165 of December 23, 1993, concerning the protection of personally identifiable information, hereinafter referred to as the "Monaco Law";

- Regulation (EU) 2016/679 of April 27, 2016, hereinafter referred to as the "GDPR";



  1. Data Controller

In accordance with regulations, the data controller is the entity that determines the purposes and means of processing.

In the context of this Privacy Policy, the data controller is:

Platinum Age Management SARL

18 Avenue de Grande Bretagne

98000 Monaco

RCI Monaco: 23S09613

 

  1. Processed Personal Data

 

★ Which of my personal data are processed?

- Categories of processed data

The processed data include, on the one hand, the information that the User will provide to access the Services, and on the other hand, the information automatically recorded by the application during the use of the Services.

  • User identification data: name, surname, date of birth, and gender.
  • Contact details: email address, postal address, phone number.
  • Nutritional data.
  • Morphological data.
  • Physiological data, including weight.
  • Data related to the use of Services: information related to goals pursued, analysis and history of training, or results obtained.

 

  • Connection data: information regarding your use of the Services, including access dates and times, duration and frequency of visits, characteristics of subscribed Services, indication of the browser used, dates and times, and duration and frequency of connection.

The User is expressly informed that the nutritional, morphological, and physiological data collected and processed in the context of the use of the Services may be considered as "health data" within the meaning of Article 12 of the Monaco Law, or "health-related data" within the meaning of Article 9 of the GDPR. By subscribing to the Services, the User gives explicit and prior consent to the processing of this data, through a checkbox provided for this purpose. The User is also informed that they have the option to withdraw their consent at any time and to exercise their right to erasure of their data (see Article 4 of this Privacy Policy).

- Mandatory nature of data collection

The collection of data is mandatory if this data is necessary to access the Services. The collection is optional if it involves the consent of users.

 

  1. Processing Modalities of Your Personal Data

★ What are the purposes of processing your data?

When you browse our site or use our Services, your data may be processed for the following purposes:

➔ Contract and customer account management. Under this purpose, the User may:

  • Request a "demo".
  • Subscribe to a commercial offer.
  • Create and manage a User profile.

This processing is necessary for the performance of the contract or pre-contractual measures taken at the request of the User.

 

➔ Monitoring of nutritional, sports, and emotional activity. Under this purpose, the User may:

- Benefit from secure access to the platform and use the programs offered by Platinum Age Management.

This processing is necessary for the performance of the contract or pre-contractual measures taken at the request of the User.

➔ Improving access to Services. Under this purpose, the User may:

- Access the Services via their Apple account.

- Access the Services via connected devices (e.g., watches, fitness devices) subject to compatibility.

This processing is based on the legitimate interest of Platinum Age Management, consisting of allowing each User to benefit from facilitated access to the Services.

➔ Payment and invoice management, and accounting.

This processing is in response to a legal obligation.

➔ Informing Users about our news (newsletter).

This processing is based on the legitimate interest of Platinum Age Management, consisting of informing Users about the various developments related to its development.

➔ Commercial prospecting by electronic means and personalization of advertising content.

This processing is based on the consent of the User.

➔ Conducting satisfaction surveys and customer studies: surveys, product tests, sales statistics, and organization of competitions.

This processing is based on the legitimate interest of Platinum Age Management, consisting of the continuous improvement of our Services.

 

➔ Pre-litigation and litigation management.

This processing is based on the legitimate interest of Platinum Age Management, consisting of establishing the proof of a right or contract.

How do we collect your data?

We collect your data through your own browsing or use of the Platinum Age Management platform (direct collection).

When the personal data that we invite you to provide to us is necessary to access or use the Services (e.g., recording performance to ensure tracking), the requirement to provide this data is contractual. If you do not comply, you may not be able to access or use the Services.

★ Are your data transmitted to third parties?

Platinum Age Management undertakes not to transmit your personal data in any form to third parties who are not on the following list of recipients:

  • Authorized employees and officers of Platinum Age Management;
  • Service providers of Platinum Age Management for the organization and execution of Services;
  • To any third party, upon court order or administrative or regulatory authority.

In this context, the service providers concerned are those responsible for the following missions: white-label software solutions consisting of providing application functionalities, connected equipment, and application hosting.

★ Are your data transferred outside the Principality?

Some personal data that we collect may be transferred outside the Principality, where some of our subcontractors or partners may be located.

In any case, Platinum Age Management ensures that any transfer of personal data outside the Principality is (i) made to a country or organization that has an adequate level of protection within the meaning of Article 20 of the Monaco Law, or (ii) framed by sufficient guarantees ensuring compliance with the protection of fundamental freedoms and rights of the persons concerned, as well as the exercise of corresponding rights by the concerned recipients, in accordance with the provisions of Article 20-1 of the Monaco Law.

★ How long are your data kept?

We keep your personal data until the purposes for which they were collected are achieved.

If you are not yet a customer, your personal data may be kept until you withdraw your consent to receive commercial prospecting, and up to 3 (three) years from the last commercial contact with us (e.g., when you click on an offer that we address to you).

If you are a customer, your personal data may be kept up to 5 (five) years from the closing of the accounting period of Platinum Age Management following the end of the contractual relationship, in intermediate archiving