Privacy Notice

Die deutsche Übersetzung der Datenschutzerklärung ist hier verfügbar.

This Privacy Notice was last updated on 6.4.2022

This Privacy Notice explains how Fjuul processes your personal data. Fjuul is committed to protecting your privacy and to complying with applicable data protection and privacy laws. In case you have any questions concerning data protection at Fjuul, please contact our data protection officer: dpo@fjuul.com.

OVERVIEW OF HOW FJUUL USES YOUR PERSONAL DATA

The Fjuul App collects data on your physical activities directly from your phone or, depending on how you use the app, through a separate fitness device you use, such as a smartwatch. By using particular algorithms, Fjuul translates this data into universal energy points (so-called Fjuul Points). The calculation of Fjuul Points is based on the intensity and duration of your activity. This allows you to consistently compare your days and progress, pursue goals that suit your fitness level or ambition, and compare your progress with others. You can use the Fjuul Points as currency in selected Fjuul partnership programs, and redeem your points for rewards, either online or offline.

Fjuul also processes personal data to provide and administer the Fjuul website.

You have control over your personal data and how it’s collected, used, and shared. Depending on your choice, your personal data is used for one or several of the following services.

WORKPLACE WELL-BEING SERVICE

Organisations and their health care providers can partner with Fjuul. Through the Fjuul App and its related services, employees can keep track of their healthy activities and get coaching.

REWARD PARTNERSHIPS

Organisations who wish to encourage an active lifestyle can partner with Fjuul. Through the Fjuul App and its related services, organisations can reward teams, employees or customers for reaching pre-defined goals.

COMMUNITY AND BRAND BUILDING

Organisations and communities who wish to encourage an active lifestyle can partner with Fjuul. Through the Fjuul App and its related services, organisations and communities can bring people together who can challenge themselves and each other to move for a greater cause, for instance by donating money to charity.

WHAT PERSONAL DATA WE COLLECT AND WHY

Personal data provided by you

When you start using the Fjuul App, you are requested to register and create a user account (the Fjuul Account). For that purpose, we ask you to provide us with your email address that is used to authenticate you, to enable you to use the Fjuul App and to enable us to communicate with you.

Information on your height, weight, gender and birth date are also required as part of your registration process. This information is needed for optimizing the allocation of Fjuul Points and providing personalized services, such as activity guidance, goal setting and coaching.

Personal data collected from fitness devices or applications

The Fjuul App starts collecting data after you have entered the requested information, installed the Fjuul App to your mobile device, and actively enabled collection of data from a mobile phone, sensor, fitness device or application. When you enable collection of data from a fitness device or application, Fjuul starts to receive data collected by that device or application. Data is collected as long as a source device or application is on and you have enabled collection of data from that device or application.

The exact types of personal data collected from a fitness device depend on the features of the devices you use and the data collection choices you have made on those devices.

The following types of personal data can be collected from most supported devices:

Type of activity (e.g. running, cycling, swimming, walking)
duration of activity
distance covered during activity
number of steps taken or floors climbed
estimated consumed calories
your training goals
heart rate and heart rate variability
stress level
sleep
workout intensity
workout summaries

We also collect the following information relating to your fitness device:

device type
device id
operating system

Automated decision-making

The Fjuul Points are calculated by Fjuul’s algorithms based on the intensity and duration of your activity. This means that decisions in relation to the rewards provided by partnership programs, for instance, based on the number of Fjuul Points achieved, or bonus levels reached, are sometimes made by automated means. We perform regular checks to the accuracy of the algorithms, and more detailed information about the data used for your rewards can be found in your partner program.

Personal data collected on the Fjuul website

We collect some technical data automatically through the use of our website, which may be associated with individual users. This includes IP address, type and device ID of the user’s device as well as mobile operating system, browser type, browser version, the specific sub-sites of our website that the user visits, the time and date of the visit, the time spent on those sites, unique device identifiers and other statistical data. If a user contacts us through the contact form on the Fjuul website, we also collect the user’s name and email address entered on the form.

Data collected in surveys

In certain programs you have the possibility to participate in surveys. The purpose of the surveys is to improve the products and service offerings of Fjuul. Participation is voluntary. In the context of surveys, we do not collect any identifiers regarding you. Therefore, after you have submitted your answers, we cannot link your answers back to you.

HOW WE PROCESS AND USE YOUR PERSONAL DATA

We use your personal data for:

Service delivery

Information collected during the registration and the use of the Fjuul App is needed to:

create your Fjuul account and manage its use
analyse the monitored physical movements and provide you with services
enable the conversion of collected fitness data to Fjuul Points

Providing you with product information and marketing

Contact information you provide in the Fjuul App or through another means, such as the contact form on the Fjuul website, might be used for:

informing you of updates and new features in the App
letting you know of ongoing challenges and benefits
contacting you if you have asked us to
informing you about offers that relate to a program or a challenge you participate in (e.g. the purchase of a fitness device)

If you don’t want to receive any communication from us, you can anytime opt-out from emails or disable push notifications from your profile when this function is used.

Service and business development and fraud prevention

We analyse the usage of the App and it’s features and collect data of the device you use to be able to:

develop the Fjuul App’s features and services and the algorithms used
further develop the usability and user experience
provide product support
correct problems and errors
prevent and investigate fraud and other criminal activities

Providing and administering the Fjuul website

We use the technical data collected in connection with your use of the Fjuul website to:

provide a well-functioning website
analyse the use of the website and ensure its security

LEGAL BASIS OF PROCESSING PERSONAL DATA

Processing of personal data is only lawful if at least one of the following applies:

the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which the controller is subject;
processing is necessary in order to protect the vital interests of the data subject or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Personal data concerning health is considered to be sensitive personal data. Processing of such data is prohibited, unless additional conditions are met. Processing is, for instance, allowed if the data subject has given explicit consent to the processing for one or more specified purposes.

It is necessary for Fjuul to process your personal data in order to provide you with the Fjuul fitness App service in accordance with the service contract between you and Fjuul. The legal basis for such processing is the necessity for the performance of a contract.

Some of the data processed by Fjuul, such as heart rate data, constitutes sensitive data, since it might give indications about an individual’s health. Such personal data is collected and processed based on your explicit consent.

Data processing for marketing activities, for communicating news on the use of Fjuul, for providing you with the Fjuul website and for service development and fraud detection activities are based on Fjuul’s legitimate interest to keep you informed of the features of the App and existing reward programs, and to develop the service and resolve problems.

You have the possibility to opt-out from receiving marketing and service-related news communication.

You can manage your consents in the Fjuul App. You have the right to withdraw your consent at any time, but this might affect the provision of the service as described below.

The following personal data processing activities require your consent:

Collection of data from a mobile phone, sensor, an external fitness device or application of your choice. The provision of the Fjuul service is not possible without collection of data from an external fitness device or application. Therefore, you cannot use Fjuul without consenting to data collecting from an external device or application.
Disclosure of information to another data controller (such as an insurance company or your employer). Depending on the terms of your partnership program, the disclosure might include the following information: information regarding the fact that you have earned a reward; information regarding your Fjuul Point count; or a report of your fitness activity level that is based on the amount of Fjuul Points you have gained. You can withdraw your consent for partner disclosure at any time, but this may affect the accumulation of rewards in accordance with the rules of that program.
Collection and processing of special categories of personal data included in your survey inputs. We need your consent in order to be able to collect all information you enter into our surveys. Some of this data might amount to health data, such as data regarding your well-being. However, once your answers have been submitted, we can no longer link them back to your account or to you.

RETENTION TIME OF PERSONAL DATA

Personal data collection stops when the user account has no active fitness source connected to it. Personal data is collected as long as collection from a source device is enabled and the source device is on and your Fjuul Account is active. The account is considered to be active as long as we get new data into the App. To stop transferring data you need to deactivate the Fjuul App from reading from and writing data to Fjuul in your original source device/application (e.g. your phone/fitness tracker/app).

To remove your data from Fjuul, you need to choose the option Remove account in the Fjuul App menu. Within 200 days, your personal data will be deleted. It is possible that we have to retain your personal data beyond 200 days if it is necessary for complying with applicable laws.

PERSONAL DATA DISCLOSURES

Disclosure of personal data refers to situations where your personal data is provided to another data controller or data processor, such as a service provider. We will comply with applicable data protection laws and applicable criteria for the disclosure of personal data.

External service providers

In building and maintaining the Fjuul App, we use external service providers. For instance, we use Google Analytics service for Firebase. Google Analytics processes data as described at https://policies.google.com/technologies/partner-sites. We also use Google Cloud to store data, including personal data, on their servers in Germany.

For calculating your Biological Age (BAM), we cooperate with the global reinsurance company SCOR and its wholly owned subsidiary ReMark. The data sent for this purpose will not identify you to them, and this data will not be retained and stored. SCOR receives aggregated data for research and development. This data will not identify you.

In order to carry out surveys, we use external service providers (such as Typeform S. L.) that act as our data processors on our behalf. We only retrieve, store and process the information you enter in the survey form. This information will not identify you.

Partners

Fjuul partners with organisations, companies and communities. Depending on your reason to use the Fjuul App, we might share a part of your personal data with one or more of these partners.

The Fjuul App can be used in the following types of partnership programs:

Partners can use the Fjuul App to provide their employees with a workplace well-being service
Partners can use the Fjuul App to reward employees or customers (e.g. within a workplace-wellbeing program or as part of an insurance offering)
Partners can use the Fjuul App for community building, whereby users can participate in challenges within or between groups/companies

In these programs, the following data might be shared as indicated below.

When you use the Fjuul App as part of a workplace wellbeing program, Fjuul might share with your employer and/or your company’s wellbeing service provider, aggregated data about the whole group. This data will not identify you.
When you participate in a reward program, Fjuul might share your average number of Fjuul Points achieved, your number of goals reached, and/or your bonus level reached for a defined period of time, for instance, your 100 days rolling average. Fjuul might also share aggregated data about the whole group participating. This data will not identify you.
When you participate in a challenge, Fjuul might share the total amount of Fjuul Points added by you to that challenge, with the partner organising it. Fjuul might also share aggregated data about the whole group participating. This data will not identify you.

What data is shared and for which purpose, depends on your partnership program, and on what you choose to share. We do not share any other personal data than the data required for the purpose of your specific program.

If you choose to provide your personal data to a partner, your data is governed by the Privacy Notice of this partner. Please note that the Privacy Notices of third parties differ from Fjuul’s Privacy Notice.

Other disclosures

Fjuul may disclose minimum required amount of your personal data to competent authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request, or in connection with a merger, acquisition, reorganization or sale of Fjuul.

PERSONAL DATA OF CHILDREN

We do not knowingly collect personal data of children under the age of 13. We request that children under the age of 13 do not register an account and we will take steps to delete any such data if such collection comes to our knowledge.

YOUR RIGHTS

You can request a copy of or access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, and you have the right to object to processing of your personal data.

You can modify and correct any personal data you have given when using the Fjuul App by logging into your Fjuul Account.

To request access to, portability or erasure of your personal data, or to delete your Fjuul account, please contact us by using the feedback function in the App, or at: dpo@fjuul.com.

You have the right to lodge a complaint with a supervisory data protection authority.

The Finnish data protection authority can be contacted at: https://tietosuoja.fi/etusivu

The Austrian data protection authority can be contacted at: https://www.dsb.gv.at

A list with the contact details and websites of the differentGerman data protection authorities can be found at: https://www.datenschutzkonferenz-online.de/datenschutzaufsichtsbehoerden.html

DATA SECURITY

Our systems are firewall protected. We also use encryption techniques and authentication procedures to maintain the security of your personal data and prevent unauthorized access to your Fjuul Account and our systems.

Authorized Fjuul personnel and service providers who are granted access to personal data are required to keep such data confidential.

Your data will only be processed by persons who have the right to do so and who, due to their duties, need to process it. Authorized Fjuul personnel who are granted access to personal data are required to keep such data confidential. Your personal data may also be processed by service providers based on our instructions and in compliance with our Privacy Notice.

INTERNATIONAL TRANSFERS

Fjuul does not transfer or disclose your personal data outside the EU/EEA without appropriate safeguards.

We use Google Analytics and Firebase, a web analysis service of Google. We also use Google reCAPTCHA to prevent spam and fraudulent use of our website. Google LLC, based in the United States, relies on the European Commission’s Standard Contractual Clauses (SCCs) for transfer of personal data out of the European Economic Area, the UK or Switzerland.

COOKIES ON THE FJUUL WEBSITE

A “cookie” is a piece of information that is stored on a user’s computer, tablet or phone (hereinafter together “device”) when they visit a website. Cookies can help in identifying a user’s device when they visit the website and remember helpful details of the use and the choices made by the user to improve the user experience. We always ask your consent for use of cookies on the Fjuul website, unless the use of a cookie is essential for providing you with the website and its features.

Cookies cannot be used alone to identify an individual, but they may be linked directly or indirectly to an identifiable individual when combined with other information. In these cases, cookies may be treated as personal data. If we identify a user based on cookies, we make sure that all cookie information is processed as personal data in accordance with applicable data protection laws.

We use both session and persistent cookies for various purposes.

Session cookies are stored in memory for the duration of the session and removed once the user closes the browser.
Persistent cookies are placed on hard drive of the user’s computer or device and stored until they expire, or the user deletes the cookies.

We use both first- and third-party cookies for various purposes.

First party cookies refer to both session and persistent cookies placed by us on our website.
Third party cookies are cookies placed by third parties on our website, such as Google Analytics.

We use cookies as set out below:

Essential cookies:

Type: Session cookies
Administered by us
Purpose: These cookies are essential to provide the Fjuul website and to enable the use of its most important features.

Tracking and performance cookies

Type: Persistent Cookies
Administered by third-parties
Purpose: These cookies are used to track information about traffic to the Fjuul website and how users use the website (Google Analytics). We also use these cookies to optimize functionalities of the Fjuul website, such as to prevent misuse of the contact form (Google reCAPTCHA).

UPDATES TO THIS PRIVACY NOTICE

Fjuul reserves the right to update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will modify the date of the update at the top of this Privacy Notice.

HOW TO CONTACT US

Fjuul Vision Oy Jokipuistonkaari 2 A 28, 04130 Sipoo.

You can contact us through the contact form on our website. In issues relating to your Fjuul Account, or to opt out from marketing messages, please contact: support@fjuul.com. In any privacy matters, you can contact our Data Protection Officer: dpo@fjuul.com.

SUMMARY: PROCESSING YOUR PERSONAL DATA

Type of processing: Providing you the Fjuul App
Purpose of processing: To create and maintain your account, to analyse your fitness data and calculate your Fjuul Points, to store your data to achieve all of this
Personal data disclosures: In building and maintaining the Fjuul App, we use external service providers. Currently we use Google Analytics service, Firebase and Google Cloud.
Types of personal data Fjuul processes: Email address, height, weight, gender, birth date, type of activity, duration of activity, distance, steps taken, floors climbed, estimated consumed calories, training goals, heart rate data, stress data, sleep data, workout data, Healthy Minutes, Fjuul Points,
information relating to your fitness device: device type, device id, operating system, IP address
Legal basis: Contract between you and Fjuul
Your consent
Fjuul’s legal role towards you: Controller
Type of processing: Workplace well-being service (optional)
Purpose of processing: To provide you with the workplace well-being service
Personal data disclosures: You may choose to provide aggregated personal data to your employer.
Types of personal data Fjuul processes: This data is the aggregated amount of the entire group participating. A comparison diagram is shown when the group has reached a pre-set minimum amount of participants. This will not identify you
Legal basis: Your consent
Fjuul’s legal role towards you: Controller
Type of processing: Reward partners (for instance insurance partnerships) (optional)
Purpose of processing: To provide you with the features necessary to use the service you have purchased
Personal data disclosures: You may choose to provide aggregated personal data (for instance, activity level, average level of Fjuul Points over a specified period of time) to a reward partner whose service you are using
Types of personal data Fjuul processes: What data is transferred depends on the program in which you participate.
Legal basis: Your consent
Fjuul’s legal role towards you: Processor or Controller
Type of processing: Biological Age Model (BAM) (optional)
Purpose of processing: To provide you with an estimate of your biological age
Personal data disclosures: Aggregated data is transferred to the external service provider, SCOR for calculation.
Types of personal data Fjuul processes: Aggregated data about your activities. This data will not identify you to SCOR, and it will not be retained and stored.
Legal basis: Contract between you and Fjuul
Fjuul’s legal role towards you: Controller
Type of processing: Compliance with legal obligations
Purpose of processing: Fjuul may disclose minimum required amount of your personal data to competent authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request
Personal data disclosures: Data may be disclosed to competent authorities
Types of personal data Fjuul processes:
Legal basis: Compliance with legal obligations
Fjuul’s legal role towards you: Controller
Type of processing: Service and business development and fraud prevention
Purpose of processing: To develop the Fjuul App’s features and services and the algorithms used. To provide product support. To correct problems and errors. To prevent and investigate fraud and other criminal activities
Personal data disclosures: No disclosures
Types of personal data Fjuul processes:
Legal basis: Legitimate interest
Fjuul’s legal role towards you: Controller
Type of processing: Transfer of ownership
Purpose of processing: In connection with a merger, acquisition, reorganization or sale of Fjuul
Personal data disclosures: Data may be disclosed to the buyer or to the new company being formed
Types of personal data Fjuul processes:
Legal basis: Legitimate interest
Fjuul’s legal role towards you: Controller
Type of processing: The Fjuul website
Purpose of processing: To provide and administer the Fjuul website
Personal data disclosures: To provide and administer the Fjuul website and analyze its use, we use external service providers. Currently we use Google Analytics and Google reCAPTCHA.
Types of personal data Fjuul processes: IP address, type and device ID of the user’s device, mobile operating system, browser type, browser version, the specific sub-sites of our website that the user visits, the time and date of the visit, the time spent on those sites.
Legal basis: Legitimate interest
Fjuul’s legal role towards you: Controller
Type of processing: Marketing and communication
Purpose of processing: To contact you on your request. To provide you with information on use and new features of the Fjuul App and new reward programs
Personal data disclosures: No disclosures
Types of personal data Fjuul processes: Name, email address
Legal basis: Legitimate interest (you can opt out whenever you want)
Fjuul’s legal role towards you: Controller
Type of processing: Further service development with anonymous data
Purpose of processing: After personal data it is no longer needed for the purposes specified in this table, we render in anonymous. We use this data for further improving our services, for example, our algorithms for calculating Fjuul Points.
Personal data disclosures: Third parties will not receive any personal data
Types of personal data Fjuul processes: No personal data is processed, only data rendered anonymous