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Tempo Privacy Policy

Effective Date: Feb 26, 2020

Tempo Interactive Inc. d/b/a Tempo (“Tempo,” “we,” “our,” or “us”) is a provider of fitness technology hardware and services that blend computer vision, machine learning, and human expertise to deliver a superior training experience. Your privacy is important to us and we are committed to protecting it. Your choice to share information with us is a critical part of our services which aim to improve your overall fitness.

This privacy policy (“Privacy Policy”) explains how and why we collect, use, and share the information we collect through our websites and mobile applications, including (our “Sites”), through your use of our live and pre-recorded fitness classes and training programs (“Tempo Classes”), and through other services available through your Tempo device and subscription, as well as from your interactions directly with us (collectively, our “Services”). The terms “you,” “your” or “user” means the users of the Site and Services.

This Privacy Policy does not cover or apply to our processing of information about employees, contractors, trainers, or other business partners.


Information We Collect And Use

We generally collect two types of information from and about you in connection with the Services:

We collect your information from a variety of sources, including:

A. Information You Provide to Us

    B. Information from Third Party Sources

      We may receive Personal Information about you from our business partners and service providers and combine this Information with other Information we collect from or about you (“Third Parties”). The Third Parties may include the Apple App Store or Google Play App Store, social media sites such as Facebook where you have interacted with us or made your profile public via your privacy settings, website operators, payment processors, marketing partners, shipping providers, job application platforms, references, background check providers and recruiters. The Information may include contact information, demographic information, interests, information about your orders, social media profiles, educational and professional history, background checks and performance reviews. We use this Information to administer and facilitate our Services, your orders, our marketing activities, to provide you with information about our business and Services, and for the discovery and evaluation of job candidates.

      Even if you delete your account on a Third Party, we will retain any Information provided by that Third Party. Similarly, if you delete or deactivate your User Account on the Services, any Information that we have shared with Third Parties (in accordance with this Privacy Policy) may be retained by those Third Parties subject to their privacy policies. We strive to work only with third parties that adhere to data privacy practices at least as protective of users as this Privacy Policy.

      C. Information We Collect Automatically

        We use various technologies to collect information about the device or browser you use to navigate our Sites, or from your use of our Services, including:

          D. Other Uses of Personal Information

            In addition to the uses described above, we may collect and use Personal Information for the following general purposes:

                  How We Share And Disclose Personal Information

                  We do not sell your Personal Information to Third Parties. We may share your Personal Information in the following ways:

                  Other than as set out above, you will receive notice when Personal Information about you might be shared with third parties, and you will have an opportunity to choose not to share the Personal Information. We may use any and all Non-Personal Information collected from or about you for any reasonable purpose that is necessary to provide the Services.

                  Online Privacy Choices and User Rights

                  We support the self-regulatory principles of the Digital Advertising Alliance (“DAA”). We work with advertisers, advertising networks, advertising servers, and analytics companies (“Ad Partners”) that use data collection technologies to understand how our Services are being used and to analyze your location and browsing history in order to deliver advertising relevant to your interests, as well as to provide advertising-related insights such as reporting, attribution, analytics, and market research. These advertisements may appear on our Services or other websites or services, including through social media networks. These Ad Partners may be able to associate devices across third party websites or services over time and link various devices used by the same individual. Tempo does not control these Ad Partners, and/or their use of tracking technologies, which is instead governed by the privacy policies of the Ad Partners.

                  For more information about how Ad Partners use the information collected by these technologies and your options for restricting cookies placed by some of these Ad Partners, please visit the DAA’s opt-out page. The DAA’s opt-outs are device-and browser-specific and may not work on all devices. If you choose to opt-out through the DAA’s tools it does not mean you will cease to see advertising. Rather, the ads you see will be based on the website you are visiting and not your interests.

                  You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting app choices and downloading the mobile AppChoices app.

                  You have some choices regarding how we use your Personal Information, including the following:

                  Additionally, if you have registered for a User Account, you may have the ability to access and use certain features and functionality that provide you with the ability to set certain privacy, permissions, and account options. Please be aware that that if you limit the collection of certain Information, you may not be able to use all of the features and functionality of the Services.

                  Retention of Your Information

                  We retain your Information for as long as it is needed to provide you with Services, or for other purposes described in this Privacy Policy, and for as long as legally required. We do not retain your Information for longer than is necessary for these purposes. The retention period for any particular Information will vary depending on the nature of that Information and the purposes for which it is collected and processed, your exercise of your privacy choices above, and applicable laws.

                  You Information may be transferred, processed and stored anywhere in the world, including but not limited to, in the cloud, on our servers, on the servers of our affiliates or on the servers of our service providers.

                  Children's Privacy

                  These Services are not designed to be used by minors. As such, we do not knowingly collect or solicit any Information from anyone under the age of 13 and the Services are not targeted towards anyone under the age of 13. In the event that we learn that we have inadvertently collected Personal Information from someone under age 13, we will delete that information as quickly as possible. If you believe that we might have received Information from a child under 13, please contact us at

                  Links To Other Websites And Services

                  The Services may contain links to third party websites or services, including those of our business partners and social media sites. Our Services may also include buttons and widgets hosted by other companies (for example, the Facebook, Instagram, Twitter, LinkedIn and YouTube “Share” buttons). Some of these features collect Personal Information or other Information such as your IP address and information about the websites you have visited.

                  This Privacy Policy does not apply to the practices of these or any other third parties. Tempo is not responsible for the privacy practices of any entity that it does not own or control. We encourage you to review the privacy policies and terms of those third parties to learn more about their privacy practices.


                  While no data transmission over the internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Information. Unfortunately, the transmission of Information via the internet is not completely secure. Although we do our best to protect your Information, we cannot guarantee the security of your Information transmitted to or through the Services. Any transmission of Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

                  It is important for you to protect against unauthorized access to your password and to your computers and devices. Be sure to sign off when finished using a shared computer.

                  How To Contact Us

                  If you have any questions about this Privacy Policy or the Services, please contact us by email at

                  Changes To Our Privacy Policy

                  This Privacy Policy is subject to occasional revisions. We will notify you of the changes by posting the new privacy policy on the Sites and updating the effective date. We encourage you to check this page periodically to stay informed about how we are processing Personal Information. Your continued use of the Site or Services following any such change constitutes acceptance of the updated Privacy Policy.

                  California Users’ Privacy Policy Rights Notice

                  In addition to your rights provided for above in this Privacy Policy, if you are a California resident, you have additional rights in relation to your Personal Information, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). This California Privacy Rights Notice (“California Notice”) sets out those additional rights. Any terms defined in the CCPA have the same meaning when used in this California Notice.

                  Your Rights to Know, Access, Correct, and Delete Personal Information

                  To the extent provided by law, up to twice per year, you may request that we disclose to you free of charge:

                  You may request that we correct any inaccurate Personal Information that we collected from you. To the extent provided by law, you may also request that we delete your Personal Information.

                  If you would like to access, manage, change, correct, limit, or delete your Personal Information, you can do so via your User Account settings. Alternatively, to exercise the rights described above, please email your request to

                  We will confirm receipt of your request with 10 business days. We will respond to your request within 45 calendar days of receiving your request, and notify you if we need an additional 45 days to respond.

                  Verifying Requests

                  When you ask us to disclose specific pieces of Personal Information to you or to delete Personal Information we obtained from you, we have to verify your identity before processing your request. If we are unable to verify your identity we may deny your request at our discretion. As a part of this process, we will match the identifying information provided by you to the Persona Information we have about you. We may ask for additional Personal Information such as government or other identification, along with your name, address history, and information about your previous interactions with us. More stringent verification is required if you do not have or cannot access your User Account with us.

                  An Authorized Agent Can Make Requests on Your Behalf

                  You may designate an authorized agent to make a request to access or a request to delete on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide the agent with a valid power of attorney. We will also request your valid government issued identification and the authorized agent’s valid government issued identification. We may verify the authenticity of the request directly with you, and may deny requests from authorized agents who do not submit sufficient proof that they have been authorized by you to act on your behalf, or are unable to verify their identity.

                  Categories of Personal Information We Collect

                  Pursuant to the CCPA, this section describes: 1) disclosure of the categories of your Personal Information we collected in the 12 months prior to the “Last Updated” date of this Privacy Policy; 2) identification of the categories of sources from which your Personal Information is collected; and 3) the categories of Personal information that we disclose to third parties, and the categories of third parties to whom the information is disclosed. Additional information about these categories can be found in the previous Privacy Policy sections above. The categories are as follows:

                  We may also disclose Personal Information: 1) to governmental regulatory authorities as required by law; 2) to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or any other person, to protect against fraud or credit risk, or to enforce our legal rights or contractual commitments that you have made; 3) as part of an organizational business transaction, such as a merger, acquisition, joint venture, financing, or sale of organizational assets; and 4) in the event of insolvency, bankruptcy, or receivership.

                  The Purposes for Our Collection of Your Personal Information

                  The CCPA requires disclosure of the business or commercial purpose for our collecting and disclosing of your Personal Information. We collect, use, and disclose the categories of Personal Information for our business and commercial purposes described in the “Information You Provide to Us,” “Information from Third Party Sources” and “Other Uses of Personal Information” sections above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase transactions, processing payments, and for providing advertising and marketing services.

                  Your Rights Regarding the Sale of Your Personal Information

                  We will not sell Personal Information about you, as defined under the CCPA. You do not need to “opt-out” or tell us to refrain from selling your Information.

                  Your Right to Nondiscrimination

                  Limiting use of, or deleting, your Personal Information, or restricting certain Personal Information we may share with third parties, may impact features and uses that rely on the use of sharing of that information. However, we will not discriminate against you for exercising any of your rights under the CCPA, including otherwise denying you goods or services, providing you with a different level or quality of Services, or charging you different prices or rates for Services.


                  If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us by email at

                  Contact Us

                  If you have questions about these practices, you can contact by email at

                  In addition to the rights above, pursuant to California Civil Code sections 1798.83-1798.84, once per year and at no charge, California residents who share Personal Information with us have the right to request and obtain: 1) a list of third parties to whom we have disclosed their Personal Information for direct marketing purposes in the prior calendar year; and 2) the type of Personal Information disclosed to those third parties. If you would like to exercise this right, please use the contact information listed in this section to contact us.