Privacy Policy

Last Updated:  July 8, 2026

1. INTRODUCTION

Welcome to the UREVO Privacy Policy.

This Privacy Policy is issued by UREVO and its affiliates (collectively, “UREVO”, “we”, “us”, or “our”).

We are a digital-first direct-to-consumer (DTC) fitness technology brand. Our Services are provided exclusively through online and digital channels, including our official website, mobile applications, connected fitness devices, and authorized third-party digital platforms.

This Privacy Policy explains how we collect, use, store, and share your Personal Information when you access or use our Services, including:

  • Our official website contact: contact@urevo.com.
  • UREVO App mobile application
  • Smart fitness equipment (including treadmills and walking pads such as CyberPad / SpaceWalk / Foldi series)
  • Device connectivity and firmware services
  • Customer support and service communications
  • Authorized third-party fitness integrations (e.g., Apple Health, Google Fit, Zwift, Kinomap)

We do not sell your Personal Information or Fitness Data.

If you do not provide necessary Personal Information required for core functionality, certain Services such as account registration, device pairing, order fulfillment, or workout tracking may not be available.

This Privacy Policy should be read together with our Terms of Use. By using our Services, you acknowledge and agree to this Policy.

2. INFORMATION WE COLLECT

We apply a data minimization principle, meaning we only collect Personal Information that is necessary to operate, maintain, and improve our Services.

We collect information in the following categories:

2.1 Information you provide to us

We may collect Personal Information that you voluntarily provide, including:

Account and registration information

  • Email address
  • Phone number
  • Login credentials (encrypted password)
  • Account profile information

Order and transaction information

  • Shipping and billing details
  • Order history
  • Warranty and after-sales service requests
  • Purchase records processed via third-party e-commerce platforms

Profile and fitness-related information

  • Height, weight, age (if provided)
  • Fitness goals and preferences
  • Health or workout preferences you voluntarily submit

Some of this information may constitute Sensitive Personal Information under applicable laws.

Customer support information

  • Emails and chat records
  • Service inquiries and feedback
  • Support communication history

UGC (User Generated Content)

  • Workout posts
  • Comments and reviews
  • Fitness progress records
  • Profile images or avatars

Referral information

  • Contact information you choose to provide when inviting others to join UREVO

Optional social features

Where enabled, you may allow limited contact synchronization for the purpose of identifying existing UREVO users. This feature is optional and not required for core Services.

2.2 Information collected automatically

Sensor-generated and interaction data

  • Movement and treadmill activity data generated during device usage
  • Interaction data from App features and connected services

Optional Intelligent Features

Where enabled, UREVO may provide optional intelligent features, including:

  • Voice control
  • Facial recognition or biometric authentication
  • Camera or image processing-based functionality

These features are:

  • Strictly optional and disabled by default
  • Activated only with explicit user consent
  • Processed locally on the device or in real time where possible
  • Not used for advertising, profiling, or marketing purposes
  • Not used to train general-purpose machine learning models without explicit consent

Users may enable or disable these features at any time in device or App settings.

2.3 Information from third parties

We may receive information from:

Connected fitness platforms (with your authorization)

  • Apple Health
  • Google Fit
  • Zwift
  • Kinomap

Third-party account providers

  • Social login services (basic profile data only)

E-commerce and payment partners

  • Order and transaction confirmation data
  • Payment status (we do not store full card details)

Fraud prevention and security providers

  • Device risk signals
  • Authentication-related identifiers

3. HOW WE USE YOUR PERSONAL INFORMATION

We process your Personal Information for the purposes described below and in accordance with applicable data protection laws.

3.1 Provision of core services

We use your Personal Information to provide and operate core functionality, including:

  • Account creation and authentication
  • Device pairing and connectivity (e.g., Bluetooth connection with UREVO devices)
  • Workout tracking and history storage
  • Order processing and fulfillment (via third-party e-commerce platforms)
  • Device firmware updates and maintenance
  • Customer support and troubleshooting
  • Pre-sale consultation and service inquiries

3.2 Service communications

We may use your Personal Information to send service-related communications, including:

  • Order confirmation and logistics updates
  • Device status and malfunction notifications
  • Security alerts and account protection notices
  • Policy updates and service announcements
  • Customer support responses
  • Product safety or recall notifications

3.3 SmartCoach and personalized services

We may use your data to provide personalized fitness services, including:

  • Workout analysis and fitness insights
  • Personalized training recommendations
  • SmartCoach algorithm optimization

We may use aggregated, pseudonymized, or de-identified data to improve system performance and recommendation quality.

SmartCoach provides fitness recommendations and insights based on your activity data. These recommendations are intended to support your fitness experience and do not constitute medical advice, professional coaching, or decisions that produce legal or similarly significant effects.

You may disable personalization features at any time in App settings. After disabling, personalized recommendations will stop.

3.4 UGC (User Generated Content)

When you submit content such as posts, comments, reviews, workout records, or avatars within the App, you grant UREVO a limited, non-exclusive license to host, store, display, and process such content solely for providing and improving the Services.

You retain ownership of your content.

You may delete your content at any time. After deletion:

  • Content will no longer be publicly visible
  • Residual copies may remain in backup systems for a limited period or where required by law
  • Aggregated or anonymized analytics may be retained

3.5 Analytics, product improvement, and research

We use Personal Information to:

  • Analyze usage patterns of Apps and devices
  • Improve product performance and system stability
  • Develop new features
  • Conduct internal business analytics

We may use aggregated or properly de-identified data that cannot reasonably identify any individual user.

3.6 Marketing and promotional communications

We may send marketing communications, including:

  • Email promotions
  • App push notifications
  • Product updates and offers

User controls:

  • Email unsubscribe link
  • SMS opt-out (reply STOP)
  • App notification settings

You will still receive non-marketing service messages such as:

  • Order updates
  • Security alerts
  • Service notifications

3.7 Security and fraud prevention

We process Personal Information to:

  • Detect unauthorized access
  • Prevent fraudulent activity
  • Protect account and device security
  • Monitor abnormal usage patterns

3.8 Legal compliance and dispute handling

We may process Personal Information to:

  • Comply with legal obligations
  • Respond to lawful requests
  • Handle disputes and enforce agreements
  • Maintain required business records

3.9 Business operations

We may use Personal Information for:

  • Internal reporting and analysis
  • Service optimization
  • Corporate restructuring, merger, or acquisition scenarios

4. HOW WE SHARE YOUR PERSONAL INFORMATION

We do not sell Personal Information or Fitness Data.

We only share information in the limited circumstances described below.

4.1 Service providers

We may share Personal Information with third-party service providers, including:

  • Cloud infrastructure providers
  • Payment processors (e.g., PayPal, Stripe, Shopify Payments)
  • Logistics and fulfillment partners
  • Customer support service providers
  • Analytics and monitoring providers
  • IT and technical service providers

Where required by applicable laws, we enter into appropriate data protection agreements with service providers and require them to process Personal Information only for authorized purposes.

They are prohibited from:

  • Using Personal Information for their own independent marketing purposes;
  • Selling Personal Information or using it for unrelated commercial purposes;
  • Retaining Personal Information beyond the period necessary to provide the contracted services, except where retention is required for legitimate business purposes or by law.

4.2 Affiliates

We may share Personal Information with affiliated entities for:

  • Internal administration
  • Service operation and maintenance
  • Customer support coordination

Where required, cross-border transfers are protected by appropriate safeguards (e.g., SCCs).

4.3 Analytics and advertising partners

We may share:

  • Aggregated information;
  • Pseudonymized identifiers where appropriate;
  • Usage information and measurement data.

for analytics, performance measurement, and advertising effectiveness.

Where required by applicable law, you may opt out of such processing via available privacy controls.

Where required by applicable laws, we will obtain your consent before using cookies or similar tracking technologies for advertising and analytics purposes.

4.4 Third-party fitness platforms

With your explicit authorization, we may share Fitness Data with:

  • Apple Health
  • Google Fit
  • Zwift
  • Kinomap

You may revoke authorization at any time in App settings. After revocation, data sharing will stop immediately.

These third-party services process data under their own privacy policies.

4.5 Legal disclosure

We may disclose Personal Information when required by:

  • Valid legal requests
  • Court orders or subpoenas
  • Government or regulatory authorities

Where legally permitted, we may notify you before disclosure.

We only disclose the minimum data required.

4.6 Business transfers

In the event of a merger, acquisition, restructuring, or asset transfer:

  • Personal Information may be transferred as part of the transaction
  • We will ensure appropriate legal safeguards are applied
  • Users will be notified where required by law

4.7 In-app visibility features

Certain App features may allow limited visibility of user activity, such as:

  • Leaderboard rankings
  • Challenge participation results
  • Aggregated performance statistics

You may control visibility or opt out in App settings.

4.8 SDKs and embedded technologies

We use third-party SDKs for:

  • Analytics
  • App performance monitoring
  • Feature functionality

5. COOKIES, ANALYTICS AND SIMILAR TRACKING TECHNOLOGIES

UREVO and our third-party providers use cookies and similar tracking technologies to collect information about your interactions with our website, applications, and online services.

These technologies help us operate our Services, improve user experience, analyze website usage, provide personalized content and advertisements, measure the effectiveness of our marketing activities, and support other activities described in this Privacy Policy.

You can manage your cookie preferences at any time through the Cookie Settings tool available on our website. Where required by applicable laws, we will obtain your consent before placing non-essential cookies or similar tracking technologies on your device.

5.1 Types of cookies and similar technologies we use

We classify cookies and similar tracking technologies into the following categories:

Strictly Necessary Cookies

These cookies are essential for the operation of our website and cannot be disabled.

They enable core functions such as website security, account authentication, shopping cart functionality, checkout processes, payment-related services, and saving your privacy preferences.

These cookies do not require consent where they are necessary to provide services requested by you or to ensure the proper functioning of our website.

Analytics and Performance Cookies

These cookies help us understand how visitors use our website and applications, including website traffic, user interactions, and performance.

We use these technologies to analyze usage trends, identify technical issues, improve website functionality, and enhance user experience.

The information collected through these technologies may include information about your device, browser, pages visited, interactions with our Services, and usage patterns.

Functional Cookies

These cookies allow our website to remember choices you make and provide enhanced functionality and personalization.

They may be used to remember information such as your language preference, region settings, account preferences, or other customized settings.

These cookies help provide a more convenient and personalized experience when you use our Services.

Advertising and Targeting Cookies

These cookies may be used by UREVO and our advertising partners to provide more relevant advertisements and content, measure advertising effectiveness, and improve our marketing activities.

These technologies may collect information about your interactions with our website and may use identifiers associated with your browser or device to support targeted advertising activities.

Where required by applicable laws, we will obtain your consent before using advertising and targeting cookies.

5.2 Third-Party tracking technologies

We may allow third-party service providers, including analytics providers, advertising partners, and social media platforms, to use cookies and similar tracking technologies on our Services.

These third parties may collect information about your online activities over time and across different websites or online services.

The use of these technologies by third parties is subject to their own privacy policies and practices. We encourage you to review the privacy policies of these third parties to understand how they collect and use information.

5.3 Managing your cookie preferences

You can manage your cookie preferences at any time through the Cookie Settings tool available on our website.

Depending on your location and applicable privacy laws, you may be able to accept, reject, or customize certain categories of cookies.

You may also manage cookies through your browser settings, including deleting existing cookies or blocking certain cookies. Please note that disabling certain cookies may affect the functionality or availability of some features of our Services.

For more information about our use of cookies and similar tracking technologies, please see our Cookie Policy.

5.4 U.S. privacy rights regarding cookies and similar technologies

Certain sharing of information collected through cookies and similar tracking technologies, including information used for advertising measurement, analytics, or cross-context behavioral advertising, may be considered “sharing” under certain U.S. privacy laws.

Where required by applicable U.S. privacy laws, eligible users may have the right to opt out of such sharing.

You may exercise applicable rights by adjusting your cookie preferences through our Cookie Settings tool or by following the instructions described in this Privacy Policy.

6. FITNESS DATA

6.1 Definition of Fitness Data

“Fitness Data” refers to exercise-related information generated through UREVO devices and App usage, including but not limited to:

  • Workout duration
  • Speed and distance
  • Step count (where applicable)
  • Estimated calorie consumption
  • Heart rate data (when available via connected third-party devices)
  • Incline training records
  • Outdoor GPS route data (only when enabled by the user)
  • Workout history and performance records

Certain Fitness Data may constitute Sensitive Personal Information or special categories of personal data under applicable laws, depending on the jurisdiction, such as heart rate data or precise location data.

6.2 Scope of data collected

We may collect the following categories of Fitness Data:

  • Device operation and sensor logs
  • User-provided physical profile information (e.g., height, weight)
  • Workout history and session records
  • Outdoor activity route data (if enabled by the user)
  • Derived performance metrics generated from workouts
  • Aggregated statistical fitness summaries

6.3 Use of Fitness Data

We use Fitness Data for the following purposes:

  • Store and display workout history
  • Provide SmartCoach features as described in Section 3
  • Improve device performance and algorithm accuracy using aggregated or de-identified data
  • Analyze usage patterns to improve product and Service quality

We may use aggregated, pseudonymized, or properly de-identified data for product improvement, analytics, and system optimization. Such data cannot reasonably identify any individual user.

We do not use identifiable raw Fitness Data for unrelated purposes without your consent.

Visibility and community features

When leaderboard, challenge, or community features are enabled, certain aggregated or anonymized performance metrics (such as workout duration, distance, or calorie consumption) may be visible to other users participating in the same feature.

Your detailed Fitness Data and full workout history remain private by default unless you choose to actively share such information in your App settings.

You may control or disable visibility-related features at any time in the App.

6.4 Sharing of Fitness Data

We do not sell Fitness Data or disclose it to insurance companies, medical institutions, or data brokers.

We may share Fitness Data only in the following limited cases:

  • Service providers bound by Data Processing Agreements (DPAs), such as cloud hosting and analytics providers
  • Third-party fitness platforms you explicitly authorize (e.g., Apple Health, Google Fit, Zwift, Kinomap)
  • Aggregated or properly de-identified data used for analytics and service improvement

6.5 Multi-user device isolation

If multiple user accounts are used on a single UREVO device, each user’s Fitness Data is stored separately and is not merged or cross-linked.

Users are responsible for safeguarding their account credentials.

6.6 Medical disclaimer

Fitness Data and SmartCoach recommendations are provided for general fitness and wellness purposes only and do not constitute medical advice, diagnosis, or treatment.

The Services are not intended for medical monitoring, clinical use, or rehabilitation purposes.

Users with medical conditions, pregnancy, or recovery needs should consult a healthcare professional before use.

To the maximum extent permitted by applicable law, UREVO is not responsible for decisions made based on Fitness Data.

6.7 Biometric information notice

Where biometric features are enabled, we process biometric information only with appropriate consent where required by applicable law and solely to provide the user-requested functionality.

We do not use biometric data for unrelated identification, profiling, or advertising purposes.

Biometric data, where applicable, is processed solely to provide the specific functionality explicitly requested by the user, such as facial recognition-based authentication or personalization features.

Where biometric features are enabled:

  • Processing is performed locally on the device or in real time
  • Biometric data is not stored or retained on UREVO servers unless explicitly required for a user-enabled feature and only with the user’s explicit consent
  • Biometric data is not shared with third parties for advertising, marketing, or profiling purposes
  • Biometric data is not used to train general-purpose machine learning models without explicit consent

Users may enable or disable biometric features at any time through device or application settings.

6.8 Data ownership, rights, and export

You have rights over your Fitness Data, including:

  • Right to access your data
  • Right to export data in machine-readable formats (CSV, JSON, GPX)
  • Right to request deletion of your data

Upon deletion or account closure, your data will generally be deleted, anonymized, or de-identified in accordance with applicable retention requirements.

7. INTERNATIONAL DATA TRANSFERS

7.1 Cross-border data scope

Your Personal Information and Fitness Data may be transferred to, stored in, and processed in countries or regions outside your country of residence where UREVO, its affiliates, or its service providers operate.

These jurisdictions may have different data protection laws from those in your country of residence. Where such transfers occur, we implement appropriate safeguards to ensure your data is protected in accordance with applicable data protection laws.

7.2 Purposes of cross-border transfers

We may transfer personal data internationally for the following purposes:

  • Global cloud infrastructure hosting and system operation
  • Cross-regional customer support and service delivery
  • Product analytics, performance monitoring, and service optimization
  • Internal business administration and operational efficiency

7.3 Safeguards for cross-border transfers

EU & UK users:

We rely on Standard Contractual Clauses (“SCCs”) approved by the European Commission for transfers of Personal Information outside the EEA/UK. You may request a copy of applicable safeguards via service_eu@urevo.com.

Technical and organizational safeguards:

We implement appropriate security measures, including:

  • TLS encryption for data transmission
  • AES encryption for data storage
  • Access control and authorization management
  • Regular security testing and risk assessments

Mainland China users:

We comply with applicable PRC data protection laws, including required security assessments or personal information protection impact assessments where applicable.

Where data is transferred internationally, we ensure an essentially equivalent level of protection to that required under applicable data protection laws.

Data minimization principle:

Where legally permitted, cross-border transfers are limited to the minimum amount of Personal Information necessary for the relevant processing purposes.

7.4 Third-party overseas service providers

Where required by applicable law, overseas service providers are required to:

  • Enter into appropriate data protection agreements (such as DPAs or equivalent mechanisms);
  • Implement security measures consistent with applicable laws and UREVO standards;
  • Process Personal Information only for authorized purposes.
  • Not use Personal Information for purposes unrelated to the authorized services they provide to UREVO, unless permitted by applicable law.

8. YOUR PRIVACY RIGHTS AND PREFERENCES

8.1 Your statutory privacy rights

Subject to applicable laws, you may have the following rights:

  • Right to access your Personal Information
  • Right to correct inaccurate or incomplete data
  • Right to request deletion of your Personal Information
  • Right to restrict or object to certain processing activities
  • Right to data portability (CSV, JSON, GPX where applicable)
  • Right to object to marketing communications or profiling
  • Right to withdraw consent at any time (where applicable)

Withdrawal of consent does not affect processing carried out before withdrawal.

8.2 How to exercise your rights

You may submit requests via:

  • Email: contact@urevo.com
  • UREVO App Privacy Center

For security purposes, we may require identity verification (e.g., email address, account information, or other information reasonably necessary to verify your identity).

Response timeframes vary depending on applicable privacy laws. For example:

  • EU / UK / EEA: generally within one month
  • California: generally within 45 days
  • Other jurisdictions: according to applicable legal requirements

We may extend these timeframes where permitted by law.

8.3 Authorized agent requests

You may authorize a third party to submit requests on your behalf. We may require written authorization and identity verification before processing such requests.

8.4 Limitations to your rights

We may be unable to fully comply with a request where:

  • Required for legal, tax, or regulatory obligations
  • Necessary to protect security and rights of other users
  • Required for fraud prevention or system security
  • Required for dispute resolution or order fulfillment

Where applicable, we will provide an explanation.

9. DATA RETENTION & DATA DESTRUCTION MECHANISM

We retain Personal Information only for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by applicable laws.

After the retention period expires, Personal Information will be deleted or anonymized so that it can no longer reasonably identify any individual user.

9.1 Data retention schedule

Data Category Retention Period
Account information & fitness records During the active account period; after account deletion, generally deleted or anonymized within 15 working days.
Order & payment records Retained as required by applicable tax and accounting laws
Customer service records Up to 3 years after last interaction
Device logs & analytics data Typically anonymized or deleted within 90 days
Network and system logs Up to 6 months
Marketing communication logs Up to 6 months

Retention periods may vary where required by applicable law.

9.2 Data destruction mechanisms

We apply appropriate technical and organizational measures for data deletion, including:

  • Cloud data: securely deleted and overwritten in backend systems
  • Device-local data: may be cleared via App or device settings
  • Paper records (if any): securely shredded
  • Backup data: encrypted backups retained for up to 30 days for disaster recovery, then permanently deleted.

After account deletion, Personal Information will generally be deleted, anonymized, or de-identified within approximately 15 working days, subject to legal retention obligations, backup retention requirements, and legitimate business purposes.

Some residual data may persist temporarily in secure backup systems before final deletion.

Where legal retention obligations apply, such obligations will take precedence over user deletion requests.

10. SECURITY OF YOUR INFORMATION

We implement appropriate technical, organizational, and administrative measures to protect your Personal Information and Fitness Data against unauthorized access, alteration, disclosure, or loss.

10.1 Technical security measures

We implement industry-standard security technologies, including:

  • TLS encryption for data transmission
  • AES encryption for data storage
  • Access control and permission management
  • Multi-factor authentication where applicable
  • Security monitoring, logging, and vulnerability testing

Device-local cached data stored on UREVO hardware is not automatically uploaded to our servers. You may delete such data via device or App settings.

10.2 Organizational security measures

We implement internal security controls, including:

  • Role-based access control (RBAC)
  • Confidentiality obligations for authorized personnel
  • Privacy and security training programs
  • Internal audits and compliance monitoring

Customer support communications may be recorded after prior notice and are retained only for quality assurance and dispute resolution purposes, in accordance with applicable laws.

10.3 Data security incident response

In the event of a Personal Information security incident, we will take appropriate measures, which may include:

  • Conducting investigation and risk assessment
  • Notifying affected users where required by applicable law
  • Reporting to relevant regulatory authorities where required
  • Implementing remedial security measures (e.g., password reset or account protection steps)

10.4 Third-party services disclaimer

This Privacy Policy applies only to Personal Information processed under UREVO’s control.

We are not responsible for the privacy or security practices of third-party services you choose to connect or use, including Apple Health, Google Fit, Zwift, Kinomap, social login providers, and payment processors.

These third parties operate independently under their own privacy policies.

We encourage you to review their privacy policies before authorizing data sharing.

10.5 Data protection impact assessment

Where required by applicable law, we conduct assessments for high-risk processing activities, including:

  • SmartCoach personalization and profiling
  • Processing of Sensitive Personal Information or special categories of personal data, including Fitness Data, at scale
  • Large-scale analytics using aggregated or de-identified data

These assessments help identify and mitigate privacy risks before processing begins.

No system of data transmission or storage is completely secure.

11. LEGAL BASIS FOR PROCESSING

If you are located in the European Economic Area, United Kingdom, or other applicable European regions, we process your Personal Information based on the following legal bases:

  • Performance of a contract: account creation, device pairing, workout tracking, and order fulfillment
  • Legitimate interests: service improvement, analytics, fraud prevention, and service communications
  • Consent: marketing communications, non-essential analytics, and certain personalization features where required
  • Legal obligation: compliance with applicable tax, accounting, and regulatory requirements

Where processing is based on consent, you may withdraw consent at any time.

Legal bases apply per processing purpose as described in Section 3 of this Privacy Policy.

12. CHILDREN’S PRIVACY

Age requirements may vary depending on jurisdiction and specific service features.

Our Services are not directed to children under the minimum age required by applicable laws. We do not knowingly collect Personal Information from children without verifiable parental or guardian consent.

Minimum age requirements:

  • United States: 13 years old (COPPA)
  • European Union / United Kingdom: generally 16 years old, or the applicable local age requirement (which may vary between 13 and 16 depending on jurisdiction)
  • Canada: generally 13 years old, subject to applicable provincial requirements

If we become aware that we have collected Personal Information from a child without valid consent, we will delete such information in accordance with applicable laws.

We do not knowingly provide marketing communications or personalized SmartCoach features to child accounts.

Where required, parental or guardian consent is necessary for processing Sensitive Personal Data of minors.

If an account is identified as belonging to a child without valid consent, we may restrict certain features, including cloud synchronization, community features, or data storage, until verification or deletion is completed.

13. U.S. STATE PRIVACY NOTICE

This section applies to residents of U.S. states with applicable consumer privacy laws.

Your privacy rights

Subject to applicable law, you may have the following rights:

  • Right to know categories and purposes of Personal Information collection and use
  • Right to access, correct, and request deletion of Personal Information
  • Right to opt out of cross-context behavioral advertising “sharing”
  • Right to limit use of Sensitive Personal Information, including Fitness Data
  • Right to non-discrimination for exercising privacy rights

You may exercise your rights via the UREVO App Privacy Center or designated request channels.

Opt-out of “sharing”

California residents may opt out of cross-context behavioral advertising via:

  • “Your Privacy Choices” link available on our website, allowing you to manage your privacy preferences and exercise applicable privacy choices.
  • UREVO App Privacy Center.

CCPA/CPRA statement

We do not sell Personal Information for monetary consideration.

Certain limited processing of device identifiers or pseudonymized data for advertising measurement may be considered “sharing” under applicable law. You may opt out as described above.

California Shine the Light notice

California residents may request information once per year regarding disclosure of Personal Information to third parties for direct marketing purposes under California Civil Code §1798.83.

Requests may be submitted via contact@urevo.com. We do not disclose Personal Information to third parties for their independent direct marketing purposes without consent.

Biometric information and related technologies

Where biometric features are enabled, we may process limited biometric information solely to provide user-requested functionality, such as facial recognition-based authentication or personalization features. If users voluntarily upload content containing biometric information, such data will only be processed within the scope of user sharing and will not be used for unrelated identification, profiling, or advertising purposes.

We will not use biometric information for purposes unrelated to the requested functionality without obtaining additional consent where required by applicable law.

Biometric features are optional and may be disabled through applicable device or App settings where available.

14.EU / UK PRIVACY NOTICE

For users in the EEA, the United Kingdom, and other applicable European regions, ZHILE HOLDING GROUP (HK) LIMITED acts as the data controller responsible for processing your Personal Information.

This section applies to users in the European Economic Area (EEA), United Kingdom, and other applicable European regions.

Under applicable data protection laws, you may have the following additional rights:

  • Right to lodge a complaint with your local supervisory authority
  • Right to request access to Personal Information processed about you
  • Right to request rectification or deletion of your Personal Information
  • Right to object to processing based on legitimate interests or direct marketing
  • Right to restrict processing under applicable legal conditions
  • Right to data portability, where applicable

We process Personal Information in accordance with applicable GDPR / UK GDPR requirements, including principles of lawfulness, fairness, transparency, data minimization, and storage limitation.

Where applicable, we may rely on Standard Contractual Clauses (SCCs) or other appropriate safeguards for international data transfers.

You may request a copy of applicable transfer safeguards via service_eu@urevo.com.

15. CANADA PRIVACY NOTICE

We process Personal Information of Canadian users in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant provincial regulations.

Subject to applicable legal requirements, you may:

  • Withdraw consent at any time (where processing is based on consent)
  • Request access to or correction of your Personal Information
  • Request information about how your Personal Information is used and disclosed
  • Request deletion of your Personal Information, subject to legal retention obligations

We will only disclose Personal Information to government authorities where required by valid legal process.

For privacy-related inquiries, please contact: contact@urevo.com.

16. HOW TO CONTACT US

For privacy-related requests, please contact the UREVO entity responsible for your region:

United States and Canada:

Email: contact@urevo.com

European Economic Area (EEA), United Kingdom, and other applicable European regions:

Email: service_eu@urevo.com

You may also submit requests through the UREVO App Privacy Center.

We may require identity verification (such as email address, account information, or other information reasonably necessary to verify your identity) to protect account security.

We respond to requests within applicable legal timeframes.

If you have difficulty contacting the applicable UREVO entity, you may also contact general support for assistance.

Data controller

UREVO Services are operated by different UREVO entities depending on your location.

For users located in the United States and Canada, UREVO WELLNESS US CO., LTD acts as the data controller responsible for processing your Personal Information.

For users located in the European Economic Area (EEA), the United Kingdom, and other applicable European regions, ZHILE HOLDING GROUP (HK) LIMITED acts as the data controller responsible for processing your Personal Information.

The applicable UREVO entity responsible for your Personal Information is determined based on your country or region of residence and the services you use.

General Support (for general product or service inquiries):

Email: contact@urevo.com

US Hotline: +1844-998-2473 (Mon–Sun 9AM–6PM PST)

17. ACCOUNT CANCELLATION AND DATA DELETION

17.1 Account cancellation

You may request account cancellation through the UREVO App:

Settings → Privacy → Delete Account (where available)

17.2 Effects of account cancellation

Upon cancellation:

  • We will stop providing account-based Services
  • Your data will generally be deleted, anonymized, or de-identified unless retention is required by law or necessary for legitimate business purposes.
  • Certain transaction, tax, or legal compliance records may be retained where required by applicable law

Where feasible, retained data will be stored in a non-identifiable or restricted-access form.

Where legal retention obligations apply, such obligations will take precedence over deletion requests.

Some residual copies may remain in secure backup systems for a limited period before being automatically deleted.

17.3 Third-party connections

After cancellation:

  • Device bindings will be removed
  • Third-party fitness integrations (e.g., Apple Health, Google Fit, Zwift, Kinomap) will be disconnected and access revoked
  • Cloud-based workout history and account services will no longer be accessible

17.4 Withdrawal of account deletion request

Where applicable, you may withdraw an account deletion request within a limited period before deletion is finalized. After processing begins, deletion may not be reversible in certain cases.

We recommend exporting your data before initiating deletion requests.

18. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in business operations, technical developments, or legal requirements.

18.1 Types of updates

Minor updates

Such as wording clarifications, formatting changes, or contact updates. These may be updated without separate notice, and only the “Last Updated” date will be revised.

Material updates

Including changes involving:

  • Processing of Sensitive Personal Information
  • Cross-border data transfers
  • Data sharing practices with third parties
  • User rights or data subject rights
  • Corporate structure or data controllers
  • Mergers, acquisitions, or restructuring involving Personal Information

18.2 Notification of material changes

Where required by applicable law, we will notify users in advance via email and/or App notifications.

The updated Privacy Policy will take effect on the stated effective date. Where required by applicable law, we will obtain additional consent or provide additional notice before implementing material changes. If you do not agree with the revised Privacy Policy, you may discontinue use of the Services or contact us regarding available privacy choices or account options.