SPORT2E Spółka z ograniczoną odpowiedzialnością is a company registered in Poland (registration number 0001148943), with its registered office at Emilii Plater 49, 00-125 Warsaw, Poland (hereinafter referred to as "SPORT2E", "we", or "us"). The company was established under Polish law based on the Articles of Association dated January 7, 2025, and may process personal data in accordance with the provisions of the General Data Protection Regulation (GDPR) and the Polish Personal Data Protection Act (Ustawa o ochronie danych osobowych).
This Privacy Policy applies to your use of the Sportera mobile application ("Application"), which includes a Marketplace, the company's websites (including https://sportera.app/), and all services provided through these platforms ("Services"). It sets out how we collect, store, and process personal data.
Minimum Age
You must be at least 18 years old to use the Services. If you are under 18, please do not provide us with any personal information.
Personal Data We Collect
To ensure Sportera functions properly and can reward you for your activity, we collect certain information.
Device and Interaction Data
When you access the Sportera app or website, we automatically receive technical information such as:
- The type of your device (smartphone, tablet, etc.);
- Operating system and browser;
- IP address and unique device identifier;
- Time zone;
- Cookie data;
- Pages you view, links you click, and your interactions with the platform.
We Use
- Cookies – text files stored on your device;
- Log files – to record IP address, browser type, date/time, and activity;
- Web beacons, pixels, and tags – to understand how you use the service.
Data You Provide Voluntarily
When you register or use our services, we may receive:
- Your name and contact details (email, address, etc.);
- Payment information (if you purchase products or subscriptions);
- Authentication data from Apple or Google login.
Health and Activity Data
To track your physical activity, accurately reward you, and improve the service, we may collect the following data with your consent:
- Geolocation (required to track steps and activity);
- Physical movements (e.g., step count, workouts);
- Age, gender, height, weight;
- Medical indicators (if you add them manually);
- Access to your camera or gallery (for progress photos);
- Data from Apple Health or Google Fit (if you enable synchronization).
We do not collect this data without your consent. If you disable location services or health data access, Sportera will not be able to track your activity or reward you.
Data Storage and Management
- Some data is stored locally on the user's device.
- Other data is stored on the company's secure servers.
- Users can manage access to their personal data through the app settings or their device's operating system settings.
Who We May Share Your Data With
- Other users: your photo, bio, and step count may be publicly visible.
- Service providers: including CRM, analytics, hosting, and payment processing.
- Partners: may send you offers, but only with your consent.
- Government authorities: when required by law.
- Mergers and acquisitions: as part of business transactions.
International Data Transfers
Your data may be transferred outside the country in which you reside. If data is transferred from the UK/EEA to countries with a lower level of data protection, we ensure the use of Standard Contractual Clauses and other appropriate safeguards.
To learn more, contact us at [email protected] with the subject line "international transfers."
Data Retention
Your personal data will be retained only for as long as necessary to fulfill the purposes outlined in this policy, or for the period required by applicable laws or regulatory obligations.
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes of processing, whether those purposes can be achieved by other means, and applicable legal, tax, accounting, or other requirements.
Data Security
We take reasonable measures in line with industry standards to ensure the security of all our data and to prevent unauthorized access or unlawful use.
COOKIES
We use cookies and similar technologies in the Sportera app for various purposes, including analytics and advertising. For more details about our use of cookies, please refer to ANNEX 2.
Links
The Services may contain features or links to third-party websites and services. Any information you provide on such sites or services is transmitted directly to their operators and is subject to their privacy and security policies—even if you accessed them via the Sportera app.
We are not responsible for the content, privacy practices, or security of any third-party resources. We recommend reviewing the privacy policies of such third parties before providing them with your personal data.
Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. All changes will be published in the Sportera app and may also be sent to you via email. Please review the policy periodically for updates.
Contact
If you have any questions, comments, or requests regarding this Privacy Policy, please contact us at [email protected] with the subject line: "enquiry".
ANNEX 1 – Purposes of Collecting Personal Information
The Sportera app complies with the Google API Services User Data Policy, including its restrictions on use.
Below are the categories of personal data we collect, how we use them, and the legal basis for processing:
- Contact data (phone number): identity verification during registration – legitimate interest.
- Contact data, profile, movement data: providing services and marketplace functionality – performance of a contract.
- Geolocation data (iOS): movement verification – consent and performance of a contract.
- Movement data (HealthKit / Google Fit): for awarding Sportera rewards – consent and performance of a contract.
- Contact and payment data: transaction processing – performance of a contract.
- Profile data and movement data: creating user rankings – legitimate interest.
- Phone number: inviting friends – legitimate interest.
- Contact data, inquiries: responding to requests, market research – legitimate interest.
- Transaction data: tracking benefits and generating statistics – legitimate interest and legal obligations.
- Marketing preferences: advertising, sharing with partners – consent or legitimate interest.
- Profile, usage, movement: fraud prevention and analytics – legitimate interest.
- Profile, technical data: service security – legitimate interest and compliance with legal requirements.
- Technical and behavioral data: analytics, service improvement – legitimate interest.
- Profile, contacts: support, communication – performance of a contract.
ANNEX 2 – COOKIES
What are cookies
We use cookies to distinguish you from other users of the Sportera app and to gather certain information about your behavior. A cookie is a small file of letters and numbers that we place on your device when you use the app or website. This helps us improve your user experience and enhance our Services.
We use both persistent cookies (stored for up to 10 years) and session cookies (deleted when you close your browser).
What types of cookies we use
We may use the following types of cookies:
- Strictly necessary cookies – required for the operation of the app and website (e.g., to log in to secure areas);
- Analytical/tracking cookies – allow us to count visitors, analyze usage of the Services, and verify transactions;
- Advertising and retargeting cookies – allow us to show you relevant ads on the app and other websites.
Please note: Third-party services (such as ad networks and analytics providers) may also use cookies, which we do not control.
You can block cookies via your browser settings, but some features may not function properly as a result.
We use standard analytics tools such as Google Analytics and Facebook Analytics, which collect IP address, user behavior, and other data.
Cookie consent
We request your consent to place cookies when you first visit our website, except for cookies that are necessary to provide the Services you have requested. A notification about this appears on the website's homepage.
How to disable cookies
If you do not wish to accept cookies, you can change your browser settings. Please note that this may limit the functionality of the website.
Sharing of personal data
Under the GDPR, residents of the EU and EEA have guaranteed rights over their personal data, regardless of citizenship. These rights apply to any company processing their data, even if located outside the EU.
We have shared or may share the following categories of personal data with third parties (e.g., analytics partners or advertising platforms):
- Profile or contact data
- Device/IP data
- Web analytics
- Social media data
- Demographic data
- Geolocation data
- Special categories of data (e.g., health data, if provided voluntarily with consent)
- Other
As noted in Annex 2, we use third-party service cookies. These cookies allow third parties to collect information about your activity on our service linked to your browser or device.
Such data may be used to show you relevant ads on our platform or on other sites. Under GDPR, sharing personal data with third parties for behavioral advertising purposes may constitute data processing that requires your prior consent.
You have the right to opt out of such sharing/processing by following the instructions provided in this section.
To ensure and improve the functionality of the Sportera app, we share personal data with the following categories of third parties:
- Service providers
- Other users (where certain profile information is publicly accessible)
- Business partners
- Third parties in connection with business transactions (such as mergers, acquisitions, or sales)
- Government authorities, regulators, and law enforcement agencies (for legal reasons)
Other Data Sharing Based on User Consent
We are committed to protecting your privacy and processing your data with due care. In accordance with European Union legislation, including the General Data Protection Regulation (GDPR), we only share your personal data with third parties when there is a valid legal basis and for permitted purposes.
Scope of Sharing
We only share the categories of personal data for which you have given explicit consent (e.g., name, contact details, etc.).
Purpose of Sharing
Data is shared solely for specified purposes, including:
- Sending marketing communications;
- Personalized offers;
- Analytics or service improvement.
Processing of Data by Third Parties
All third-party partners are required to:
- Process personal data only within the agreed purposes;
- Comply with GDPR requirements and the terms of signed Data Processing Agreements (DPAs).
Right to Withdraw Consent
You have the right to withdraw your consent to the processing or sharing of your personal data at any time. To do so, please contact us at: [email protected]
Upon receiving your request, we will stop processing and sharing your data unless there is another lawful basis for doing so.
Your Rights Under the GDPR
You have the right to:
- Access information about which personal data we process;
- Correct inaccuracies in your personal data;
- Request the deletion of your personal data;
- Restrict or object to processing;
- Receive a copy of your data in a structured format (data portability);
- Lodge a complaint with a data protection supervisory authority.
To exercise these rights, contact us at [email protected]