California Privacy Notice

If you are a resident of California, this notice applies to you and supplements the Paceline Privacy Policy.  This notice is intended to provide certain information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”). 

When we use the term “personal information” in this notice, we are referring to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.  Personal information does not include publicly-available information and certain other information that is regulated by certain other applicable laws that are exempted from the requirements of the CCPA. Information We Collect In the preceding 12 months, we have collected the categories of personal information listed below. For more details about the specific data points we collect, please see the “Information We Collect” section in our Privacy Policy.

Category	Examples
Identifiers	Name, email address, phone number, and IP address
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, phone number, physical characteristics or description, and financial information.  Some Personal Information included in this category may overlap with other categories
Characteristics of protected classifications under California law	Gender and age.
Commercial information	Purchasing habits, information about your financial accounts, rewards and use of rewards, transaction history, account status, and credit limit(s)
Biometric information	Wellness, exercise and activity data and preferences you share with us. energy output, activity levels and time periods, meditation time, cycling distance, exercise minutes, heart rate, step counts, swimming distance, swimming strokes, walking and running distances, workout period, height, sex, and weight
Internet or other similar network activity	Browsing history, session logs, personal preferences including marketing and cookie preferences, unique identifiers, and information about your interaction with our Services and communications with us
Geolocation data	GPS location and cellular network information of your device
Inferences drawn from the above information	We may create consumer profiles to reflect your preferences and behaviors, such as your fitness activities and shopping habits

Categories of Sources We collect personal information from the sources noted below.  Please see our Privacy Policy for more details.

• Directly from you when you provide it to us, when you use our Services, and when you interact with us through social media
• Third party service providers that provide data and information to us
• Wearable devices that you link to your account in the Services
• Your financial accounts that you link to your account in the Services through Plaid (this includes information that Plaid provides to us)
• If you are a Paceline cardholder, we may receive information about you from our credit card processing and issuing partner or other rewards partnersin connection with the administration of the credit card and credit card rewards program

Our Business Purposes for Collecting Personal Information Our purposes for collecting your personal information are detailed in our Privacy Policy, including the “How We Use Your Information” section.  In general, we collect personal information from you so that we can provide our Services, operate our business, and provide information that you request from us.  We also collect your personal information to:

• Communicate with you about your use of our Services, to respond to your inquiries, to provide you with rewards, and for other customer service purposes
• Tailor the content and information that we may send or display to you, to offer personalized fitness goals and activities and rewards for completing those goals/activities, to provide personalized help and instructions, and to otherwise personalize your experiences while using the Services
• Conduct research and analysis
• Engage in marketing and promotional activities
• Enhance or improve user experience, our business, and our Services, including the safety and security thereof
• Detect, prevent, or otherwise address fraud, security or technical issues
• Fulfill or assist with our legal obligations

 Third Parties We Share Personal Information With We may share your personal information with third parties, including our service providers, our affiliates, data analytics providers, social networks, other users of our Services (if you have added such users as your “friends” in the Services), in the context of a business transfer, as part of a legal process, to the extent appropriate to protect Paceline or other third parties, and with your consent. For more details, please see the “How We Share Your Information” section of our Privacy Policy. 

Your Rights

Right to Know You have the right to request that we disclose certain information to you about our collection of your personal information.  Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of personal information we have collected about you
• The categories of sources from which we have collected your personal information
• Our business or commercial purpose(s) for collecting or selling your personal information
• The categories of third parties with whom we have shared your personal information; and
• The specific pieces of personal information we have collected about you

We do not sell your personal information, but are required to tell you that you have the right to request that we disclose certain information to you about our disclosures and sales of your personal information.  Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of personal information we have collected from you
• The categories of personal information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of personal information for each category of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose

Right to Delete You have the right at any time to request that we delete your personal information.  However, in some cases we cannot delete all or some of your personal information as required or permitted by applicable laws. Right to Non-Discrimination We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you. How to Contact us to Exercise your Rights To submit a request to exercise your “Right to Know” or “Right to Delete” rights provided in this notice, please click here, contact us by email at opt-out-ca@hold.paceline.fit.  We will evaluate the request and take action where required to do so.    Please include “California Rights Request” in the subject line of your request. We will confirm receipt of your request within 10 business days and will provide information about how we will process your request. We always aim to respond to your request as soon as we can, within the timeframes permitted under the CCPA.  If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days). Verification of Requests and Authorized Agents We may have to verify your identity when you contact us to exercise your “Right to Know” or your “Right to Delete.”  Our verification process may vary depending on the nature of your request.  However, generally, we will verify your request by asking you to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. You may also use an authorized agent to exercise your rights on your behalf.  If you wish to use an authorized agent to make a request on your behalf, unless you have provided the authorized agent with power of attorney, we may require that: (1) you provide your authorized agent signed permission to do so; (2) you verify your identity; and (3) you confirm that you have provided the authorized agent permission to submit the request.   We may deny any request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.  Your authorized agent may make a request on your behalf by contacting us by email at opt-out-ca@hold.paceline.fit.   Date of Last Update: October 8, 2021   116329668v.1