Effective Date: January 01, 2024

SECTION 1 – INTRODUCTION

Welcome to Pellea Inc.’s Pellea Fitness (hereinafter “Pellea”)!

As part of our mission of helping make our online and offline community and marketplace dynamic sub-platform better for everyone, Pellea collects and processes a lot of information. This Privacy Policy is intended to help you better understand how we collect, use and store your personal information-whether you are a vendor (“merchant”) that uses Pellea’s products or services, applications or services (together, the “Services”), a member (“customer” or “client”) that shops at a store using our technology, an affiliate (“associate”), or whether you’re simply visiting these websites. By using any of Pellea’s Services, or by dealing with vendors using Pellea’s Services, you are agreeing to the terms of this Privacy Policy and, as applicable, Pellea’s Terms of Use and Terms of Service.

We may update this Privacy Policy from time to time to show changes to our privacy practices or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy, we will give you notice of such changes by posting the revised policy on these websites, and where appropriate, by other means. By continuing to use these websites or the Support Service after these changes are posted, you agree to the revised policy.

SECTION 2 – INFORMATION FROM VENDORS

Privacy matters! If you are a Vendor, you agree to post a privacy policy on your storefront that complies with the laws applicable to your business. You also agree to get consent from your Members for the use and access of their Personal Information by Pellea and other third parties. In addition, if you are collecting any sensitive Personal Information from your Members (including information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexuality), you agree to get affirmative, express consent from your Members for the use and access of sensitive Personal Information by Pellea and other third parties.

What information do we collect from Vendors and why?

We collect your name, company name, business type, website, email address, phone number, address, Twitter, Facebook, Instagram, Linkedin, Youtube, Pinterest, Snapchat, Telegram or other social media handles, policies, Stripe Account, payment account, credit card details, and GST/HST number;

Other backgrounds information, such as your store name, store description, seller info, branding, store banners, store icon, product or service name, product or service description, product or service short description, categories, feature image, gallery, SEO title, SEO descriptions, keywords and other self-descriptions you choose to give.

We need this information to give you our Services; such as, to confirm your identity, contact you, and invoice you.

We collect data about the Pellea-hosted web pages that you visit. We also collect data about how and when you access your account, including information about the device and browser you use, your network connection, and your IP address.

We need this information to give you access to and improve our Services.

Upon completing the sign-up process for the products or services, and depending on your location, we may create a Pellea Payments account on your behalf. If you activate a Pellea Payments account (applicable only to Canada, US, UK, and Australia Partners), we collect your business address, business type, business ID number, date of birth (if you are an individual business owner), bank account information and government-issued identification information, such as your Social Security Number or your Social Insurance Number or, alternatively, if you are Canadian Partner and choose not to give your Social Insurance Number, a copy of your government-issued identification.

We need this information to create a Pellea Payments account for you, to give you Pellea Payments services, including fraud and risk monitoring, and to comply with applicable legal and regulatory requirements.

We collect Personal Information about our Members that you share with us or that offer while shopping or during checkout.

We use this information to give you our Services and so that you can process orders and better serve our Members.

We will also use Personal Information in other cases where you have given us your express permission.

When do we collect this information?

We collect Personal Information when you sign up for our Services when you access our Services or otherwise give us the information.

SECTION 3 – INFORMATION FROM MEMBERS

We collect the information you give to us, such as when you create an account, update your profile, use the interactive features of our Services, take part in contests, promotions, or surveys, request customer or client support, or otherwise communicate with us.

What information do we collect and why?

The types of information we may collect include:

Members’ username, nickname, first name, last name, full name, date of birth, current location, email address, phone number, photographs, shipping and billing address, payment details, IP address, device data;

Profile type and information relating to activities interested to learning, current skill level in activities, preferred group size for learning, success to learning facilities, goals seek to accomplish in activities, how far willing to travel to teach activities, activities able to teach, level of expertise when teaching activities, preferred group size for teaching, teaching facilities available, have the necessary teaching equipment, how far willing to travel to teach activities, activities like to announce;

Messages and interactive forum information, such as discussion group posts, media posts in galleries, messages to other Members and information you give in connection with activities and events; other backgrounds, contact and demographic information, such as your languages learned, relationship status, gender type, about you, work details, educational backgrounds, professional skills, given qualifications, specific training, many accomplishments, distinct qualities, regular hobbies, general interests, life experience, world views, Twitter, Facebook, Instagram, Linkedin, Youtube, WhatsApp and other social networks, personal URL, IM username, emergency contact, and other self-descriptions you choose to give.

Information stored on your mobile devices, such as your photos, calendar information, and contacts, if you have permitted us to get access to this information.

Information about you from other Members such as trust ratings, friend connections, public references, and other interconnections and interactions between you and other Members.

Information provided to us by you as a part of the identity verification process. This includes the identity document and images used in the process, as well as the information included in the identity document provided.

We need this information to offer Members our Services, including supporting and processing orders, authentication, and processing payments. We also use this information to improve our Services.

When do we collect this information?

Information is collected when a Member uses or accesses our Services, such as when a Member, places an order with a Vendor on our site, or signs up for an account on our site as a Member.

SECTION 4 – INFORMATION FROM AFFILIATES

Affiliates are individuals or businesses that have agreed to the terms of Pellea Partner Program to work with Pellea to promote the Services by (a) referring customers or clients to Pellea; (b) developing Pellea store themes for Affiliate use, or (c) developing apps using the Pellea Application Interface (API) for Affiliate use.

What information do we collect from Affiliates and why?

We collect your name, website, payment email address, and how you will promote us.

We use this information to work with you, confirm your identity, contact you, and credit you.

We collect data about the Pellea-hosted web pages that you visit and how and when you access your account, including information about the device and browser you use, your network connection, and your IP address.

We use this information to give you access to and improve our Services.

We collect Personal Information about our Members that you share with us or that they give to us directly.

We use this information to work with you and to offer our Services to our Members.

We will also use Personal Information in other cases where you have given us express permission.

When do we collect this information?

We collect this information when you sign up for an Affiliate Account, when you sign up one of your Members for our Services, or when our Members sign up themselves. We also collect any other information that you might give to us.

SECTION 5 – INFORMATION FROM PELLEA WEBSITES VISITORS AND SUPPORT USERS

What information do we collect and why?

From Pellea website visitors, we collect information about the device and browser you use, your network connection, and your IP address. We also collect Personal Information submitted by you via any messaging feature available from any of our websites (“Messaging Feature”).

We may also receive Personal Information when you buy tickets or make other requests to Pellea via any of our websites.

From telephone support users, we collect your phone number and call audio.

From chat support users, we collect your name, email address, information about the device and browser you use, your network connection, your IP address, and chat transcript.

From forum users, we collect your name, email address, and website URL.

We use this information to give and enhance our Services (including servicing your account, if applicable), and answer any questions you may have.

When do we collect this information?

We collect this information when you visit Pellea-hosted web pages, use Services offered on our websites or engage with us either by email, web form, instant message, phone, or post content on or through our websites (including forums, blogs and via any Messaging Feature). We also collect any other information that you might give to us.

SECTION 6 – CONSENT

What is the age of consent?

By using these websites, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

How do you get my consent?

When our Members’, Vendors’ or Affiliates give us personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent or allow you to say no.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting our Privacy Compliance Officer here or via email at [email protected].

[Re: Privacy Compliance Officer]

SECTION 7 – DISCLOSURE

We may disclose your personal information if we are required by law to do so or if you violate our Terms of Use or Terms of Service.

SECTION 8 – PELLEA

Our store is hosted on fitness.pellea.com. They give us an online e-commerce platform that allows vendors to sell our products or services to members.

Your data is stored through Pellea’s data storage, databases, and the general Pellea application. They store your data on a secure server behind a firewall.

Payment:

If you choose a direct payment gateway to complete your purchase, then Pellea stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, and Discover.

PCI-DSS requirements help make sure the secure handling of credit card information by our store and its service providers.

For more insight, you may also want to read Pellea’s Terms of Use and Terms of Service or Privacy Statement here.

SECTION 9 – THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use, and show your information to the extent necessary to allow them to do the services they give to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their privacy policies with respect to the information we are required to give to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the way your personal information will be handled by these providers.

In particular, remember that certain providers may be in or have facilities that are located in a different jurisdiction than either you or us. So if you choose to do with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our store’s websites or are redirected to a third-party website, websites or application, you are no longer governed by this Privacy Policy or our website’s Terms of Use and Terms of Service.

Links

When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and urge you to read their privacy statements.

Social Media Tools

We may offer social sharing features or other integrated tools which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of certain information with your friends or the public, depending on the settings you set up with the third-party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that give these social sharing features. Pellea may also allow you to get access to Google Maps. Please note that when you use Google Maps, you are subject to Google’s privacy policy, as amended by Google from time to time.

SECTION 10 – SECURITY

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed.

If you give us your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and carry out additional generally accepted industry standards.

Privacy Setting

You may change your privacy settings and decide whether certain information about you will be visible to others by navigating to “Account & Settings” on our websites and editing your “Privacy Settings.”

Account Information

You may update or correct information about you or deactivate your account at any time by logging into your account and editing your profile. Pellea will not give members access to account data that is not already available to a logged-in member. Even after you deactivate your account, we may keep certain information as required by law, for legitimate business purposes or to protect member safety. If your account is deactivated, Pellea will give access to the data associated with the deactivated account upon receipt of the required legal documentation.

Location Information via Mobile Device

You can turn location-based services on and off by adjusting the settings of your Internet browser or mobile device and after the standard uninstall process and removing Pellea’s application from your device. Doing so, however, may mean that you cannot use all or a portion of our Services.

Information From Cookies and Similar Tracking Technologies

What is a cookie? A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our websites or websites.

Here is a list of cookies that we use. We’ve listed them here so you can choose if you want to opt-out of cookies or not.

_session_id, unique token, sessional, Allows Pellea to store information about your session (referrer, landing page, etc).

_Pellea_visit, no data held, Persistent for 30 minutes from the last visit, Used by our websites or websites provider’s internal stats tracker to record the number of visits.

_Pellea_uniq, no data held, expires midnight (on the visitor) of the next day, Counts the number of visits to a store by a single Member.

cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.

_secure_session_id, unique token, sessional.

storefront_digest, unique token, indefinite If the shop has a password, this is used to decide if the current visitor has access.

Why does Pellea use cookies and similar tracking technology?

We use cookies to recognize your device and give you a personalized experience.

We also use cookies to serve targeted ads from Google, Facebook, Bing, and other third-party vendors.

Our third-party advertisers use cookies to track your earlier visits to our websites or websites and elsewhere on the Internet to serve you targeted ads. For more information about targeted or Behavioural advertising, please visit https://networkadvertising.org/understanding-online-advertising.

Opting out: You can opt-out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.

We may also use web beacons, tracking technology, and other automated tracking methods on our websites or websites, in communications with you, and in our products or services, to measure performance and engagement.

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

The purpose of a cookie is to find you electronically, store your preferences for viewing our webpages, allow “remarketing” relevant to your interests based on your visits to our site, and show you relevant ads on our websites or websites and across the Internet.

Cookies are stored on your device to help us in providing and improving our Services. For example, we use cookies to keep you logged into your account and we use data collection devices such as Analytics to help analyze our web page flow, measure promotional effectiveness, and give you information relevant to your interests.

Through first-party and third-party cookies, third parties may collect information about you while you are visiting Pellea-hosted web-pages and other websites. They may use these results to show you advertisements on Pellea-hosted webpages and across the Internet-based on your visits to these sites. We do not collect this information or control the advertising content that you will see.

When and why do we share Personal Information with third parties?

Pellea works with third parties to help give you our Services and we may share Personal Information with them to support these efforts. In certain limited circumstances, we may also be required to share information with third parties to conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also receive Personal Information from our partners and third parties.

Personal Information may be shared with third parties to prevent, investigate, or act on illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or Terms of Service, or any other agreement related to the Services, or as otherwise required by law.

Personal Information may be shared with third-party vendors to help us conduct marketing and/or advertising campaigns.

Personal Information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.

Pellea is responsible for all transfers of Personal Information to third parties under the EU-U.S. Privacy Shield Principles, the U.S.-Swiss Safe Harbor Framework, and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

Pellea will always ask for your consent before sharing your Personal Information with third parties for purposes other than those described in Section 9.

Pellea remains responsible for Personal Information transferred to a third-party for processing or to support our efforts in providing you with our Services. Any Personal Information transferred to a third-party for data processing is processed our instructions, and is subject, by law, to a comparable level of protection as that provided by Pellea.

A “comparable level of protection” means a level of protection generally equal to that provided by Pellea.

What do we do with your Personal Information when you terminate your relationship with us?

We will continue to store archived copies of your Personal Information for legitimate business purposes and to comply with the law.

We will continue to store anonymous information, such as websites or websites visits, without identifiers, to improve our Services.

What we don’t do with your Personal Information?

We do not and will never share, show, sell, rent, or otherwise give Personal Information to other companies (other than to specific Pellea Vendors you may be interacting with) for the marketing of their products or services.

If you are a Vendor using Pellea’ Services, we do not use the Personal Information we collect from you or your Members to independently contact or market to your Members. However, Pellea may contact or market to your Members if we get their information from another source, such as from the Members themselves.

How do we keep your Personal Information secure?

We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details, and any other Personal Information entrusted to us. Our information security systems apply to people, processes, and information technology systems on a risk management basis.

We do annual audits to make sure our handling of your credit card information aligns with industry guidelines. We are certified as a PCI DSS Level 1 compliant service provider, which is the highest level of compliance available, and our platform is audited annually by a third-party qualified security assessor.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your Personal Information.

Residents of the European Economic Area (“EEA”)

Pellea works with Vendors and users around the world, including in the EEA. If you are located in the EEA, your personal information is processed by Pellea’s Irish affiliate, Pellea Inc. Please note that as part of our service, we may transfer your personal information to other regions, including Canada and the United States. To make sure that your information is protected when transferred out of the EEA, Pellea relies on the EU-U.S. Privacy Shield (described in more detail below), as well as inter-company agreements between our various affiliates that may process your information on behalf of Pellea International Inc.

Additionally, if you are located in the EEA, you have certain rights under European law concerning your data, including the right to ask for access to, correct, amend, delete, or limit your data. To exercise these rights, please reach out to us using the contact information below.

How do we protect your information across borders?

While Pellea Inc. is a Canadian company, we offer services to Members, and our technology processes data from users around the world. Accordingly, Pellea may send your personal information outside of the country, state, or province in which you are located.

Pellea (specifically Pellea’s affiliates Pellea Data Processing (USA) Inc., Pellea Payments (USA) Inc., and Pellea (USA) Inc.) complies with the EU-U.S. Privacy Shield Framework, about the collection, use, and retention of Personal Information from data subjects in the European Economic Area (“EEA”), and with the U.S.-Swiss Safe Harbor Framework about the collection, use, and retention of Personal Information from data subjects in Switzerland. In this regard, we have certified that we adhere to the Privacy Shield Principles of notice, choice, accountability for transfers, security, data integrity and purpose limitation, access, recourse, enforcement, and liability.

If you are located in the EEA or Switzerland and believe that your Personal Information has been used in a way that is not consistent with the relevant privacy policies listed above, please contact us using the information below. If your complaint or dispute remains unresolved, you may also contact the International Centre for Dispute Resolution®, the international division of the American Arbitration Association® (ICDR/AAA). This organization provides independent dispute resolution services, at no charge to you. ICDR/AAA can be contacted at https://adr.org.

If, after attempting to resolve a dispute through ICDR/AAA, you feel that your concerns about the use of your Personal Information have not been resolved, you may seek a resolution of the issue through binding arbitration. For more information about the binding arbitration process, please visit https://privacyshield.gov.

By participating in the EU-U.S. Privacy Shield Framework and the U.S.-Swiss Safe Harbor Framework, Pellea’s participating U.S. entities are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the EU-U.S. Privacy Shield, please visit https://privacyshield.gov (you can view Pellea’s certification statement at https://privacyshield.gov/participant?id=a2zt0000000TNSNAA4&status=Active). For more information about the U.S.-Swiss Safe Harbor Framework, please visit https://export.gov/safeharbor_swiss.

Control and access to your Personal Information

You keep all rights to your Personal Information and can get access to it anytime. Also, Pellea takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. You can update many types of Personal Information, such as payment or contact information, directly within your account settings. If you are unable to change your Personal Information within your account settings, please contact us to make the required changes. It’s important to remember that if you delete or limit the use of your Personal Information, the Services may not function properly.

Questions and Contact Information

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, want more information or have any questions about this Privacy Policy, please contact our Privacy Compliance Officer here or via email at [email protected].

[Attn: Privacy Compliance Officer]

Pellea Inc.

Toronto, ON, M5B1G7, Canada