PRIVACY POLICY
STARFIT

FITSTARS - FZCO is an international company in the field of fitness and health, whose mission is to make self-care and regular physical activity the norm. FITSTARS - FZCO operates a partnership program for influencers and ambassadors aimed at promoting a healthy lifestyle and the online fitness lessons of FITSTARS – FZCO.

The website https://ambassadors.ae is used exclusively for partner registration, the provision of information, promotional tools and terms of cooperation, and is not a platform for providing fitness services to end users. All partner activities are carried out independently, and the Company provides only technical and organizational support within the framework of the applicable rules and agreements. The website https://ambassadors.ae is the property of FITSTARS – FZCO.

We have developed this Privacy Policy in accordance with international legislation in the field of personal data protection and the applicable legislation of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), in order to inform you about our procedures regarding the collection, use, disclosure, storage, clarification, updating, modification, retrieval, transfer, dissemination, provision, access, blocking, deletion and destruction of information on the website https://ambassadors.ae (hereinafter, the “Website”).

By using our Website and participating in the partnership program, you give us consent to collect, use and store your personal data and other information. You also agree to our Offer. Please review and accept our Offer if you wish to use our Website.

The terms set out below will help you better understand this Policy:

«Personal data» or «Personal information» means any information that identifies or can be used to directly or indirectly identify any natural person, including, without limitation, first name and last name, date of birth, email address, occupation, information regarding use of the service, gender or other demographic information.

«Processing of Personal data» means any operation or set of operations performed on Personal data, regardless of whether they are performed by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, use, disclosure or dissemination, and erasure or destruction.

«Controller» means a person or organization which, alone or jointly with others, determines the purposes and means of Processing of Personal data.

«Participant in the partnership program» or «Ambassador» or «User» or «You» means a natural person who is 18 years of age or older.

«FITSTARS – FZCO» or «company» or «we» means a company incorporated and operating under the laws of the United Arab Emirates, registered at: 25469–001, IFZA Business Park, DDP, Dubai Silicon Oasis, Dubai, UAE.

«Personal data information system» means a set of personal data contained in databases and information technologies and technical means that ensure their processing.

«Offer» means a digital agreement between the company and the ambassador regarding the latter’s participation in the company’s partnership program via the website https://ambassadors.ae.

«Cross-border transfer of personal data» means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign natural person or a foreign legal entity.

FITSTARS - FZCO acts as the Controller and Processor of your personal data.

The security and confidentiality of your personal data are important to us, and therefore we make every effort on a daily basis to ensure the security of your personal data. We use them strictly in accordance with this Privacy Policy and the applicable international legislation and legislation of the UAE, namely in accordance with the applicable legislation of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). We want to develop our partnership program with your help and provide you with quality cooperation, and therefore we may update and revise this Privacy Policy. By providing your personal data, you consent to their further processing by FITSTARS - FZCO and agree to receive any informational messages and other service notifications.

We will use your information only for the purposes set out below:

• When you visit our Website;
• When you fill out the registration form on the Website to become a participant in the partnership program (ambassador).

By accepting the terms of this Policy, you agree that access to the Website is always carried out in strict compliance with the following rules:

• You must use the Website exclusively in accordance with its intended purpose;
• Access to and use of the Website must be carried out by you in full compliance with the terms of this Policy, the Offer, the Consent of the personal data subject to the processing of his personal data, the Cookie Policy and other company documents, as well as the relevant applicable international legislative acts and legislative acts of the UAE;
• You are obliged to provide accurate and complete information about yourself and the persons you represent;
• You must not perform any actions directly prohibited by this Policy.

In case of violation of any rules of this Policy, the user’s access to the Website may be blocked for the entire period of the internal investigation regarding the violation.

• The Company processes personal data only on a lawful and fair basis:
  The Company does not disclose to third parties and does not disseminate personal data without the User’s consent, except in cases where such actions are permitted without the consent of the personal data subject in accordance with the applicable legislation;
• The Company determines specific lawful purposes before the start of processing (including collection/receipt) of personal data;
• Processing of personal data at the Company is limited to achieving specific, predetermined and lawful purposes.

FITSTARS - FZCO avoids collecting unnecessary personal data and collects only the information important for it for the purpose of processing and storage.

Our relations with Users are governed in accordance with the Offer posted on our Website.

YOU HEREBY CONFIRM THAT YOU PERSONALLY BEAR FULL RESPONSIBILITY FOR PROVIDING CONSENT TO FITSTARS - FZCO TO USE YOUR PERSONAL DATA FOR EFFECTIVE PARTICIPATION IN THE PARTNERSHIP PROGRAM VIA THE WEBSITE, AS WELL AS FOR THE FULFILLMENT OF THE COMPANY’S OBLIGATIONS. UNLESS OTHERWISE SPECIFIED, FITSTARS - FZCO ASSUMES THAT CONSENT WAS REQUESTED AND GIVEN.

When using the Website, you may provide us with any additional information about yourself.
When using the Website, we may also collect information related to the use of the Website and combine it with information about other users. This helps to improve the quality of our services for you.

Data that we may collect about you as a user of the FITSTARS - FZCO Website include:

• Personal information: such information may include your first and last name, patronymic; login and password; mailing address; postal code; email address; telephone number; IP address used to connect the computer to the Internet; computer and connection information such as browser type, version and time zone setting, types and versions of browser plug-ins, operating system and platform; language; registration date; internal user ID; date of birth; passport number; personal ID in social networks; company browsing history; tracking of the “Send data in SMS” functionality; tracking of the “build a route” functionality; data on the start and duration of the user’s sessions on the Website; viewing data during the user’s session; biometric personal data (user photographs).
• Related information. Some data that we receive may not be clearly identifiable. We may also collect such information as demographic data, information about your use of the service and general data related to the platform (Non-identifying information). We may collect information obtained from registered and unregistered platform users.
• Data from mobile devices (for example, location). We may use such information obtained through third-party services. However, you can hide it from us. If you do not know how to disable the location services of your device, we recommend that you contact your mobile operator or device manufacturer.
• Third parties may also provide us with information about you. If we combine this information with information about you collected through the service, we will continue to treat such combined information as set out in this Privacy Policy.

When you use the FITSTARS - FZCO Website, you agree to the collection of your personal information, and you also agree to receive emails, including the use of information for marketing mailings aimed at promoting our products or products similar to our products or services. You may withdraw your consent at any time by unsubscribing from our emails using the opt-out link contained in each email.

If you want to start using the Website, you must meet the following requirements.
If you are a natural person, then:

1. You must be 18 (eighteen) full years of age; and
2. You must be of legal age under the laws of the country from which you access and/or use the Website and/or services. If you have reached the age of 18 but are a minor under the laws of your country of residence, you are required to familiarize yourself with this Policy, and your legal representative must act on your behalf.

The Company is in no way responsible for deliberate actions of third parties with the aim of substituting or replacing the user or the company. Such person bears full personal responsibility.

We use your Personal data strictly in accordance with the legislation of the UAE and international legislation on personal data protection, other applicable data processing legislation, the Privacy Policy, the Offer, the Consent of the personal data subject to the processing of his personal data, posted on our Website, for one of the following purposes:

• identification of a participant in the partnership program;
• sending notifications and security confirmations;
• communication with the participant in his/her language;
• personalization of content and/or user convenience;
• recording, booking, authorization and administration;
• responses to your requests;
• providing marketing and event communications;
• conducting votes and surveys;
• for maintaining internal statistics;
• for improving our services;
• internal research and development;
• provision of services;
• legal obligations (for example, prevention of fraud);
• compliance with internal audit requirements;
• for the performance of our contractual obligations to you;
• for providing users of our platform with the platform and the corresponding functionality;
• analysis and improvement of our service;
• meeting information security needs and protecting our users;
• compliance with legal obligations: we must use and disclose personal information in certain ways in accordance with our legal obligations.

We also inform you of cases when a third party may request your Personal data from us:

• in response to lawful requests by public authorities, including to meet lawful requirements of national security or law enforcement;
• for protecting, establishing or exercising our legal rights or defending against legal claims, including debt collection; court rulings, court proceedings or other legal claims;
• when we in good faith believe that such disclosure is necessary to comply with legal requirements, to prevent imminent physical harm or financial loss, or to investigate, prevent or take action regarding illegal activity or suspected fraud.

Please note that the above lists are not exhaustive. We will record all the purposes for which we process your Personal data.
We use information collected through the service to provide and improve the service, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and in other cases permitted with your consent.

We may transfer your Personal information that is subject to Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) outside the UAE for permitted purposes as described above. This may include countries that provide the same level of protection as the laws of your country or another level. We guarantee that any such international transfers will be carried out in compliance with appropriate security measures where required by legislation or other applicable laws. You may contact us at any time using the contact information below if you need additional information about such safeguards.

With regard to persons subject to Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), in the case of transferring Personal information to countries or territories outside the UAE that are not recognized as providing an adequate level of data protection, we implement appropriate data transfer mechanisms, and any personal information will be protected.

If any information from the Personal data that you have provided to us changes, for example, if you change your email address or if you wish to cancel any request you have made to us, please inform us by contacting us by email at accounts@starfit.com.

We are not responsible for any losses arising from any inaccurate, unreliable, incomplete or incomplete Personal information that you provide to us.

You have a number of legal rights in relation to the Personal information that we hold about you. These rights include:

• Obtaining information about the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information (in particular, information that is legally protected);
• Requesting correction of your personal information if it is inaccurate or incomplete;
• Requesting deletion of your personal information in certain circumstances. Please note that there may be circumstances where you ask us to delete your personal information but we are legally entitled to retain it;
• Objecting to and requesting restriction of the processing of your personal information in certain circumstances. Again, there may be circumstances where you object or ask us to restrict our processing of your personal information, but we are legally entitled to refuse that request;
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another lawful reason (other than consent) to do so.

If you wish to do any of the above, please send an email to accounts@starfit.com.

We may work with advertising agencies and providers who use any technologies to help us understand how people use our Website. These providers may use technologies to display advertising that may interest you. You can opt out of receiving such advertising. Our service is not responsible for external advertising and cannot guarantee its absence.

You are hereby duly informed of the existence of algorithms of automated decision-making (including profiling) used by the Website, which help us improve our interaction with you as our User and improve your further experience with our Website. For example, such automated decision-making algorithms may help us customize your profile based on browsing history, user sessions and advertising that you view.

We have adopted all legislative requirements relating to our obligations as a Data Controller and/or Processor under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) in order to ensure an adequate level of data protection for you.

FITSTARS - FZCO has implemented all appropriate precautions to ensure that our clients meet the highest standards and principles of Personal data protection in accordance with the applicable legislation of the UAE and other relevant international standards.

To conduct our global operations, we may transfer and access Personal data from around the world. This Policy applies even if we transfer Personal data to other countries.

We use cookie identifiers and other similar tracking technologies so that you can use some of the basic functions of the Website. The Website may automatically collect Usage Data through cookies. A cookie is a small text file that a website uses to recognize repeated visits by users in order to ensure the user’s continuous access to the site and ease of use of the site. You can find detailed information in the Cookie Policy on our Website.

We always treat personal data with care and do not disclose your Personal data to other Participants, organizations or private individuals unless such disclosure is required to provide the company’s services or to conduct our business operations with you, as specified above for the purposes of processing such data.

In addition to the disclosure cases specified in this Policy, we may disclose information about you:

• to the extent that we are required to do so by law;
• in connection with any legal proceedings or prospective legal proceedings;
• for the purpose of establishing, exercising or defending our legal rights, including providing information to other persons for the purposes of fraud prevention and reducing credit risk;
• to companies (contractors) for which users request SMS with contact information;
• to third parties in the event of a merger, restructuring, joint venture, assignment, sale of part of the business or the entire business.

We may transfer data to trusted partners to contact you based on your request to receive such messages, to assist in conducting statistical analysis or customer support. Such third parties are prohibited from using your Personal data for any purpose other than these purposes and are required to maintain the confidentiality of your information. If you do not want us to transfer your personal data to these companies, please contact us by email at accounts@starfit.com.

In addition, we will transfer user data to companies (contractors) that are registered through their representative on our Website, in respect of which such users request SMS with contact information. In such cases, the following data are subject to transfer: First name, Last name, telephone, e-mail, time of the request.

We cooperate with other companies and individuals for the implementation of the partnership program by users of our Website, and we may need to share your data with them in order to provide you with information, products or services. Examples may include data analysis and the provision of additional services. In all cases where we transfer your information to such agents, we expressly require the agent to acknowledge and adhere to this Policy.

We always care about the security of your Personal data. We provide such capabilities to protect your information from gross violations. In accordance with the requirements of regulatory documents, we have created a personal data protection system consisting of subsystems of legal, organizational and technical protection.

The legal protection subsystem is a set of legal, organizational and regulatory documents that ensure the creation, functioning and improvement of the personal data protection system. The organizational protection subsystem includes the organization of the management structure of the personal data protection system, the permission system, and the protection of information when working with partners and third parties.

The technical protection subsystem includes a set of technical, software, and hardware-software tools that ensure the protection of personal data.

The main data protection measures used by the Operator are:

• Appointment of a person responsible for the processing of personal data.
• Determination of current security threats to personal data during their processing and development of measures and activities to protect personal data.
• Development of a policy regarding the processing of personal data.
• Establishment of individual employee access passwords to the information system in accordance with their job responsibilities.
• Application of information security tools that have undergone the prescribed conformity assessment procedure.
• Certified anti-virus software with regularly updated databases.
• Compliance with conditions that ensure the safety of personal data and exclude unauthorized access to them.
• Detection of unauthorized access to personal data and taking measures.
• Implementation of internal control and audit.

Information about your account is encrypted using a special password stored in a closed database that we do not disclose to anyone. In turn, we advise you to choose your password carefully and never disclose it to other persons, and to take care of the security of your computer and mobile phone.

We store information no longer than necessary. This implies that we will retain personal information for any period of time described below:

• for as long as required by law,
• for as long as we have strong reasons to retain it,
• until you ask us to stop using it,
• or for as long as our user for whom you are an authorized representative remains a user.

If you do not wish to be a participant in the partnership program, you may immediately delete your Personal data by sending us a request by email to accounts@starfit.com.

We reserve the right to retain information that is reasonably necessary after your account is closed where required to comply with applicable tax/income laws, resolve disputes, and enforce our agreements. We will delete this information as soon as such data become unnecessary, but no later than 5 years after your last use of our Website as a participant in the partnership program and provision of your personal data to us.

We value our clients, but we also value their freedom of choice. You may withdraw your consent to the processing of your information. You may do this at any time by deleting your data by sending an email to accounts@starfit.com with a request to delete your Personal data. You have the right to restrict the processing of your Personal data for certain purposes. If you have any objections to the processing of your Personal data, you may do so by sending an email to accounts@starfit.com.

We may refuse a request to access or correct personal information in circumstances provided by law. And if we do so, we will provide you with written notice of the reasons for the refusal. We can provide you with a copy of all Personal data that we have about you in electronic format.

You always have the opportunity and authority to export your Personal data collected or stored in digital form concerning you as our Participant by sending your electronic request to accounts@starfit.com.

You may clarify with us what Personal information we store and what we do with your data. If necessary, we can provide you with a copy of all data that we store about you.

The Website is not intended for and not directed to natural persons under 18 (eighteen) years of age, and we do not intentionally or deliberately collect information about such persons. If you suspect that we have collected information about a natural person under 18 (eighteen) years of age, please contact us by email at accounts@starfit.com so that we can delete such information.

There may be certain cases when FITSTARS - FZCO may contact you. Given the fact that registration on the Website or otherwise necessarily contains the relevant email address and/or your contacts, all notifications from FITSTARS - FZCO must be sent to your email and/or another method of communication. Push notifications may also be used on our Website to inform about certain alerts or important information.

As a rule, we may send you notifications and other information that we deem necessary (including certain advertising information) by one of the communication methods described below:

• Messages by email or push notifications
• Messages by phone
• Messages by email
• Messages by email or in your account

Since we are a company established in accordance with the legislation of the UAE, we process and store your information, among other things, on foreign servers, and our service providers may also process and store information on foreign servers. When we transfer your information to foreign servers, we protect personal data as described in this Policy.

When we transfer personal data outside the UAE, we rely on transfer mechanisms provided for by the PDPL and the relevant by-laws (including contractual safeguards and other appropriate protective measures). Such transfers are carried out where there is an adequate level of protection or where appropriate safeguards are applied in accordance with applicable law.

Our Website may contain links to other websites. We do not control and are not responsible for the content or practices of those other websites. Our provision of such links does not imply our endorsement of those other websites, their content, their owners or their practices. This Policy does not apply to those other websites, which are subject to any other privacy policies and other possible policies.

We may update this Policy from time to time by posting a new version on the Website. You should check this page from time to time to review any changes. If we make any material changes, we will notify you by posting the revised Policy on our Website and providing notice to your email address associated with your account. This will help you always stay informed about what information we collect, how we use it and under what circumstances, if any, it is disclosed. By continuing to use the Website and the FITSTARS - FZCO partnership program and/or by continuing to provide us with your Personal data, you will be subject to the terms of the Policy in effect at that time.

The person responsible for data protection (Data Protection Officer) is: ___________________. If you have any questions regarding this Policy or you wish to obtain additional information about the protection of your Personal data used on our Website, please contact us by email at accounts@starfit.com.