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Privacy & Policy

# Privacy Policy

*This Privacy Policy was last updated on 18 October 2018*

Fitco Ltd is a company incorporated in Georgia (registration number 406242757),
whose registered office is Monk Gabriel Salosi Ave, 6th turn, corp 9, flat 36
(hereafter referred to as “Fitco”, “we” or “us” as the context may require).
The Privacy Policy applies to your use of the SiApp mobile application (the “SiApp”),
any website operated by Fitco (including (the “Fitco Website(s)”)
and the services we provide that are accessible via any of them (the “Services”).
This Privacy Policy sets out the basis on which any personal data we collect from you,
or that you provide to us, will be stored and processed by us.
Please note that you must be aged 13 years or older to use the Services.
Please do not use the Services or provide us with any personal information if you are under 13 years of age.


From time to time, we may collect or ask you to provide personal information
including (without limitation) the following: your name, mobile phone number,
email address, password, IP address, unique device identifiers and other
identification credentials, biographical details, photographs and/or
payment information.

As part of the Services, we may provide functionality allowing you to search for
friends by using your Facebook credentials and, when you elect to do this, you
will be asked to allow the SiApp to access certain information associated with
your Facebook account such as your name, profile picture, gender and list of
friends. Provided you consent to this, such information will be processed by us
in order to identify your Facebook friends who are users of SiApp and to allow
you to invite those Facebook friends to install the SiApp application.

Please note that, with your consent, we will collect information about your
physical movements in order for the SiApp to function properly and monitor
and verify forms of eligible movement. You may turn Internet Connection
on and off from time to time using the settings of your operating system of
your mobile device but, if you disable this functionality, we will not be able
to give you access to services and products provided in application market.

We work with third parties from time to time (including, for example,
business partners, sub-contractors in technical, payment and delivery services,
advertising networks, analytics providers, search information providers and
credit reference agencies) who may provide to us information about you.
This may include your purchase history from business partners who supply you
with rewards made available via the SiApp application.


We may use your personal data to:

– provide the Services (using our own systems and those of appropriate third party service providers);
– verify your physical movement and location and issue SiCoins on the basis of this verified data;
– analyze the usage of, and improve, the Services;
– communicate with you, including without limitation to inform you of updates
to the SiApp application, Fitco Website(s), our Terms of Use and/or this Privacy Policy;
– perform market and customer research;
– market our services to you;
– correct errors and problems with the Services;
– investigate and/or prevent suspected fraud or other criminal activities;
– create daily leaderboards of users, comprising all users or users meeting
particular criteria as ranked by the number of steps completed or using other criteria;
– operate the SiApp Marketplace; and/or
– investigate disputes between users.

Additionally, we and/or our trusted partners may contact you from time to time
with offers that may interest you and/or to inform you of other products and
services. Certain of your personal data may be shared with other users of the
SiApp application as part of the normal operation of the Services (for example
your uploaded profile picture and biographical information will be accessible
to all users, and we may publish your total verified steps, or other movement,
during a particular period to other users from time to time).
Further, we may, from time to time, expand or reduce our business which may
involve the transfer of certain divisions or assets of our company to other
parties, and the data we store and use, where relevant, may be transferred
to such third parties. From time to time we may transfer the data we store
and use to locations outside the Georgia’s Economic Area, some of which may
have different data protection laws to the GEO, or no data protection laws.
In all such cases, we transmit such information only to entities that comply
with this policy and applicable law.

Your personal data will be kept only for as long as is necessary.
We take reasonable industry-standard care in keeping all our data secure and
in preventing any unauthorized access or unlawful use of it.
All personal data we store and process is handled strictly in accordance with
applicable data protection legislation.


We use cookies to distinguish you from other users of the SiApp application and
Fitco Website(s) and obtain certain information about your usage and behavior.
A cookie is a small file of letters and numbers that we put on your computer
when you use the SiApp application or Fitco Website(s).
This helps us to provide you with a better experience when you use the SiApp
application or browse the Fitco Website(s) and also allows us to improve the Services.
We will use both persistent cookies, which could remain on your device until
their expiration (which, in some cases, is up to 10 years,
and session cookies, which are temporary files removed from your device once
your browser is closed.

The types of cookies we may use include:

– Analytical/Tracking Cookies, which allow us to recognise and count the number
of visitors and analyse use of the Services, as well as to verify transactions; and
– Advertising and Retargeting Cookies, which allow us to generate appropriate
advertising directed to you on the Fitco Website(s) as well as on the
SiApp application and other third party websites.

Please note that third parties (including, for example, advertising networks and
providers of external services like web traffic analysis services) may also
use cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.
You may block cookies by activating the appropriate setting on your browser but,
if you do so, you may not be able to use all functionalities of the Services.

We use a number of industry-standard data analytics tools, such as
Google Analytics and Facebook Analytics.
These collect certain information about you,
such as your device’s IP address and browsing and usage behaviour,
and are used to allow us to track and monitor the traffic visiting the SiApp application and Fitco Website(s).


You have the right to ask us not to process your personal information for marketing purposes.
You can exercise your right to prevent such processing (i.e. “opt out”)
by clicking “unsubscribe” at the bottom of our marketing emails or by emailing
[](, with the subject “unsubscribe”.
You have the right to change your personal information we hold about you.
You can exercise your right by accessing your Account information in our app
(Open SiApp app -> Your Account Screen -> Edit (on Android) or Pencil icon (on iPhone) -> Change your details -> Save)
You have the right to ask us about the personal information we hold about you
and to request a copy of your personal information.
You can exercise your right to access this information by emailing
[](, with the subject “data access request”.
You have the right to delete your account and any personal information we hold on you.
You can exercise your right to delete your SiApp account and the personal information attached to it yourself,
by triggering an account deletion via the Help section within the SiApp app
(Open SiApp app -> Your Account Screen -> Settings -> Help -> Contact us -> Choose your problem = Delete Account)

Additionally, information about concerns or complaints may be made
to the Office of the Personal Data Protection Inspector of Georgia,


We reserve the right to change this Privacy Policy at any time.
Any such changes we may make to this Privacy Policy will be posted on the SiApp/Fitco Website(s),
and may be emailed to you.
Please check the Privacy Policy available on the SiApp and Fitco Website(s) from time to time.
In the event of any such change, by continuing to use the SiApp or Fitco Website(s) you agree to the relevant change.


Questions, comments and requests regarding this Privacy Policy are welcomed and
should be addressed to [](
with subject line “enquiry”.