Introduction
Peloton Document Solutions LLC, d/b/a/ pelotonRPM (“Peloton”) attaches the utmost importance to protecting your privacy and personal information. Accordingly, we have created this privacy policy (the “Privacy Policy”) in order to help you understand how Peloton treats information that you may provide to us, including how:
- We may use such information;
- We protect the security of such information; and
- To the extent you reside in the European Union and are subject to the General Data Protection Regulation (“GDPR”), you may have us remove such information from our servers by emailing privacy@pelotonrpm.com.
This includes any information associated directly with you (such as your name, title, email address, IP address or phone number) or that could be used to identify you that is supplied to us in conjunction with your use or potential use of the Peloton Software, Website and Service (also referenced collectively as the “Service.”)
In the event that Peloton purchases data from third parties, all third party sellers will be checked to ensure that all information has been supplied in accordance with any applicable GDPR standards.
Except as described in this Privacy Policy, we will not, without your consent, disclose, sell, rent, or otherwise provide to any third party any personally identifiable information collected through this Website or the Service.
Please note that our Website and the Documents shared via the Service may include hyperlinks to other websites that are neither owned nor managed by us. Peloton is not associated with these third-party websites and does not review their privacy policies. We cannot guarantee the privacy of any information that may be obtained by third parties at these other websites. We suggest that you review the privacy policies of any website you visit before supplying personally identifiable information through, or to, that website.
Information Collected via Peloton’s Public Website
Peloton maintains a log of certain information concerning visitors use of the Website, including, but not limited to, a visitor’s IP address (a computer’s numerical Internet address), the websites from which visitors access the Website, the type of web browsers used to access the Website, and the pages viewed.
Information collected via Peloton’s Service
Peloton gathers a range of information through usage of our Service. The Service is a web application that enables companies, other organizations and their representatives (the “Clients”) to share Peloton’s proprietary training materials and videos (the “Documents”) with their employees, contractors and other representatives (the “Readers.”) The Service also entails the provision of live, online, video-based simulation training for Readers. Videos and feedback information will be created during the Service and proprietary information provided by the Client may be made accessible to Readers via the Documents (the “Client Materials”).
When you are invited by a Client (or by Peloton, on Client’s behalf) to review a Document you will be prompted to register for the Service. Registration will require you to provide Peloton with information, including your company name and title. By registering for the Service you consent to allow Peloton to use such information in a manner that conforms with the terms of this Privacy Policy. While Peloton will not be profiling individuals, Clients may use this information to do so. Peloton does not decide who will or will not be granted access to a particular Document via the Peloton Service. The Client has full control over that decision. An Individual’s information is available to the Client and/or the Client’s Representatives. If you choose not to provide consent for your data to be utilized in conjunction with the provision of the Services, please contact the Client directly to notify them of such a decision.
Upon completion of registration you will be permitted to view the Documents via the Peloton Service. Peloton will have the ability to use your information to contact you for purposes relating to the Service, such as email alerts and notifications. Email communications will be sent to the email address listed in your profile. Peloton may also send SMS-based notifications to the mobile phone number you have provided for security and authentication purposes.
Your contact information will be added to the Peloton database of current and former users. This will allow Clients to share relevant Documents with you in the future without requiring an additional registration.
Peloton may use your business contact information to contact you regarding your and/or your company’s use of the Service and for customer support purposes, and to inform you of updates, modifications and other matters relating to the Service. You may decline to receive email from us that does not relate directly to your access to or use of the Service at any time. Peloton will use your username and password solely for registration, login and security related purposes.
Peloton also compiles and maintains information relating to your access to the Service, and certain actions taken by you while accessing the Service (for example, access to a Document, page views, searches, whether you shared the Document). Peloton may also maintain a log of users’ IP addresses, the websites from which users access the Service, the type of web browsers used to access the Service and the browser’s settings that may affect Service performance. Peloton may make any or all of this information available to a Client.
Data regarding your access to and use of the Peloton Service may also be provided to an employer whose systems are used by you to access the Service. Also, for purposes of maintaining and enhancing Service performance and security, Peloton may use such information as well. For technical support purposes Peloton may share information about your browser and other local computer settings in order to troubleshoot or avoid potential access problems.
In addition, in the event that Peloton goes through a business transaction such as a merger, an acquisition, a bankruptcy or restructuring, a joint venture, assignment or a sale of all or a portion of its stock or assets to which this Privacy Policy relates, your information will likely be among the transferred assets. You acknowledge that such transfers may occur and provide your unqualified consent.
Notwithstanding any other provision of this Privacy Policy, Peloton may disclose information collected about you in response to a subpoena, search warrant, court order, exchange rule or other legal process; and in its sole discretion if it believes such disclosure is appropriate in connection with an official government investigation, or under exigent circumstances in response to a perceived significant threat to a person’s health or property. We may also disclose information in order to enforce applicable Terms of Use, including as part of an investigation of potential violations; to detect, prevent, or otherwise address fraud, security or technical issues; and/or to protect against harm to the rights, property or safety of Peloton, our users or the public as required or permitted by law.
Information Security
We are committed to protecting Peloton and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold.
Peloton protects your information online by using industry standard encryption methods to prevent unauthorized access to Documents, data, and customer account information stored on our servers. Documents are fully encrypted. When you enter sensitive information on our registration or login forms, we encrypt that information using secure socket layer technology (SSL). We encrypt or hash your phone numbers and passwords in our databases to protect your online security, and we use HTTPS (SSL/TLS) to transmit and receive this information from you.
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Peloton and its service providers also maintain strict physical security at properties and facilities and only provide access to authorized personnel. To the extent required by the GDPR, Peloton does not host any personally identifiable information in countries outside of the EU and the United States.
Access to the information you provide us with is restricted to those of our employees, contractors and agents who need to know that information in order to operate, develop or improve our Service. These employees, contractors and agents are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. All contractors having access to information that could identify a person located in the EU are subject to agreements complying with the requirements of the GDPR.
While we follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
Updating Information
You can change or update your business contact information at any time, regardless of whether you are a current or former user of the Service, by logging into the Service with your user ID and password and accessing your profile. Of course, if your information has been deleted at any time, in accordance with your request or Peloton’s policies, your account will be deleted and you will not be able to update or change your information. All business contact information except your email address can be changed by you through your profile. If you wish to change your email address as listed in your profile, you must call our Customer Support line for assistance.
You may request that we remove your business contact information from our database. However, by doing so, you will automatically lose all access rights to the Service. You may have your business contact information removed from the database by emailing us at answers@pelotonrpm.com. Please note that your business contact information may be re-added to the database in the future if you are invited to view a Document by another Client.
Use of Cookies
Cookies are small pieces of information that are stored by your browser on your computer. Cookies can be used to remember certain information about you in order to customize the information you see during visits to a website and/or to collect information about your visit.
If you choose to contact us using an online form, communicate with Clients, via the Service or otherwise submit information through our website, your web browser will create a temporary Cookie. This temporary Cookie records your email address and makes it faster and easier to complete and submit forms. Once you have finished using the form or submitting your information, the Cookie is automatically deleted. We do not collect any information stored in this temporary Cookie.
Peloton also uses Cookies to help identify you and provide you with an additional level of security. After you have accessed the Peloton Service and supplied your user ID and password, a temporary Cookie is placed on your computer indicating that you have been verified to access the Service. This Cookie enables you to enter the Service throughout your current working session and will remain on your computer until you close your web browser or clear your cache. If your browser is set not to accept Cookies, you will not be able to sign into and/or use the Service. These Cookies are temporary unless you select “Remember My Email.” None of our Cookies are used for tracking your behavior outside of the Service.
Minors
The Peloton Service and website are not intended for use by children under the age of 18, and we do not intentionally collect any information from users under the age of 18. If a parent or guardian becomes aware that his or her child has provided Peloton with personal information, he or she should contact us at security@pelotonrpm.com. If you believe that we have mistakenly or unintentionally collected such information through our Site, please notify us at privacy@pelotonrpm.com so that we may immediately delete the information from our servers.
Changes & Notifications
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent. To the extent required by the GDPR, we will notify users of any material updates to this Privacy Policy.
Data Transfer
By using the Service or voluntarily providing us with information, including sensitive, confidential or personally identifiable data, you are consenting to our use and disclosure of it in accordance with this Privacy Policy. This Privacy Policy is intended to cover collection of information through our Services. If you provide personal data through our Service, you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of Peloton and any authorized third parties referred to herein located in the United States, which may have different data protection rules than in your country.
Data Retention
We will retain Reader usage data for as long as the Reader’s account is active or as needed to provide the Service. If you wish to cancel your account or request that we no longer use your information to provide you with Services, please contact us at privacy@pelotonrpm.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We will retain individual videos and feedback created during the Service that are deemed Client Materials for a period of three months and will then return or destroy such Materials in accordance with the applicable Services Agreement. An individual can, at any time, withdraw consent with no penalty and Peloton will act as quickly as possible to remove an Individual’s information. Please email privacy@pelotonrpm.com to withdraw consent or for any other questions regarding information processes.
For EU Residents, an individual’s consent date to our Terms of Use and Privacy Policy will be recorded and we will re-confirm consent every two years as specified under the GDPR standards. All individuals protected under the GDPR have a right to complain to the Information Commissioner’s Officer in the UK.
Contacting Us
If you have any questions or comments about this Privacy Policy please contact us at:
Steven Wiesner
Chief Privacy Officer
Data Protection Officer
privacy@pelotonrpm.com