She Privacy Policy
Strong Healthy Empowered, LLC, which may be referred to as “She App”, “we”, “us”, “our”, and “ours”, is committed to protecting the privacy of your personal data.
This policy describes how and why we collect, hold, process, and use your personal data, your rights in relation to your personal data, and how to contact us in the event you have a complaint, according to with data privacy and security laws applicable to you in the relevant jurisdiction to which the processing relates (collectively, the “Data Protection Legislation”).
This policy applies to you when She processes your persona data, including when you:
Visit our website or any microsites, online shopping websites, or other websites provided and operated by us, or other websites operated by third parties on behalf of us that post a link to this policy (collectively, “She Website”),
Enroll as a client or a customer online, in person, or otherwise,
Buy our products online, over the phone, or in person,
Create an account with us,
Engage with our promotions, surveys, or provide marketing response to our engagement activities,
Register for events,
Elect to receive newsletters or product updates and offers, or
Contact us in any other way.
It is important that the personal data She holds about you is accurate and current. Please keep She informed if your personal data changes. Any inaccurate or false information may prevent us from providing services to you or lead to delayed service.
1. Who are we?
She is a leader in the health and wellness industry and develops and sells fitness training and coaching plans for its clients. Strong Healthy Empowered, LLC is a Utah limited liability company with a registered office at 12577 South Fort Street, Draper, UT 84020. To know the entity acting as a data controller for the processing of your personal data, please click the “Contact Us” link on the She Website.
2. How to contact us
Should you have any questions about this policy, you may contact us at Strong Healthy Empowered, LLC, 12577 South Fort Street, Draper, UT 84020 or at support@thatshelife.com
3. What personal data do we collect?
The personal data refers to any information that you provide to us that relates to an identified or identifiable individual. The personal data we collect may include:
Your personal details, such as when you use the She Website, your IP address, and traffic data:
Location data, weblogs, and other communication data, and
The resources that you access; when you fill in forms on the She Website, subscribe to any service, request further services, or contact us about She products and services; when you contact us, we may keep a record of that correspondence.
In the event that you decide to order any products or services from She, we may need to further process your first name, last name, email address, mobile number, domicile country, postal code, payment card details, delivery address, etc.
If you are or intend to become a customer or client of She, or in any way interact with us, we will hold personal data about you relevant to our relationship with you, according to applicable internal and statutory rules and policies. If you provide She with any persona data of other individuals, it is your responsibility to inform them of this policy and their rights with respect to such data, to comply with applicable law in processing their personal data, and to obtain the appropriate consent of those individuals where legally required.
If you fail to provide certain personal data when requested, it may delay or prevent us from providing our products and services to you, performing the contract we have entered into with you, and/or we may be prevented from complying with our legal obligations. In short, we may have to terminate our business relationship with you.
The categories and scope of personal data we collect about you may vary from time to time, depending on your choice of and interaction with our products and services, as well as the country or region in which you live.
Some of the personal data we request from you in connection with providing you with products and services is mandatory. In the event that you elect to not provide such personal data to us, we may not be able to provide you with our products and services. In those circumstances, we may have to end our business relationship with you. We will seek to notify you if this is the case in due course.
Your personal data will be used and disclosed by She only for the purposes for which it was provided, unless you agree otherwise or for other specific reasons such as if the use or disclosure of this information is required by law.
Sensitive personal data
Depending on the applicable Data Protection Legislation and the nature of the services provided by us, some of the information we collect may be sensitive personal data. For example, She may process your bank card information to process your payment. We may also collect other sensitive personal data about you according to the applicable Data Protection Legislation, such as on the basis of your appropriate consent.
Minor’s personal data
We do not knowingly solicit or collect personal data from anyone under the age of 18, or the minimum age of minors under the applicable laws of your jurisdiction (whichever is higher). However, due to the technical limitations, we may not be able to identify the exact age of our users under certain circumstances. If you have not yet reached the minimum age defined in your jurisdiction, please do not use our service or disclose any of your personal data to us.
4. Why do we process your personal data?
Where lawfully permitted, She may process your personal data for the following purposes:
Process your client application, account creating, authentication, and management (managing user logins, passwords, and profiles):
Carry out our rights and obligations arising from any agreements entered into between you and us (including to process, fulfill and notify you of the status of your product order, to process one-time or recurring payments, to process your product return and exchange request, and to provide you customer service);
Provide client services such as planning and facilitating fitness training and other client benefits;
General administration of your client account;
Prevent and detect fraud against your or us;
Ensure that business policies are adhered to and the confidentiality of commercially sensitive information;
Allow you to participate in interactive features of our service when you choose to do so;
Send you the latest marketing information about our company, events, product/services specials, where to have consented to be contacted for such purposes;
To facilitate communication between you and She; publish She newsletters that may contain personal information (such as name);
Create promotional materials, statistical analysis, policies, marketing plans and strategies, company and intra-group communications, reports or other related business issues;
Perform analytics in order to provide you with better services, to know your preferences and targeted communication;
Improve existing products and services, research and develop new products and services;
Register for events;
Facilitate and improve your use of the She Website;
Prevent unauthorized access and modifications to IT systems;
Comply with applicable laws and regulatory requirements and assist with any governmental or police investigation; and
Other purposes directly relating to any of the above.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you, seek your appropriate consent, or we will explain the legal basis other than the consent which allows us to do so.
5. Our legal basis for processing personal data
If required by applicable Data Protection Legislation, we will seek to obtain your consent to process your personal data, and only process your personal data upon receiving such consent. When required and allowed by applicable Data Protection Legislation, we may process your personal data for a legitimate interest, for purposes necessary for the performance of a contract with you, for example for the processing or fulfilment of orders for our products or services, or for complying with
our legal obligations.
6. Direct marketing communications
Subject to your consent, we may use your personal data to send you marketing updates (by email, text message, or post) about our services, including special offers, promotions, incentives or other information in terms of our products/services we think may be of interest to you.
In connection with such marketing, we may use your name, contact details, products and services portfolio information, transaction pattern and behavior, financial background, and demographic data held by us.
Where data are processed for the purposes of direct marketing, you have the right to opt out of receiving direct marketing communications at any time and we will arrange effective procedures accordingly allowing you at any time to “opt-out” from having your data used for such purposes.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
7. To whom do we disclose or transfer your personal data?
Why might She share your personal data with third parties?
She will share your personal data with third parties where required by law, where it is necessary to perform the contract we have entered into with you, based on your appropriate consent or other legal bases as legally permitted.
Which third parties may receive and process your personal data?
Where applicable Data Protection Legislation permits, She may share such data from time to time with the following third parties, which will be bound by confidentiality and data protection obligations:
Other entities within the She group (“She Organization”), those She employees, directors, managers, and agents who have a need to access your personal data to carry out their responsibilities, if necessary for (one of) the purposes listed in this Policy. Such data access will strictly take place on a “need to know” basis in order for the recipients to fulfill the processing purposes in their capacity;
Third parties that help us deliver our products to you, e.g. payment service providers, third-party logistics companies, third-party software companies;
Third parties that help us run our business, agent, contractor, supplier, vendor, or third- party service providers who provides administrative, IT, marketing, printing, fulfilment, web- tools, fraud prevention or other services to She or its affiliated companies;
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, security, insurance and accounting services;
Third parties that help She with events, travel, or conventions;
Third parties that help us collect surveys or feedback from you;
Internal Revenue Service, government agencies and regulators, and others who require
reporting of processing activities in certain circumstances; andLaw enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
She third-party service providers are required by law to take appropriate security measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you in accordance with legal requirements and with our instructions, and that they will take appropriate security measures to help prevent unauthorized or accidental access, processing, erasure, loss or use of the data transferred to these service providers for processing. She only permits them to process your personal data for specified purposes and with appropriate security measures in place.
What about other third parties?
She may also disclose your personal data to third parties as a result of or in preparation for the possible sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of She. If any change happens to the original process purpose or method, then the new owners may notify you and request your consent accordingly.
8. Data security
She endeavors to maintain appropriate physical, procedural and technical security over our offices, IT systems and data centers so as to prevent any unauthorized access, disclosure, copying, use or modification of personal data. She has put in place security measures appropriate to protect against the risk of personal data being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.
She has also put in place appropriate measures and procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will take commercially reasonable steps to ensure that any personal data held by us is protected against unauthorized or accidental access, processing, erasure, loss, or use.
9. How long will your personal data be kept?
She will only retain your personal data for as long as is necessary to fulfill the purposes for
which it is collected, which retention period is determined by the nature and duration of your relationship with She. This is subject to cases in which we may need to retain your data for longer than the retention period in order to comply with a legal requirement, such as a litigation hold or government investigation.
Different retention periods apply for different types of personal data and depending upon your country of residence. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, She may anonymize or take other similar technical methods related to the personal data so that it can no longer be associated with you, in which case She may use such information without further notice to you.
10. Your data subject rights
We will respond and honor your request as entitled to data subjects, on a case-by-case basis, according to the applicable Data Protection Legislation. Under certain circumstances, as proscribed by applicable Data Protection Legislation in your geographic country/region, you may have the right to:
Request access to and copy of your personal data. This enables you to have any incomplete or inaccurate information that we hold about you and to check that we are processing it lawfully;
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing;
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it;
Withdraw consent to our processing of your personal information. You can exercise this option at any time by contacting us, using the contact details outlined above. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in accordance with applicable Data Protection Legislation;
Object where we are processing your personal data for direct marketing purposes;
Make a complaint if you believe that She has breached this policy or applicable Data Protection Legislation; and
Other rights as authorized and permitted by the applicable Data Protection Legislation.
If you want to exercise any of the above rights, including the right to withdraw consent to the processing of your personal data, please contact She at support@thatshelife.com. We will deal with the foregoing request and provide a response thereto within 30 days unless the applicable Data Protection Legislation otherwise required, provided that we have all the necessary information. In cases where further information, assessment, or investigation is required, we will seek to agree on alternative time frames with you. When you request the erasure/restricted processing of your personal data or withdraw your consent to the processing of your personal data, please note that this may give rise to the termination of our relationship with you or prevent us from providing you with certain services/benefits. If you are not satisfied with our response or believe we are not lawfully processing your data, you can also complain to a supervisory authority at any time.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if any request made by you is clearly unfounded or excessive if permitted by applicable Data Protection Legislation. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
11. Cookies
When you visit She Website, we may obtain information about your general internet usage by depositing certain bits of information called "cookies" in your web browser software or the hard drive of your computer. Cookies are sent back only to the She Website that deposited them when a visitor returns to that site.
Cookies help us improve the She Website and provide you with a better and more personalized service. Some of the cookies we use are essential for the She Website to operate.
It is possible to switch off cookies by setting your browser preferences. Turning cookies off may result in a loss of functionality when using the She Website.
12. Changes to this policy
We may change this policy from time to time. Any changes we may make to this policy in the future will be posted on the She Website homepage. Where changes to this policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice, and/or appropriate consent if required by applicable Data Protection Legislation.