PROJECT WELLBEING
PRIVACY POLICY

Last Updated on March 1, 2023

YOUR PRIVACY: OVERVIEW 
If you are a consumer in the United States, this privacy policy ("Privacy Policy") explains how Project Wellbeing LLC and our subsidiaries and affiliated companies, (collectively, "Project Wellbeing," "we," or "us,") collect, use, process, disclose, and retain your personal data when you access or use our websites, mobile applications, Project Wellbeing Wellness Center, and any other applications, products, or services that display this Privacy Policy (collectively, the “Services”). This Privacy Policy also applies to personal data we collect when you shop or use services at our facility, register for and attend our events, engage with us on social media, join a membership program, or otherwise interact with us.
Please review this Privacy Policy carefully. Note that we may provide different or additional privacy notices in connection with certain activities, programs, and offerings. These notices may supplement or clarify our privacy practices and may provide you with additional choices about how we process your personal data. 
REVISIONS TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you with additional notice (such as adding a statement to our websites’ homepages or sending you a notification, if applicable). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
By interacting with Project Wellbeing through your use of our Site or Wellness Center and facilities, you expressly and directly consent and agree to the practices set forth below.
TABLE OF CONTENTS
COLLECTION OF PERSONAL DATA
USE OF PERSONAL DATA
DISCLOSURE OF PERSONAL DATA
TARGETED ADVERTISING AND ANALYTICS
DATA TRANSFERS
CHILDREN’S PRIVACY
THIRD PARTY SITES
YOUR PRIVACY RIGHTS AND CHOICES
CONTACT US

COLLECTION OF PERSONAL DATA
In this Privacy Policy, "personal data" means any information that is related to an identified or reasonably identifiable natural person, or as otherwise defined under applicable law. The types of personal data we collect about you depend on your interactions with us. In this section, we describe the categories of personal data we collect and the sources of this data.
PERSONAL DATA YOU PROVIDE TO PROJECT WELLBEING
We collect personal data directly from you when you purchase our products, use our services, or otherwise interact with us, including:
Personal Information. We collect information with content you provide to us in connection with an account or profile, such as when you register for an account, create a profile, participate in our membership programs, fill out a form, or use the Project Wellbeing wellness centers and facilities. Examples of profile data we may collect include, without limitation: your name, email address, phone number, mailing address, date of birth, account login name and password, ID, credit card information, emergency contact, height, weight, health and wellness information (including, without limitation, health conditions, labs and lab results, metabolic conditions, and information shared with your provider or fitness specialist); fitness and exercise activity data (such as heart rate, watts or power, RPM or cadence, and similar metrics); fitness assessments, body measurements, equipment you own, activity preference, injuries, physical limitations, clothing and shoe size, hobbies, interests, business name, preferred language, dietary restrictions, allergies, Images (including photographs and video), audio recordings, and sounds; social media handles, and services you attend in connection with our membership programs, Your responses to our marketing or operational communications (such as your interests, or responses to surveys, questionnaires, sweepstakes, or contests); Information you disclose in public forums or submit, transmit, message, upload, share, or otherwise make available, publicly or privately, including in online classes, discussion boards or forums, training sessions or events, messages, comments, searches, or queries, including, without limitation, through the use of our Site.
Demographic Data. We may collect demographic data when you fill out forms or surveys or sign up for and participate in events, contests, sweepstakes, promotions, and special programs that we provide. Examples of such information include age and gender.
Transaction Data. We collect transaction information related to the products and services you purchase from us. Examples of information collected include the type of products or services requested or provided, order details, delivery information, amount charged, payment method, billing or shipping information, government-issued identification card (for returns only), and information about any products or services you returned or exchanged with us. If you make a purchase, we work with third-party payment processors to collect and process your payment information.
Communications Data. We collect information when you communicate with us or others on our Services, such as when you request additional information about products or services, interact with our customer service team or providers, or sign up to receive our email newsletters or marketing messages. We also collect communications data when you interact with us on social media, such as by tagging us and/or our products or permitting us to follow your social media profile. Examples of such data may include your contact information, the date and time of your communications, online identifiers, social media profile, and the content of your communications.
User Content. We collect any other information or content you provide to us, such as when you rate workouts, provide design or product feedback, make other submissions to us, participate in any of our events, or use other features of our Services that may be offered from time to time, which may require the collection of certain personal data in order to utilize the features. Examples of user content may include information about your goals, opinions, feedback, preferences, text, images, and any other personal data you choose to provide in your interactions with us.
Employment Applications. We collect Personal Information such as your name, address, e-mail, and phone number when you apply for employment with us. In addition, we may collect information relating to your education and employment history when you submit that information as part of an employment application. 
PERSONAL DATA WE COLLECT AUTOMATICALLY
We automatically collect certain personal data when you access and use our Services or shop at our facilities. The types of information we collect may include:
Usage Data. We collect information about your activity on our Services via log files, cookies, web beacons such as Google Analytics, and other tracking technologies. Examples of such data include your access dates and times, pages or screens viewed, how long you spent on a page or screen, the routes by which you access our Services, searches you conduct on the Services, information about your activity on a page or screen, app crashes and other system activity, your use of any hyperlinks available within our Services, information about your interactions with our emails, your Internet service provider (ISP), Mobile Advertising ID, media access control (MAC) address, and identifiers associated with browser cookies, web beacons, and similar technologies we deploy on our Services.

Audio, Video or Sensory Data. We collect audio, video, or sensory information from you. Examples of such data include video recordings when you visit our facilities.

Location Data. We collect information about your precise or approximate location information in accordance with your device permissions. You may use our Services without enabling us to collect location data from your device, however, this may affect some functionality available in the Services. We may also use technology at our facilities to collect data about the presence of your device.

Activity Data. When you use Project Wellbeing wellness centers and facilities, we may collect activity data, such as information about how your body moves, including audio and video recordings of your workout and how you position and move your head, arms, hands, feet, legs, and torso. We may also collect workout history and metrics data, including your heart rate, fitness performance history, and achievements.

How We Use Geolocation. When Using our App, Project Wellbeing will request permission to obtain your location to better provide you with location-specific information, including, but not limited to, facility hours, check-in prompts, and promotions. In that case, the App will utilize location services on your mobile device to collect and use location data, including the real-time geographic location of your device. If you consent to the App’s utilization of location services, we may use GPS, Bluetooth, your device’s unique identifier, and/or your IP Address, along with Wi-Fi and cell tower locations, and other technologies to determine your device’s geolocation. We maintain location data records for as long as necessary to deliver the services you request. We will collect geolocation data only if you consent, and you may choose in your App settings whether the location services will be always running or only when the App is in use. You may also choose to disable location services through our App in the “Settings” function of your mobile device, but if you do so, you will not receive any notifications or services that require a geolocation. You can also contact your mobile service carrier or your device manufacturer for more information on disabling location services.
PERSONAL DATA WE COLLECT FROM OTHER SOURCES
We may collect personal data about you from other sources. For example, we may collect personal data about you from:
Third-party providers of online booking tools when you sign up for and participate in services or events offered or sponsored by Project Wellbeing;
Our members, including when they bring you as a guest to one of our events, or if they list you as an emergency contact;

Third parties hosting events, including those sponsored by Project Wellbeing, when they provide event attendance or participation information to us;

Other guests or third parties, including when they provide information in connection with a dispute;

Carriers or other third parties when they provide your updated delivery and address information to us, which we use to correct our records and deliver your next purchase or communication;

Third-party platforms, such as Facebook, Twitter, Google, Spotify, Apple Health, Trainerize, Mindbody, and Instagram, that you use to interact with our Services (e.g., to create an account) or that allow you to provide information to us (e.g., via plugins, widgets or other tools), but always in accordance with the authorization procedures and privacy settings you establish with such services; and

Unaffiliated parties, such as our service providers, analytics companies, marketing or advertising service providers, fraud prevention service providers, consumer data resellers, and other third parties that provide us with information, so we can better understand you and provide you with information and offers that may be of interest to you.
PERSONAL DATA WE DERIVE
We may derive information or draw inferences about you based on the other types of personal data we collect. For example, we may infer your location based on your IP address, or your purchasing habits based on your browsing behavior on our Services.
USE OF PERSONAL DATA 
We collect and use personal data for various purposes, including to:

Provide Goods and Services. Provide, administer, deliver, customize, support, maintain, and improve our products, events, services, and membership programs;

Improving the Site, goods, and services. Including through statistical and other analysis;

Complete Transactions. Complete the transactions you request, perform our contractual obligations, including processing payments through third-party vendors, and as otherwise anticipated within the context of our ongoing business relationship;

Manage Accounts. Create and manage your online accounts, profiles, and membership programs;
Customer Service Communications. Send communications related to your account, participation in membership programs, purchases, exchanges, and returns;

Respond to You. Respond to your requests and any other communications from you, including to provide customer service;

Advertising and Marketing. Send advertising or marketing communications about products, services, offers, promotions, rewards, and events offered by Project Wellbeing and others, and provide news and information that we believe may be of interest to you;

Events and Offers. Offer, conduct, and administer events, classes, contests, prize draws, and other promotions;

Research and Development. Conduct research and development;

Personalize Your Experience. Monitor, analyze, and audit your engagement with our brand and your interactions with our Services and online ads to better understand your interests and behaviors and customize your experience;

Safety and Security. Detect and protect against malicious, deceptive, or illegal activity, including fraudulent transactions, error, negligence, and breach of contract, security incidents, and harm to the rights, property or safety of Project Wellbeing and our users, customers, employees, or others;

Troubleshooting. Debug, identify, and repair errors that impair existing intended functionality of our Services;

Corporate Transactions. We may process personal data in the context of corporate acquisitions, mergers, or other corporate transactions;

Comply with Legal Obligations. Comply with our legal or regulatory obligations, including our tax obligations and those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions; and

Your Consent. We may process your personal data in accordance with your consent, or when you intentionally direct or instruct us to do so;

DISCLOSURE OF PERSONAL DATA 
There are some circumstances where we may disclose or share personal data to a third-party and for the purposes described below:

Affiliates and Subsidiaries. We disclose your personal data to our corporate affiliates and entities, including our holding company, sister companies, and subsidiaries for the purposes described in the “USE OF PERSONAL DATA” section above;

Service Providers. We disclose personal data to unaffiliated companies or individuals we hire or work with that perform services on our behalf, including fitness and health services, customer support, web hosting, information technology, payment processing, financing, product fulfillment, marketing and database management, direct mail and email distribution, events, contest, sweepstakes and promotion administration, music integration, extended warranty services, and advertising and analytics services. These service providers and contractors have access to personal data in order to perform services for us;

Contractors and Third-Party Partners. We disclose personal data to unaffiliated companies or individuals we partner with to provide certain products, services, or experiences to you;

Third-party for Legal or Security Reasons. We permit certain third parties, like our fraud prevention partners, to collect personal data in order to detect and prevent fraudulent transactions;

Corporate Transaction. Personal data may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization or financing involving Project Wellbeing;

Professional Advisors. We disclose personal data to our legal, financial, insurance, and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of Project Wellbeing’s business or operations;

Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process (including an enforceable request from authorities), to respond to claims (including inquiries by you in connection with your purchases from Project Wellbeing), enforce or apply our Membership Agreement and Terms of Use, or to protect the rights, property, or personal safety of Project Wellbeing, our members, guests, employees, or others;

Other Users of the Services or the Public. When you use a Project Wellbeing wellness center or other facilities, we may display your username so that other users can connect with you. Also, if you choose to activate the camera on your computer during a virtual workout, other users may be able to see your video while the workout is occurring or during future, on-demand versions of the workout. We do not control how other users, or third parties use any personal data that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured, or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it;
Your Consent or at Your Direction. We disclose personal data, such as profile data and communications data, to third parties when we have your consent or direction to do so. We may also disclose your personal data to third parties, such as providers, fitness facilities, and providers of online booking tools, when you intentionally direct us to do so or when you use our products or services to intentionally interact with third parties;

Aggregated, Anonymized or De-identified Data. We may also disclose aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you. Project Wellbeing processes, maintains, and uses this data only in a de-identified fashion and will not attempt to re-identify such data, except as permitted by law;

How We Protect Your Information. We have implemented reasonable security measures with respect to your information. Please be aware that, despite our efforts, no data security measures can guarantee security and confidentiality in all instances. There are also steps you can take to protect your information by, for example, keeping your account passwords secure.

TARGETED ADVERTISING AND ANALYTICS
We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile applications. These entities may use cookies, web beacons, SDKs, device identifiers, and other tracking technologies to collect information about your use of the Services, and other websites and applications, including your IP address and other identifiers, web browser and mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information is used to deliver ads targeted to your interests on other companies’ sites or mobile apps, analyze and track data, determine the popularity of certain content, and better understand your online activity. In addition, some of our advertising partners enable us to translate your email address into an identifier that can’t be used to identify you personally. Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web and in mobile apps.
The activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain laws.
CHILDREN’S PRIVACY
Project Wellbeing does not target our products and services to children; however, we may allow children 13 and older to use Project Wellbeing wellness centers and facilities with the consent and under the supervision of a parent or legal guardian who is a member.  
THIRD PARTY SITES
Please note that our websites contain links to third-party websites that are not controlled or operated by Project Wellbeing. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Project Wellbeing does not accept any responsibility or liability for these policies. Please review these policies before you disclose any personal data when visiting such third-party websites.
YOUR PRIVACY RIGHTS AND CHOICES

ACCESS, CORRECTION, AND DELETION
Depending on where you reside, you may have the right to (1) request to know more about and access your personal data, (2) request deletion of your personal data, and (3) request correction of inaccurate personal data.
You can make these requests at any time by visiting, accessing and updating your account information on our site or by calling us at 702-525-7791. You can also access, correct, or delete certain information stored within your online account at any time by logging into your account and navigating to the “Profile” page. After submitting your request, please monitor your email for a follow-up communication from us. We may be required to verify your request by asking you to provide additional information related to your recent interactions with us, such as your name and email.
We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful. If we deny your request, you may appeal our decision by contacting us at admin@projectwellbeing.co
OPTING OUT OF TARGETED ADVERTISING, SHARING, AND SALES
As described in the “TARGETED ADVERTISING AND ANALYTICS” section above, we process personal data to deliver ads targeted to your interests on other companies’ websites and mobile apps. Some of these activities may be considered “sales” or “sharing” of your personal data or “targeted advertising” under certain laws.
NONDISCRIMINATION
We will not discriminate against you if you exercise your privacy rights.
MARKETING COMMUNICATIONS
You may opt out of receiving promotional communications from us by following the instructions in those communications or by logging into your online account and changing your communications preferences. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
MOBILE PUSH NOTIFICATIONS/ALERTS
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
COOKIES AND SIMILAR TRACKING TECHNOLOGIES
Like many websites, Project Wellbeing uses cookies to analyze visits to our websites and emails and help us improve our website, services, and marketing campaigns. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please follow your browser’s process for doing so. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites.
You have the right to accept or reject Cookies. You can exercise your Cookie preferences by activating the setting on your web browser that allows you to refuse the setting of all or some Cookies. However, if you use your browser settings to block all Cookies, including Essential Cookies, you may not be able to access or use all or parts of our services. If you have not adjusted your browser setting to refuse cookies, our system will issue Cookies as soon as you visit our services. Blocking or deleting Cookies will not prevent device identification and related data collection from occurring when you access our services. Turning off Analytical Cookies will prevent the ability to measure the relevance and effectiveness of our services, emails, and marketing as well as to show you tailored marketing. Other marketing will still be displayed when you use our services.
GOOGLE ANALYTICS
We work with service providers (including Google Analytics) who conduct analytics to help us track and understand how visitors use our Site.  Google Analytics is a web analytics service provided by Google that uses cookies to help us analyze how users use our Sites. The information generated by the cookies about your use of the services will be transmitted to and stored by Google on servers in the United States. If you access our Site through different devices, Google may associate your devices with one another. Google has developed the Google Analytics opt-out browser add-on which you may download. Please note that the Add-on does not prevent information from being sent to Project Wellbeing.
TECHNOLOGIES IN OUR WELLNESS CENTERS AND FACILITIES
We have deployed WiFi access points in some of our wellness centers and facilities, and we receive aggregate reports regarding store traffic that relies in part on information collected from the WiFi access points to track traffic patterns at our facilities. Where such technology is used, we will provide a prominent notice at the location. If you wish to exclude your device from such in-store mobile analytics, you can opt out at any time by turning off WiFi on your device.
NOTICE OF FINANCIAL INCENTIVES
We offer various financial incentives. For example, we may provide discounts, coupons, or other benefits to customers who join membership programs or sign up to receive our marketing emails or text messages. When you participate in a financial incentive, we collect personal data from you, such as identifiers (like your email address or phone number), commercial information (like your purchase preferences and interests or purchase history), professional or employment-related information, inferences drawn about your preferences, and other categories of personal data that relate to or are reasonably capable of being associated with you. You can opt into a financial incentive by following the sign-up or participation instructions provided, and, for any ongoing benefits, you can opt-out at any time, such as by following the unsubscribe instructions in the applicable program’s terms and conditions, promotional emails, or text messages, or contacting us at admin@projectwelleing.co. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal data is reasonably related to the value of the offer or discount presented to you.

RETENTION OF PERSONAL DATA
Our retention periods for personal data are based on business needs and legal requirements. We store personal data associated with your account for as long as your account remains active. If you close your account, we will delete your account data within the applicable regulatory timeline. We retain other personal data for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. In addition, we retain your email address and information about your marketing preferences to ensure that we can honor those preferences.

CONTACT US 
If you have any questions or comments about this Privacy Policy, you may call us at 702-525-7791 or email us at info@projectwellbeing.co. 

ATTN: Privacy at Project Wellbeing
Project Wellbeing, LLC.
7155 S Buffalo Dr #165
Las Vegas, NV 89113