I. PERSONAL INFORMATION WE COLLECT

We collect the following categories of personal information and may have collected such information during the past 36 months:

Category: Customer Identifiers

Specific Information Collected: Name, email address, physical address, phone number, date of birth, gender, and IP address.

Source and Purpose: Provided directly by individuals when registering for Sydney’s Army Bootcamp services, programs, classes, events, or other activities. This information is used to register and communicate with participants and provide our Services.

Category: Emergency Contact Identifiers

Specific Information Collected: Name and phone number.

Source and Purpose: Provided by individuals for use in the event of a health or other emergency while participating in Sydney’s Army Bootcamp Services. Collection of emergency contact information is not mandatory unless otherwise required for a particular program or activity.

Category: Consumer Personal Information

Specific Information Collected: Name, email address, physical address, phone number, date of birth, and financial or payment information.

Source and Purpose: Provided directly by individuals when registering for or purchasing Sydney’s Army Bootcamp Services. This information is used to process registrations and payments and provide our Services.

Category: Geolocation Information

Specific Information Collected: General location information, such as country, city, physical address, and longitude/latitude coordinates where applicable.

Source and Purpose: May be collected from your device, where permitted by your device settings, and through your interactions with our website or online services. This information may be used to provide our Services, understand how customers interact with our business, perform analytics, and improve marketing.

Category: Commercial Information

Specific Information Collected: Records of services, memberships, classes, programs, merchandise, and other products or services purchased from Sydney’s Army Bootcamp.

Source and Purpose: Collected when individuals purchase or register for our Services. This information may be used to process transactions, understand customer preferences, analyze business performance, and improve our Services.

Category: Photographic and Video Images

Specific Information Collected: Photographs and video recordings.

Source and Purpose: May be collected during Sydney’s Army Bootcamp classes, challenges, events, promotional activities, social media content, or other activities. Where required, we may obtain appropriate consent or authorization before using photographs or videos for promotional or marketing purposes.

Category: Internet or Other Electronic Network Activity Information

Specific Information Collected: Information regarding users’ interactions with our website and online services, including IP address, browser information, device information, pages visited, and other website activity.

Source and Purpose: Collected automatically when individuals use our website or online services. This information may be used to operate, secure, analyze, and improve our website and Services, as well as for marketing purposes. For example, we may use website visitor information, including IP addresses or similar online identifiers, to help measure advertising effectiveness and create audiences for marketing.

II. HOW WE USE INFORMATION

We may use personal information we collect for any of the following purposes, in addition to the main purposes listed above:

• Provide you with our Services, including supporting your participation in Sydney’s Army Bootcamp programs.

• Contact you in connection with the Services, including via automated email and SMS communications where you have provided express consent.

• Complete transactions.

• Provide customer and account services, such as notices regarding products or services or your account.

• Comply with applicable laws, law enforcement requests, or pursue our legal rights, including performing and enforcing our contractual obligations and rights, such as billing and collection.

• Evaluate and improve our products and services, and develop new products and services.

• Tailor our marketing and advertising to you, including via retargeting and creating look-alike audiences.

• Send certain marketing communications, including SMS messages, using automated technology in accordance with applicable law.

The legal bases we rely upon to process your information in connection with the use cases described above are:

• We process personal information about you when it is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract;

• We process personal information about you when processing is necessary for compliance with a legal obligation which applies to us;

• We process personal information about you when processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms.

III. SMS COMMUNICATIONS AND CONSENT

If you provide your mobile phone number and opt in to receive text messages through our website, registration process, promotional forms, keyword opt-ins, QR codes, or other communication channels, you expressly consent to receive recurring automated marketing and informational text messages from Sydney’s Army Bootcamp.

These messages may include appointment reminders, session updates, promotions, fitness tips, and other service-related communications.

Message frequency varies based on user interaction and participation.

Msg & data rates may apply.

You may opt out of receiving text messages at any time by replying STOP to any message. After you send STOP, you may receive one final confirmation message. For assistance, reply HELP or contact info@sydneysarmybootcamp.com.

Consent to receive text messages is not a condition of purchase.

We retain records of mobile messaging consent and messaging compliance documentation as required by applicable law.

IV. INFORMATION WE SHARE

We may also disclose personal information, as described in this Privacy Policy, to the following:

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Mobile information may be shared with service providers solely for operational purposes such as message delivery, system functionality, customer support, compliance obligations, or other business operations necessary to provide our Services.

We do not use mobile information for third-party lead generation or resale.

Contractors, service providers, and other third parties we use to support our business and provide you with our products and services and who are bound by contractual obligations to keep personal information confidential and secure, and to use it only for the purposes for which we disclose it to them.

Sydney’s Army Bootcamp trainers, coaches, employees, contractors, and other personnel as necessary to provide training and related services to members.

Buyers or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the

V. COOKIES AND LINKED SITES

The technologies we use for automatic data collection on our website include cookies and web beacons. A cookie is a small text file placed on your device. A web beacon is a small electronic file (e.g., clear GIFs, pixel tags, and single-pixel GIFs) with a unique identifier that is used to understand browsing activity. We use data collected through these technologies, which we may supplement with other information such as location, to help us improve our website and to deliver a better and more personalized service.

Our Use of Cookies

Our website places small files, or “cookies,” on your device. Cookies are a common method used to track, personalize, and save information about each visitor’s session.

We use cookies to personalize your experience on our website, understand how visitors use our website, improve our Services, and promote our Services to you.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our website may then be inaccessible or may not function properly.

Third-Party Cookies

Some content or applications on our website, including advertisements, may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers.

These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

They may use this information to provide you with interest-based advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Linked Sites

Our website may include links to other websites or content that belong to third parties. We are not responsible for personal information that you voluntarily disclose to such third parties, and we are not responsible for third-party websites, content, or services.

You should review the privacy policies associated with those third parties before providing them with your personal information.

Web Beacons and Advertising Technologies

In order to provide you with certain services and support advertising attribution, limited user data, such as your IP address or other unique identifiers and other event data, may be shared with certain service providers when you use our website.

For example, we may use technologies provided by services such as Google Tag Manager, Google Analytics, Meta Pixel, or similar analytics and advertising technologies.

Such information may be shared to assist Sydney’s Army Bootcamp in understanding and optimizing our users’ overall customer experience. Specifically, sharing such information may help us understand how users arrive at and use our website and better measure the performance of our advertising and marketing campaigns.

Examples of technologies that may support this behavior include pixels, JavaScript snippets, cookies, and similar tracking technologies.

Where required by applicable law, you may be able to opt out of certain tracking technologies by selecting “disagree” or otherwise adjusting your preferences through the cookie consent banner displayed when visiting our website.

VI. CHILDREN UNDER THE AGE OF 16

Our Services are not directed to or intended for use by children under the age of 16.

We do not knowingly market our products or services to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16.

In accordance with applicable privacy laws and regulations, if we learn that we have received personal information directly from a child under the age of 16, or such other age as may apply in certain jurisdictions, without the consent of the child’s parent or legal guardian, we will use that information only to respond directly to the child or the child’s parent or legal guardian to inform them that the child cannot use our Services.

We will subsequently delete such information, subject to any legal obligations requiring us to retain it.

If you believe that we might have any information from or about a child under the applicable age, please contact us at info@sydneysarmybootcamp.com.

VII. YOUR PRIVACY RIGHTS

Rights of Individuals Located in the United States

Residents of certain U.S. states, including California, Virginia, Colorado, Connecticut, Utah, and other jurisdictions with applicable privacy laws, may have or will have certain rights regarding their personal information.

Depending on applicable law, these rights may include the right to:

1. Know what personal information we collect, use, disclose, or sell;

2. Request that we delete your personal information;

3. Access and obtain a copy of personal information that we collect;

4. Request correction of inaccurate personal information;

5. Opt out of targeted advertising;

6. Opt out of certain sales or sharing of personal information where applicable;

7. Limit the use and disclosure of certain sensitive personal information; and

8. Exercise other rights provided under applicable state privacy laws.

We will honor your request to the extent required by applicable law and will make a good-faith effort to honor your request in other circumstances where appropriate.

If you disagree with our response to your request, you may appeal our decision by submitting supporting documentation or additional information to info@sydneysarmybootcamp.com.

Deletion Requests

With respect to deletion requests, we may be unable to delete certain personal information where we are legally required or permitted to retain it.

Where appropriate, we may also need to delete or deactivate your user account in order to fulfill a deletion request.

We may not accommodate a request to change or delete information if we believe doing so would violate a law or legal requirement, interfere with our ability to provide requested Services, or cause the information to be incorrect.

Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

This means that, where required by applicable law, we will not deny you Services, charge you different prices or rates, provide you with a different level or quality of Services, or otherwise penalize you because you exercised a privacy right.

However, we may charge different prices or rates, or provide a different level or quality of Services, where that difference is reasonably related to the value provided to us by your personal information and is permitted by applicable law.

How to Exercise Your Privacy Rights

You may request to exercise applicable privacy rights by contacting us at:

info@sydneysarmybootcamp.com

If Sydney’s Army Bootcamp provides a dedicated privacy request or webform on its website, you may also submit your request through that form.

Right to Be Informed

This Privacy Policy explains how we use your personal information and provides information about how you may exercise applicable privacy rights in accordance with applicable privacy laws.

Right of Access

You may be entitled to ask us for a copy of the personal information that we hold about you.

This right may be known as a “Right of Access” or “Subject Access Request,” depending on the applicable jurisdiction.

We will generally respond to valid requests within the time period required by applicable law. Where permitted by law, that period may be extended where necessary, taking into account the complexity of the request or the difficulty of accessing the information requested.

There is generally no charge for exercising these rights. However, where permitted by applicable law, we may charge a reasonable fee for repetitive, excessive, or manifestly unfounded requests. We will inform you if such circumstances apply.

Right to Rectification

If the personal information we hold about you is inaccurate or incomplete, you may request that we correct or update it.

We will review the information and, where appropriate and required by applicable law, correct inaccuracies.

Right to Erasure

In certain circumstances, you may be entitled to ask us to erase your personal information.

We may retain certain information where required or permitted by law, including information necessary to comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, or protect our legal rights.

Right to Data Portability

In certain circumstances, you may have the right to request that certain electronic personal information we hold about you be provided in a portable format so that you may move, copy, or transfer it to another organization.

This right applies only where required by applicable law.

Right to Object

You may have the right to object to your personal information being used for direct marketing.

You may also object to the continued use of your personal information in circumstances where we rely upon consent as the legal basis for processing it.

Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you may need to provide specific reasons for your objection depending on applicable law.

We will consider the reasons you provide. Where permitted by law, if we determine that we have compelling legitimate grounds to continue processing your personal information, we may continue to do so. If required, we will inform you of the reasons for our decision.

Rights Related to Automated Decision-Making and Profiling

We do not use your personal information in connection with automated decision-making that produces legal or similarly significant effects on you.

We may use limited contact information and other information to carry out certain business development, marketing, analytics, or audience-profiling activities to support and grow our business.

Where applicable, we rely upon our legitimate interests or other lawful bases permitted by applicable law for these activities.

You may exercise the privacy rights described above if you do not wish for us to process your personal information for such purposes, to the extent required by applicable law.

Identity Verification

Please note that we may take reasonable steps to verify your identity before granting you access to personal information or acting on your request to exercise your privacy rights, as required or permitted by law.

We may request information necessary to verify that the person making the request is the individual to whom the personal information relates or their authorized representative.

We may limit our response to your exercise of the above rights to the extent permitted by applicable law.

VIII. INTERNATIONAL VISITORS

For visitors using our Services from outside of the United States, any personal information you provide may be transferred to and processed in the United States for use by us and our service providers for the purposes described in this Privacy Policy.

By using our website and Services, you acknowledge that your personal information may be transferred to, stored in, and processed in the United States and other locations where our service providers or business operations are located.

Privacy and data protection laws in the United States or other countries may differ from those in your country of residence.

Where required by applicable law, we will take appropriate steps to provide protections for personal information that is transferred across borders.

If you have questions about international transfers of your personal information, please contact us at info@sydneysarmybootcamp.com.

IX. SALES OF PERSONAL INFORMATION

Sydney’s Army Bootcamp does not sell your personal information for monetary consideration.

We may use personal information for our own business purposes, including providing and improving our Services, marketing, advertising, analytics, and other purposes described in this Privacy Policy.

Where applicable privacy laws define certain forms of sharing, disclosure, targeted advertising, or other processing as a “sale” or “sharing” of personal information, you may have the right to opt out of those activities.

We will honor applicable opt-out requests in accordance with the privacy laws that apply to you.

Mobile phone information and SMS consent information will not be sold or shared with third parties or affiliates for their own marketing or promotional purposes.

X. DATA RETENTION AND SECURITY

Sydney’s Army Bootcamp retains personal information for as long as you use our Services and for as long as reasonably necessary to fulfill the purpose or purposes for which it was collected, provide our Services, maintain business and financial records, resolve disputes, enforce our agreements, comply with legal or regulatory obligations, and for other legitimate business purposes.

We retain records of SMS opt-in consent and messaging compliance documentation for as long as required by applicable law.

We have implemented reasonable technical and organizational security measures designed to help protect personal information against loss, misuse, unauthorized access, disclosure, alteration, or destruction.

These measures may include encryption of information transmitted between our systems and your browser, access controls, authentication procedures, and other administrative, technical, and physical safeguards appropriate to the nature of the information.

However, the storage and communication of information online can never be completely secure. No method of transmission over the Internet or method of electronic storage is completely secure.

You should take reasonable steps to protect against unauthorized access to your account, personal computer, mobile phone, email account, passwords, and other devices or credentials that you use to access our Services.

Sydney’s Army Bootcamp is not responsible for lost, stolen, or compromised passwords or for activity on your account resulting from unauthorized access caused by circumstances outside of our reasonable control.

If you become aware of any actual or suspected breach of security involving your personal information, or if you believe there has been a violation of this Privacy Policy, please notify us as soon as possible at:

info@sydneysarmybootcamp.com

If we determine that a security breach has occurred, we will provide notice to affected individuals and/or applicable regulatory authorities to the extent required by applicable law.