Privacy Policy

This Privacy Policy applies to the Tai Chi Walking for Beginners mobile applications, website, and related services (collectively, the “Service”) operated by VISIBLEWEBS INC., with registered office at 55 Wheatfield Road, Barrie, Ontario, L9J0T4, Canada (“Company”, “we”, “us”, or “our”).This Privacy Policy explains what personal data we collect when you use the Service, how we use and share such data, how long we retain it, and the choices and rights available to you.Depending on the features you use, we may ask you to provide certain information to personalize your experience and provide the Service. This may include your name, email address, age, height, weight, fitness level, mobility level, wellness goals, activity preferences, and other onboarding information.

We use this information to provide personalized Tai Chi programs, recommend relevant exercises and content, improve your experience, and help you track your progress within the App.
We may also automatically collect certain technical information from your device, including language settings, IP address, time zone, device type and model, device settings, operating system, and other technical information. We use this data to operate and maintain the Service, improve app performance, analyze how users interact with our products, and, where applicable, support advertising and marketing activities.

Depending on your region and the product features available to you, we provide privacy controls that allow you to manage certain types of data processing. These may include options to manage online tracking, adjust advertising preferences, request deletion of your data, and exercise other privacy rights available under applicable laws.

If you have any questions or wish to exercise your privacy rights, please contact us
at taichi.help@proton.me.

This Privacy Policy explains what personal data is collected when you use our mobile applications, websites, and related services (together, the “App” or “Service”), and how such personal data is processed.

By using the Service, you acknowledge that you have read and understood this Privacy Policy and confirm that you are over 18 years of age. Where your consent is required for a specific type of data processing, we will request such consent separately in accordance with applicable law. If you do not agree or are unable to make this confirmation, you must not use the Service. In such case, you must (a) delete your account and contact us to request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you use iOS), Google (if you use Android), any other app stores that may be available from time to time, or by us if you purchased the Service directly through our websites; If you purchased a subscription directly through our website, you may manage or cancel your subscription through Paddle’s customer portal or by contacting us. If you purchased your subscription through a third-party app store, such as Apple App Store or Google Play, you must manage or cancel your subscription directly through the relevant app store. and (c) delete the App from your devices.

Any translation of the English version is provided for convenience and transparency purposes only. In the event of any discrepancy or difference in interpretation between the English version of this Privacy Policy available at Privacy policy and any translation, the English version shall prevail. The English text shall be the sole legally binding version.

1. Identifiers
This category may include your name and email address. You may provide this information when you create an account, use certain features of the Service, make a purchase, contact customer support, or otherwise communicate with us.

2. Onboarding and product data
You provide this category of information when you register for the Service, complete the onboarding process, and/or use the Service. This may include, in particular:

• General information about you. For example, age, date of birth, gender, country, etc.

• Wellness and fitness information. This may include information such as your age, height, weight, fitness level, mobility level, activity preferences, wellness goals, areas you would like to improve, and information about your Tai Chi training activity and progress. We use this information to personalize your experience, recommend relevant exercises and training programs, and help you track your progress within the Service.

• Special wellness data. Certain information collected through the Service may be considered sensitive personal data or a special category of personal data under applicable laws. This may include information related to your physical characteristics, wellness goals, fitness level, or other information you choose to provide when using personalized features of the Service. Where required by applicable laws, we will obtain your consent before processing such information.

3. Commercial information
When you purchase a subscription or other paid service, payment information is processed by the applicable third-party payment provider. We do not collect or store your full payment card details.
We may receive limited transaction information such as the product or subscription purchased, transaction date, transaction amount, currency, subscription status, renewal status, and transaction or purchase identifiers.
Payments are processed by Paddle, which acts as our Merchant of Record and handles payment processing, billing, invoicing, applicable tax calculation, and related payment services on our behalf.
We do not collect, store, or have access to your full payment card details. Paddle may process payment-related information, including your name, email address, billing information, payment method details, transaction information, subscription status, purchase history, refunds, and other information necessary to complete and manage your transactions.
We may receive limited information from Paddle, such as transaction confirmation, subscription status, purchased products or services, transaction date, amount paid, currency, and customer identifier information necessary to provide access to the Service and manage your account.

4. Comments and attachments provided with requests
You may also provide personal information when using “Contact us” forms or when communicating via email (including through communication service providers referenced in Section 3). This may include any information or comments included in your inquiry.

1. Online activity
We record how you interact with our Service. This may include interactions with interface elements, features and content, completed Tai Chi exercises or workouts, workout duration and timing, progress within training programs, frequency and duration of Service usage, onboarding activity, and subscription-related activity.

2. Device and approximate location data
We may automatically collect technical information about the device you use to access the Service, including IP address, language settings, time zone, device type and model, operating system, device settings, internet service provider, mobile carrier, and other technical identifiers.
Your IP address may be used to determine an approximate geographic location, such as your country or region. We do not collect precise GPS location from your device.

3. Advertising identifiers
Depending on your device, your privacy settings, and the permissions you provide, we and our advertising or analytics partners may process advertising identifiers such as Apple’s Identifier for Advertisers (IDFA) or Google’s Advertising ID. These identifiers may be used for attribution, advertising measurement, and, where permitted, personalized advertising.
Where required, we obtain your consent before using such identifiers for tracking or personalized advertising.

4. Cookies and similar tracking technologies
We use cookies, SDKs, pixels, and similar technologies on our website and in our mobile applications for purposes such as providing core functionality, remembering preferences, analyzing usage, measuring advertising performance, and, where permitted, personalizing advertising.
Where required by applicable law or platform rules, non-essential tracking technologies are used only after you provide the applicable consent or permission.

We respect your privacy and provide options to limit processing that is not strictly necessary for service delivery. We use the following categories of tracking technologies:

Strictly necessary
These technologies are required for the proper functioning of our products and are typically activated when you use the Service. They allow us to:
• remember your preferences while navigating the Service,
• ensure fast content loading,
• enhance security, and
• enable core functionality.

Functional
These technologies enhance and personalize your experience by remembering your preferences (such as language or design settings) and maintaining session continuity (for example, keeping you logged in or storing cart selections). If disabled, some features may not function properly.

Performance
These technologies help us understand how users interact with the Service by collecting aggregated usage information, such as:
• visit counts and traffic sources,
• most used features or sections,
• user behavior patterns and preferences,
• If disabled, we may not receive certain analytical data.

Targeting
These technologies are used to deliver personalized advertising and measure advertising performance. If disabled, you may receive less relevant ads, and our ability to measure campaign effectiveness may be limited.If you are located in certain jurisdictions, you may adjust your tracking preferences via a dedicated consent banner.

We collect and use your data primarily to deliver our services, improve the quality of our fitness and wellness offerings, and continuously enhance them. In addition, we use data to help attract new users to our products. Below, you will find a more detailed explanation of how your information is used, including illustrative examples.
Please also note that certain information we collect, including onboarding and product-related data, may be considered a special category of personal data or sensitive data under applicable data protection laws to which we are subject.

Description and examples:
This includes verifying your identity and email address, enabling you to access and use the Service smoothly, and preventing or resolving technical issues or errors. It also includes personalizing your experience.
Personalization means adapting the Service to your preferences, fitness or mobility level, wellness goals, and progress. For example, we may recommend specific Tai Chi exercises, training programs, or content based on the information you provide during onboarding and your activity within the Service.
We also process your data to respond to your requests for technical or customer support, Service-related information, or any other inquiries you initiate. This may include accessing your account to investigate and resolve support requests, providing detailed responses to your questions, ensuring satisfaction with the Service, and handling any disputes related to the Service.

Notifications:
We may send you notifications or emails regarding Service performance, security updates, payment transactions, or updates to our Terms and Conditions or Privacy Policy.

Events:
We may process your data if you participate in in-app challenges, offline community events, giveaways, or similar activities subject to additional terms and conditions.

Categories of personal data:
All categories of data.

Lawful basis:
Performance of a contract with you, or consent where processing involves a special category of personal data in a relevant jurisdiction.

Description and examples:
We communicate with you through various channels, including push notifications. These may contain reminders and motivational messages encouraging you to follow your Tai Chi training plan or continue your practice, as well as other service-related information such as password reset instructions or account updates. For example, you may receive a daily push notification at a scheduled time reminding you to complete a workout. You can opt out of push notifications by adjusting your device settings.
We may also contact you to inform you about important updates or changes to the Service, to collect feedback, or to respond to your inquiries or complaints.

Categories of personal data:
All categories of data.

Lawful basis:
Performance of a contract with you, or legitimate interest where such processing is not strictly necessary for the provision of the Service.

Description and examples:
We and our partners use your personal data to tailor advertisements and, where appropriate, display them at relevant times. For example, if you have installed our Service, you may see advertisements for our products within platforms such as Instagram.

Categories of personal data:

• Online activity
• Commercial and subscription-related information
• Device and approximate location data
• Advertising identifiers
• Cookies, SDKs, and similar tracking technologies

Lawful basis:
Legitimate interest (or consent where required under applicable e-Privacy or similar regulations).

Description and examples:
This includes conducting audits related to counting ad impressions and unique visitors, verifying the placement and quality of advertisements, and ensuring compliance with applicable specifications, standards, and requirements.

Categories of personal data:

• Online activity
• Commercial and subscription-related information
• Device and approximate location data
• Advertising identifiers
• Cookies, SDKs, and similar tracking technologies

Lawful basis:
Legitimate interest (or consent where required under applicable e-Privacy or similar regulations).

Description and examples:
We collect and store personal data to the extent necessary to protect and defend our legal rights and interests in the event of disputes, claims, or legal proceedings. This may include using such data to support legal claims, respond to lawful requests, or establish, exercise, or defend our legal position.

Categories of personal data:
All categories of data.
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Lawful basis:
Legitimate interest.

Description and examples:
Paid subscriptions may be processed by third-party payment and subscription service providers. We do not collect or store your full payment card details. We may receive transaction and subscription information necessary to activate your access, manage subscription status, provide customer support, and maintain transaction records.

Categories of personal data:

• Identifiers
• Commercial and subscription-related information
• Device and technical information

Lawful basis:
Performance of a contract with you

Description and examples:
This helps us better understand our business, analyze performance, and maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use this data for statistical analysis and to test and optimize our offerings.

This allows us to understand which features, workouts, and training plans are most popular and which user groups engage with the Service. Based on these insights, we may improve the Service. For example, if we observe that users frequently engage with leg-focused workouts, we may develop and add new workouts targeting that area.

We may also process your data for these purposes if you participate in surveys, interviews, studies, research initiatives, or similar programs.

Categories of personal data:
• Onboarding and product data

• Online activity

• Device and technical information

• Commercial and subscription-related information

• Identifiers, where necessary

Lawful basis:
Legitimate interest (unless consent is required, for example where special categories of personal data are involved or where applicable e-Privacy regulations apply).

Description and examples:
We may include your email address in our marketing communications list, provided we have obtained your consent or otherwise established a lawful basis for sending such communications. As a result, you may receive information about our products, including promotional offers and updates. If you no longer wish to receive marketing emails, you can unsubscribe by following the instructions provided in the footer of each marketing message.

Categories of personal data:
Identifiers

Lawful basis:
Consent or legitimate interest (where permitted under applicable law, including exceptions to consent requirements in certain jurisdictions).

Description and examples:
We may process personal data to comply with applicable legal and regulatory requirements, such as tax, accounting, and other statutory obligations. In particular, we may use your commercial information to calculate and report taxes, issue invoices or receipts, respond to inquiries from tax authorities, and maintain accurate financial records. We may also process data to comply with data protection laws (such as GDPR and CCPA), and to respond to lawful requests from public authorities, law enforcement, or regulatory bodies.

Categories of personal data:
All categories of data.

Lawful basis:
Compliance with legal obligations.

Description and examples:
We use personal data to enforce our agreements and contractual obligations, as well as to detect, prevent, and address fraudulent activity. This may include verifying user identities, monitoring transactions for suspicious behavior, and taking appropriate measures to protect users and the Service from fraud or abuse.

Categories of personal data:
All categories of data.

Lawful basis:
Legitimate interest.

*Legitimate interests:
To communicate with you regarding your use of the Service
This includes, for example, sending push notifications reminding you to exercise at appropriate times. The legitimate interest we rely on for this purpose is our interest in encouraging continued use of the Service. We also consider the potential benefits to you of following your Tai Chi training plan and maintaining a consistent practice.

To research and analyze your use of the Service and conduct user research (surveys, interviews)
Our legitimate interest for this purpose is to improve the Service by understanding user preferences and enhancing the overall experience (for example, making the App easier to use, more engaging, and introducing or testing new features).

To send you marketing communications (unless you provide consent)
The legitimate interest for this processing is our interest in promoting the Service in a reasonable and appropriate manner. This may apply, for example, where there is an existing business relationship, including prior purchases within the Service.

To personalize our ads
We rely on our legitimate interest in promoting the Service in a more relevant and targeted manner.

To audit advertising performance
The legitimate interest for this processing is ensuring the accuracy and quality of our advertising services and compliance with industry standards.

To enforce our Terms and Conditions of Use and defend our legal rights and interests
The legitimate interest is to protect the Company from legal disputes, claims, or actions that could affect its operations, reputation, or financial position, as well as to ensure compliance with the Terms and applicable laws. This may include using data to support our position in disputes, respond to legal requests, or provide evidence in legal proceedings.

To prevent and combat fraud
Our legitimate interest for this purpose is to enforce legal rights, prevent and address fraud, and protect against unauthorized use of the Service.

We engage third-party partners to perform specific services and business functions on our behalf, using their technologies and resources in accordance with our instructions. This cooperation may, in particular, involve the processing of your data through software development kits (SDKs), application programming interfaces (APIs), cookies, and other similar technologies. As a result, your information may be transferred to and processed on the servers of such partners (typically without granting them direct access to specific data elements) on our behalf and for our purposes.

Such processing of personal data may be considered as sharing of information with third parties. We endeavor to enter into appropriate data processing agreements with all such third parties in order to define the rules governing the processing of your data strictly on our behalf and within the scope of such purposes. Our partners assist us in operating, providing, improving, integrating, customizing, supporting, and marketing our Service.

The categories of third parties with whom we share information include, in particular:

We disclose personal data to third-party service providers engaged to perform services or business functions on our behalf, in accordance with our instructions. We process your personal information using the following categories of service providers (and, where applicable, their subprocessors):

a. Cloud and application infrastructure providers
We use Firebase, provided by Google, to support certain backend, analytics, configuration, and application functionality. Depending on the features enabled in the Service, Firebase may process device information, technical identifiers, application events, diagnostics, and usage data. Further information is available in Google’s and Firebase’s privacy documentation.

b. Product monitoring and diagnostics providers
We use Firebase Crashlytics and, where enabled, Firebase Performance Monitoring to identify crashes, diagnose technical issues, and monitor application performance. These services may process device information, diagnostic information, application identifiers, crash logs, and related technical data.

c. Analytics and attribution providers
We use AppsFlyer for mobile attribution and advertising measurement. AppsFlyer helps us understand how users discover and install our App and how advertising campaigns perform.
We use Amplitude to understand how users interact with the Service, including which features and content are used and how users progress through the Service.
We use Google Analytics to analyze use of our website and measure website traffic and performance.
We may use Google Analytics for Firebase and Firebase Remote Config to analyze use of our mobile applications, conduct A/B tests, configure features, and improve the user experience.

d. Payment and subscription service providers
For purchases made through our website, payments are processed by Paddle, which acts as the Merchant of Record. Paddle may process payment details, billing information, transaction information, tax information, and other information necessary to complete and administer a transaction in accordance with its own privacy policy.
Purchases made through the Apple App Store or Google Play are processed by Apple or Google, respectively, in accordance with their applicable terms and privacy policies.
We also use RevenueCat to manage subscription status and entitlements across our Service. RevenueCat may process purchase identifiers, product information, subscription status, transaction information, and related technical identifiers necessary to provide subscription management services.

e. Communication and notification service providers
We use OneSignal to deliver and manage push notifications. When notifications are enabled, OneSignal may process device identifiers, notification preferences, and related technical information necessary to deliver notifications.
Push notifications may also be delivered through platform services such as Apple Push Notification service (APNs) and Firebase Cloud Messaging (FCM).

g. Marketing service providers
We use advertising platforms such as Meta Ads and Google Ads to advertise the Service, measure campaign performance, and understand how users discover our products. Depending on your device, consent choices, and applicable law, these services may process advertising identifiers, device information, online activity, and conversion events.
Where required, we obtain the applicable consent or platform permission before using data for personalized advertising or cross-app tracking.

We share personal data with payment processing and billing providers that assist us with processing transactions, managing subscriptions, issuing invoices and receipts, calculating and handling applicable taxes, and providing payment-related services. This includes Paddle, which acts as our Merchant of Record for purchases made through the Service. Paddle may process personal data such as identifiers, billing information, transaction details, subscription information, purchase history, and other information necessary to provide payment and billing services on our behalf. Such providers process personal data in accordance with applicable data protection laws and their own privacy policies.

We may process and disclose personal data to enforce our Terms and Conditions of Use, protect our rights, privacy, safety, or property (including those of our affiliates, users, or others), and to comply with requests from courts, law enforcement agencies, regulatory authorities, or other governmental bodies, where required by applicable law.

In the course of business development, we may acquire or sell assets or business units. Customer information is generally considered part of such transferred assets. We may also share data with affiliated entities and transfer information in connection with corporate transactions, including mergers, acquisitions, divestitures, or, in rare cases, insolvency proceedings.

We may share personal data with entities within our corporate group, including companies that we own, that own us, or that are under common ownership. Such entities may process personal data only for the purposes described in this Privacy Policy and subject to appropriate data protection requirements.

For the purpose of providing our services, we may share personal information with entities that perform services on our behalf or assist in fulfilling our business purposes. Depending on their role and relationship with us, such entities may be classified as service providers (or contractors) and third parties under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

To exercise control over your personal data, you are entitled to the following rights:

Access, review, update, and correction of your personal data.
You have the right to review, edit, or modify personal data you previously provided to us. If you wish to obtain a copy of the data we process, you may submit a data access request or, depending on the product you use, utilize a data access feature available within the profile section of the Service.

Deletion of your personal data.
You may request the deletion of your personal data to the extent permitted by applicable law. Upon receiving such a request, we will make reasonable efforts to comply. However, in certain cases, we may be legally required to retain specific data for a defined period (for example, records related to payments or requests submitted to us). In such cases, your request will be fulfilled with respect to the portion of data not subject to legal retention obligations, and the remaining data will be deleted once the applicable retention period has expired.

Information regarding data processing.
You have the right to be informed about the collection and use of your personal data. This includes the right to know what data is processed, for what purposes, with whom it is shared, and for how long it is stored. We aim to provide this information transparently within this Privacy Policy. If you require further details, you may contact us at any time.

Objection to or restriction of processing.
You may request that we stop or limit the processing of your personal data. For example:
• Email marketing: You may unsubscribe from marketing communications via the unsubscribe link included in each email or by contacting support.
• E-privacy settings: We provide privacy controls that allow you to manage tracking preferences on a granular, purpose-based level. These settings are typically available in the footer, menu, or profile section of our products.

Control over personalized advertising.
Depending on your device and operating system, you may manage advertising and tracking preferences through your device privacy settings. You may also be presented with consent or privacy controls within our Service that allow you to manage certain advertising and tracking activities.
On iOS, tracking permissions may be managed through Apple’s privacy and tracking settings. On Android, advertising preferences and advertising identifiers may be managed through the applicable Google and device privacy settings.
Additional information on managing advertising preferences may be available through relevant platform resources and industry opt-out tools, including:
Network Advertising Initiative, Digital Advertising Alliance (US/Canada/EU), and AppChoices.
We respect your right to control advertising preferences and provide information about the service providers involved in such processing.

Right to lodge a complaint.
You may contact us directly, as we prioritize resolving concerns promptly. However, you also have the right to file a complaint with a competent data protection authority.
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Right to data portability.
You may request to receive your personal data in a structured, commonly used, and machine-readable format (for example, a .json file).

You may request to receive your personal data in a structured, commonly used, and machine-readable format (for example, a .json file).

Verification of requests.
To process your request, we may need to verify your identity, typically by confirming that the request originates from the email associated with your account. In some cases, additional minimal verification may be required.

Authorized agents.
You may authorize another person to submit requests on your behalf. If valid authorization (such as a power of attorney) is provided, we will communicate directly with the authorized agent. Otherwise, we may contact you to confirm their authority.

Account and Data Deletion.
If you have an account, you may request deletion of your account and associated personal data through the account deletion functionality available within the App or by using the account deletion method provided on our website.
You may also contact us at taichi.help@proton.me regarding deletion of your personal data.
When an account is deleted, we delete or anonymize personal data associated with the account unless we are required or permitted to retain certain information for legitimate purposes, including legal compliance, tax and accounting obligations, fraud prevention, dispute resolution, or enforcement of our agreements.
Deleting your account does not automatically cancel an active subscription processed by Apple, Google, or Paddle. Subscription cancellation must be completed through the applicable payment provider.

If you reside in a U.S. state with applicable privacy legislation, you may have additional rights, including the ability to:
• opt out of the sale or sharing of personal data;
• opt out of targeted advertising or cross-context behavioral advertising.
We may share certain data with partners for advertising or analytics purposes, which may be considered “sale,” “sharing,” or “targeted advertising” under applicable laws. You may opt out of such processing.
Where required by applicable law, we provide mechanisms that allow eligible users to exercise applicable opt-out rights, including rights relating to targeted advertising or sharing of personal information.

California residents may exercise additional rights under CCPA/CPRA, including:
• the right to know what personal data is collected, sold, or shared and to whom;
• the right to limit the use of sensitive personal data;
• the right not to be discriminated against for exercising privacy rights.
California residents may also request information under the “Shine the Light” law regarding disclosure of personal data for third-party marketing purposes.
Requests may be submitted to taichi.help@proton.me.

If your privacy request is denied under applicable U.S. state laws, you have the right to appeal the decision within a reasonable timeframe. Appeals should be clearly marked as “PRIVACY APPEAL REQUEST FOR USA” and should include reference to the original decision for proper review.

We do not knowingly process personal data of individuals under 18 years of age. If you become aware that a person under the age of 18 has provided us with personal data, please contact us at taichi.help@proton.me

We may transfer personal data to countries other than the country in which it was originally collected in order to provide the Service and for the purposes described in this Privacy Policy. Where required by applicable law, we implement appropriate safeguards for international transfers, which may include standard contractual clauses or other legally recognized transfer mechanisms.

We use reasonable technical, organizational, and administrative safeguards designed to protect personal data against unauthorized access, disclosure, alteration, loss, misuse, or destruction.
We also require service providers that process personal data on our behalf to implement appropriate safeguards consistent with applicable data protection requirements.
However, no method of electronic transmission or storage is completely secure, and we cannot guarantee the absolute security of personal data.

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the Service, by email, or by other appropriate means where required by applicable law.
We will update the effective or “Last Updated” date when changes are made. Where applicable law requires consent for a new or materially different type of processing, we will request such consent before beginning that processing.

We retain personal data only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including for as long as you maintain an account or use the Service, and for any additional period required or permitted by applicable law.
The applicable retention period may depend on the type of data, the purpose for which it was collected, our legal and contractual obligations, the need to resolve disputes or prevent fraud, and applicable limitation periods.
When personal data is no longer required for these purposes, we delete or anonymize it.
If you request deletion of your account or personal data, we will delete or anonymize the applicable information unless we are required or permitted to retain certain information for legitimate purposes, including legal, tax, accounting, security, fraud-prevention, or dispute-resolution requirements.
Information retained for such purposes will be kept only for the period necessary to fulfill the applicable requirement and will not be used for unrelated purposes.

If you have any questions about this Privacy Policy, our privacy practices, or the processing of your personal data, or if you wish to exercise your privacy rights, please contact us at:
VISIBLEWEBS INC.

55 Wheatfield Road

Barrie, Ontario, L9J0T4

Canada
Email: taichi.help@proton.me.