Privacy Policy

Last updated: 6 August 2021

Intro

Welcome to Mirra’s Privacy Policy! Mirra (“the company”, “us”, “we”) is a trademarkwholly owned by GOLD SILVER TREE HOLDINGS LTD, registered in the United Kingdom under the registration number 13082177.

We respect your privacy, and we are committed to protecting your personal data. In this Privacy Policy we will explain what types of information we collect, how we collect your data, the usage of data, how we store your data, and your data protection rights. This privacy policy only applies to personal information that Mirra receives and does not apply to information collected by any other third parties that are not controlled by Mirra.

What data do we collect?

The types of data we collect depends on the nature of your relationship with Mirra and the applicable law. We aim to only collect data that is relevant to providing you the best experience with Mirra product and services. Mirra may data throughout thecourse of your interaction with the product and services offered by Mirra, including your visit to our website, transactions, email communication, usage of the product, among other ways:

• Name
• E-mail address
• Phone number
• Addres
• Payment information
• Username and password
• Profile picture
• Answer to survey questions
• Health information (e.g., weight, height)
• Usage data of the website and app
• Heart rate during workouts

How do we collect your data?

You directly provide Mirra most of the data we collect. We may also receive passive data when you interact with our website, mobile app, or product and services. We collect data when you:

• Sign up for the waitlist to be informed for when our products and services become available
• Sign up for the newsletter to voluntarily receive e-mails from Mirra
• Create an account and fill in your profile
• Sign up to Mirra through a third-party application
• Place an order for any of our products or services
• Voluntarily complete customer surveys or provide feedback in forms of messages, e-mails, phone calls or other methods
• Use or view our website via your browser’s cookies
• Use our device and wristband
• Interact with Mirra’s social media account
• Publicly provide review and feedback to trainers and classes on Mirra
• Sign up for Mirra’s offline events

How do we use your data?

We collect your data so that we can optimize your experience and address your requests. These may include but does not limit to:

• To process your order and provide products and services – Mirra may use information you provided upon placing an order to fulfil the delivery of the order.
• To respond to your requests – Mirra may use the information that you provided to answer any questions you may have and allocate resources to resolve your issues.
• To give you recommendations on services – Mirra may use the information you provided, such as your location and fitness goals, to give you recommendations on the trainers in your area, and nutrition services.
• To understand product performance – Mirra may use collected data to understand the performance of our products and services and develop new products and services.
• To provide offers, products and services and information that might be of interest to you – Mirra may use the information you provided to contact you about promotions, new products and services and other updates that might interest you.

Mirra may also use your data for other legitimate reasons, such as fraud protection and fulfilling legal obligations, or any other purpose that received your consent at the time you provided your data.

With whom do we share your data?

We will only disclose your information for legitimate reasons, which may include thefollowing scenarios:

• Vendors and Service Providers – Mirra uses third-party service providers to provide essential functionalities in your Mirra journey. We may share your information with these third parties, enabling them to perform services include payment processing, analytics services, IT services, logistics services, customer support, etc.
• Business Partners – Mirra may share data with business partners we work with to provide the products and services you request.
• Marketing – Mirra may allow third-party advertising companies to deploy tracking tools (e.g., cookies) to collect information related to your activities on our website. We may share de-identified information with these third parties for them to deliver targeted advertisement to you when you visit websites other than Mirra. If you wish that we do not share your information with third parties for targeted advertising purpose, you canopt out at no cost. See instructions in section “How do I manage cookies?”.
• Legal reasons – We may share your information to comply with law enforcement requests or other legal processes, such as a court order or subpoena, or to protect yours, ours, or others’ legal rights, or to enforce Mirra’s policy.
• Merger, sale, or acquisition – In the event of a merger, sale of company assets, reorganization, bankruptcy, or acquisition by another legal entity, your information may be transferred as part of such transaction.

What are cookies?

Cookies are small files that are stored on your device to collect standard internet log information and visitor data. When you visit our website, we may collect information from you automatically through cookies or similar technology.

Why do we use cookies?

We use cookies both to allow our website to function normally and to track relevant information and offer personalized experiences to you. There are four different types of cookies:

• Strictly necessary: these are account log in related cookies and are essential to the basic usage of the website
• Functionality: we use these cookies to recognize you on our website and remember your previously selected preferences
• Tracking and Performance: we use these cookies to collect statistical information about the activities on our website. This information is used to analyse the performance of our website
• Targeting and Advertising: these are cookies that are set through our website by our advertising partners, so the content you see is more relevant to you

How do I manage cookies?

When you first visit our website, you will be prompted to accept cookies. You have the option to opt out of all cookies except for strictly necessary cookies. As a result of opting out of functionality, tracking and performance, targeting and advertising cookies, you may not be able to use certain functions on the website, or your experience is not as personalized.

Additionally, the online advertising industry also provides ways for you to opt-out of receiving targeted advertisements. You may use the following websites to manage your preference for targeted ads from participating advertising partners: www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu/ or www.youradchoices.ca/, and www.aboutads.info/choices/. You may also opt-out of Google Analytics by installing this add-on.

How do we store your data (International Data Transfers)?

We take commercially reasonable technical and organizational measures to ensure the safeguard of your data in accordance with UK GDPR. The measures include, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data on a “need to know” basis, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data.

You agree that all personal data collected by mirra may be stored or transferred anywhere in the world, including but not limited to, the United Kingdom, the European Union, China and Canada, in the cloud, or on our servers.

What is your data retention policy?

Mirra will retain the data that we collected from you for as long as you use our product or service, or as necessary to fulfil the purpose(s) of providing products and services, address requests, resolve disputes, establish legal defences, pursue legitimate business needs, enforce our policies and comply with relevant laws. When we are no longer required to retain your data, we will safely destroy, erase or delete it according to applicable law.

What is my data protection rights?

Your rights under relevant laws in relation to your data is outline below:

• The right to rectification: you have the right to request that Mirra corrects anyinformation you believe is inaccurate. You also have the right to request Mirrato complete information you believe is incomplete.
• The right to restrict processing: you have the right to request that mirra restricts the processing of your personal data, under certain conditions.
• The right to object to processing: you have the right to object to Mirra’s processing of your personal data, under certain conditions.
• The right to data portability: you have the right to request that Mirra transfersthe data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise these rights, please contact us at our email: hello@mirra.fit. We try to respond to all legitimate requests within one month.

Changes to our privacy policy

We may change our privacy policy from time to time. You understand and agree that you will be deemed to have accepted the updated privacy policy if you continue to use Mirra’s products or services after we have published updated privacy policies.

How to contact us

If you have any questions or concerns regarding this privacy policy, please contact us at hello@mirra.fit.

How to contact the appropriate authorities

If you are not satisfied with how your personal data is handled, you can contact the Information Commissioner’s Office. They can be reached at: 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/ to submit your complaint.