Privacy Policy

Last updated: February 07, 2024

Introduction

FLOW WITH ME PTE. LTD. trading as Flow with Mira (“we,” “our,” “us,” “the Company”) values and respects your privacy. This Privacy Policy describes our practices regarding the collection, use, and disclosure of your information through our online pilates instruction platform, accessible via our website (www.flowwithmira.com) and mobile applications (collectively, the “Service”).

This policy complies with Singapore’s Personal Data Protection Act (PDPA), the EU’s General Data Protection Regulation (GDPR), and California Consumer Privacy Act (CCPA), among other applicable privacy laws.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

Account: A unique account created for You to access our Service
Affiliate: An entity that controls, is controlled by or is under common control with a party
Application: The software program provided by the Company named Flow with Mira Online
Company: FLOW WITH ME PTE. LTD. trading as Flow with Mira
Country: Singapore
Device: Any device that can access the Service
Health Data: Information related to your physical condition, fitness goals, and exercise history
Personal Data: Any information relating to an identified or identifiable individual
Service: The Application or the Website or both
Service Provider: Any person or entity who processes data on behalf of the Company
Usage Data: Data collected automatically during Service use
Website: Flow with Mira, accessible from https://www.flowwithmira.com/
You: The individual accessing or using the Service

Types of Data Collected

1. Personal Data

While using our Service, we collect:

Email address
First name and last name
Phone number
Address information
Payment information
Gift subscription details

2. Health and Fitness Data

Through our fitness survey and Service usage, we collect:

Exercise history and experience
Fitness goals and preferences
Physical condition and limitations
Health concerns relevant to exercise
Workout completion records

This health-related information is:

Provided voluntarily by you
Used only for customizing your experience
Protected with enhanced security measures
Never shared for marketing purposes
Subject to specific retention policies

3. Usage Data

We automatically collect:

IP address
Device information
Browser type and version
Service usage patterns
Access times and dates
Feature interaction data
Technical diagnostic data

4. Mobile Device Data

When accessing via mobile devices:

Device type and ID
Operating system
Mobile browser type
IP address
Technical data

Use of Your Personal Data

1. Primary Uses

The Company uses Personal Data for:

Service Operation

Providing and maintaining our Service
Managing your account and subscription
Processing payments and transactions
Authenticating access

Communication

Service updates and notifications
Customer support responses
Technical alerts
Account-related messages

Health and Fitness Services

Customizing workout recommendations
Providing safety guidelines
Progress tracking
Content adaptation

Gift Subscriptions

Processing gift purchases
Managing recipient activation
Gift notifications
Subscription record maintenance

Service Improvement

Feature development
Performance optimization
User experience enhancement
Research and analysis

2. Data Sharing and Disclosure

Categories of Recipients

Service Providers

We share data with:

Payment Processors

Apple Store In-App Payments
Google Play In-App Payments
Stripe
PayPal For transaction processing only

Email Marketing

Kajabi For communications management

Analytics

Google Analytics For Service usage analysis

Social Media

Facebook
Instagram
YouTube
Pinterest For content delivery and marketing

Business Partners

Shared with:

Fitness content providers
Technology partners
Marketing collaborators Under strict data protection agreements

Legal Requirements

Disclosure when:

Required by law
Subpoena or court order
Government request
Rights protection

3. Data Transfer and Storage

International Transfers

Your data may be processed in:

Singapore
Other countries where we operate
Service provider locations

Transfer Safeguards

We ensure:

Appropriate security measures
Data protection agreements
Compliance with local laws
Standard contractual clauses

4. Data Retention

Retention Periods

We retain data for:

Active account duration
Legal requirement period
Business necessity timeframe

Health Data Retention

Specific retention for:

Fitness assessments
Workout history
Health information

Data Deletion

Process includes:

Secure erasure methods
Backup removal
Third-party notification
Verification procedures

Regional Privacy Rights and Compliance

1. Singapore Personal Data Protection Act (PDPA)

Your Rights

You have the right to:

Access your personal data
Correct inaccurate data
Withdraw consent
Request data portability
Data deletion request

Our Obligations

We commit to:

Obtaining valid consent
Ensuring data accuracy
Providing access and correction
Protecting data transfers
Security measures implementation

2. GDPR Compliance (For EU Residents)

Legal Bases for Processing

We process data under:

Consent
Contract performance
Legal obligations
Legitimate interests
Vital interests
Public interest

Your GDPR Rights

You may request:

Access to your data
Data rectification
Data erasure
Processing restriction
Data portability
Processing objection
Consent withdrawal

Data Protection Measures

We implement:

Privacy by design
Data protection impact assessments
Record keeping
Breach notification procedures

3. CCPA Compliance (For California Residents)

Categories of Personal Information

We collect:

Identifiers

Name
Address
Email
Phone number
IP address
Account name

Personal Information Categories

Financial information
Health information
Purchase history
Fitness data

Internet Activity

Browsing history
Search history
Service interaction

Health and Fitness Data

Exercise preferences
Physical condition
Fitness goals
Workout history

Your CCPA Rights

You have the right to:

Know what data is collected
Delete your data
Opt-out of data sales
Non-discrimination
Access your data

Exercise Your Rights

Request methods:

Email submission
Account settings
Online form
Authorized agent

4. Additional Regional Requirements

Australia Privacy Act

We comply with:

Collection notification
Use and disclosure
Data quality
Security measures

Canada PIPEDA

We ensure:

Consent collection
Limited collection
Limited use
Limited disclosure

Brazil LGPD

We maintain:

Processing principles
Legal bases
Subject rights
Security measures

Security and Data Protection

1. Security Measures

Technical Protection

We implement:

Data encryption in transit and at rest
Secure server infrastructure
Firewall protection
Access control systems
Regular security updates

Organizational Measures

We maintain:

Employee training programs
Access restriction policies
Security audit procedures
Incident response plans
Data handling protocols

Health Data Security

Enhanced protection for:

Fitness assessments
Health information
Medical conditions
Exercise history

2. Data Breach Procedures

Notification Process

We will:

Assess breach impact
Notify affected users
Alert authorities if required
Take remedial action
Document the incident

Response Timeline

Immediate internal notification
72-hour authority notification
User notification as required
Regular status updates

Children’s Privacy

1. Age Restrictions

Service not intended for under 13
No knowing collection from minors
Immediate data deletion if discovered
Parental consent required where applicable

2. Verification

We may:

Verify age claims
Request parental consent
Remove underage accounts
Block underage registration

Changes to This Privacy Policy

1. Update Procedures

We may modify this policy:

To reflect service changes
For legal compliance
To enhance protection
To improve clarity

2. Notification Methods

We will inform you through:

Email notification
Service announcement
Website notice
App notification

3. Prior Notice

30 days notice for material changes
Immediate effect for legal requirements
Clear communication of changes
Option to review changes

Contact Information

1. Company Details

FLOW WITH ME PTE. LTD. trading as Flow with Mira [Your Singapore Business Address]

2. Data Protection Contacts

Primary Email: [email protected]
Data Protection Officer
Regional Representatives

3. Regional Offices

Singapore (Primary)
EU Representative
UK Representative
California Representative

Final Provisions

1. Language

English version prevails
Translations for convenience
Interpretation guidelines

2. Governing Law

Singapore law applies
Singapore courts’ jurisdiction
International transfer compliance

3. Severability

Invalid provisions separable
Remaining terms intact
Modified terms when required

4. Entire Agreement

This Privacy Policy:

Constitutes entire agreement
Supersedes prior versions
Incorporates referenced policies
Includes all amendments

Acknowledgment

By using our Service, you acknowledge:

Reading this Privacy Policy
Understanding your rights
Consenting to data collection
Accepting update procedures

Last Updated: February 07, 2024 Effective: March 08, 2024