SoterCoach Privacy Policy

In this Policy the following terms shall have the following meanings:

• "Account" means an account required to access and/or use certain areas and features of Our Site;
• "Cookie" means a small text file placed on your computer or device by Our Site and/or when you use certain features of Our Site.
• "Our Site" means the website, www.soter.com
• "Our Services" means any hardware, software or Cloud Services owned and operated by Soter Analytics LTD, including but not limited to the SoterSpine solution.
• "We/Us/Our" means the Soter Analytics entity you contract with and pay fees to based on the edition of the Soter product you're using. This table shows which Soter entity you contract with. For European Union data protection purposes, when we act as a controller in relation to your personal data, Soter Analytics LTD (UK) (company number 10782975) is our representative in the European Union.

Our approach to data protection is built around four key principles. They're at the heart of everything we do relating to personal data.

Transparency: We take a human approach to how we process personal data by being open, honest and transparent.

Enablement: We enable connections and efficient use of personal data to empower productivity and growth.

Security: We champion industry leading approaches to securing the personal information entrusted to us.

This Privacy Policy applies only to your use of Our Site and Our Services. It does not extend to any websites that are linked to from Our Site and Our Services (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

Some data will be collected automatically by Our Site and Our Services, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account. Depending upon your use of Our Site and Our Services, We may collect some or all of the following data:

4.1 name;

4.2 date of birth;

4.3 age;

4.4 gender;

4.5 weight, height or other body characteristics;

4.6 business/company name;

4.7 job title;

4.8 profession;

4.9 contact information such as email addresses and telephone numbers;

4.10 company identification number;

4.11 demographic information such as post code, preferences and interests;

4.12 IP address (automatically collected);

4.13 web browser type and version (automatically collected);

4.14 operating system (automatically collected);

4.15 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);

4.16 activity information collected from, but not limited to, wearable sensors;

4.17 For SoterTask product purposes we may collect, store and process your physical data through a video processing application.

We use your data to provide the best possible products and services to you. This includes:

5.1 Providing and managing your Account;

5.2 Providing and managing your access to Our Site and Our Services;

5.3 Personalising and tailoring your experience on Our Site and Our Services;

5.4 Supplying Our products and services to you;

5.5 Personalising and tailoring Our products and services for you;

5.6 Responding to communications from you;

5.7 Supplying you with email that you have subscribed to (you may unsubscribe or opt-out at any time;

5.8 Market research;

5.9 Analysing your use of Our Site and Our Services to enable Us to continually improve Our Site and Our Services and your user experience.

When you visit our websites or use our services, we collect personal data. The ways we collect it can be broadly categorised into the following:

Information you provide to us directly: When you visit or use some parts of our websites and/or services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for a free trial, respond to a job application or an email offer, participate in community forums, join us on social media, take part in training and events, contact customer support, or otherwise communicate with us.

Information we collect automatically: We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you're using our websites and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see).

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, take a look at our cookie notice.

Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.

Where we collect personal data, we'll only process it:

• to perform a contract with you, or
• where we have legitimate interests to process the personal data and they're not overridden by your rights, or
• in accordance with a legal obligation, or
• where we have your consent.

If we don't collect your personal data, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.

If you're someone who doesn't have a relationship with us, but believe that a Soter subscriber has entered your personal data into our websites or services, you'll need to contact that Soter subscriber for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data).

Some data will be collected automatically by Our Site and Our Services, other data will only be collected if you voluntarily submit it. Depending upon your use of Our Site and Our Services, We may collect some or all of the following data:

• Name
• Date of birth, age, gender
• Weight, height or other body characteristics
• Business/company name, job title, profession
• Contact information such as email addresses and telephone numbers
• Company identification number
• Demographic information such as post code, preferences and interests
• IP address (automatically collected)
• Web browser type and version (automatically collected)
• Operating system (automatically collected)
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)
• Activity information collected from wearable sensors
• For SoterTask product purposes we may collect, store and process your physical data through a video processing application

We use your data to provide the best possible products and services to you. This includes:

• Providing and managing your Account
• Providing and managing your access to Our Site and Our Services
• Personalising and tailoring your experience on Our Site and Our Services
• Supplying Our products and services to you
• Personalising and tailoring Our products and services for you
• Responding to communications from you
• Supplying you with email that you have subscribed to (you may unsubscribe or opt-out at any time)
• Market research
• Analysing your use of Our Site and Our Services to enable Us to continually improve Our Site and Our Services and your user experience

When you visit our websites or use our services, we collect personal data. The ways we collect it can be broadly categorised into the following:

• Information you provide to us directly: When you visit or use some parts of our websites and/or services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for a free trial, respond to a job application or an email offer, participate in community forums, join us on social media, take part in training and events, contact customer support, or otherwise communicate with us.
• Information we collect automatically: We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on.
• Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners.

We will not share any of your data with any third parties for any purposes, subject to the following exceptions:

• If We sell, transfer or merge parts of Our business or assets, your details may be disclosed to Our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business;
• We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data;
• We may compile statistics about the use of Our Site and Our Services including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers;
• In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site and Our Services.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• Account data will be retained for as long as your account is active or as needed to provide you services
• We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements
• If you request deletion of your data, we will delete it within 30 days unless we are required to retain it for legal purposes

You have the right to:

• Access: You have the right to request copies of your personal data
• Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete
• Erasure: You have the right to request that we erase your personal data, under certain conditions
• Restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions
• Object to processing: You have the right to object to our processing of your personal data, under certain conditions
• Data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions

Our Site and Services may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our Services.

In addition to Our own Cookies, We may also use various third party Cookies to report usage statistics of Our Site and Services, deliver advertisements on and through Our Site and Services, and so on.

This Privacy Policy applies only to your use of Our Site and Our Services. It does not extend to any websites that are linked to from Our Site and Our Services. We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

Our Site and Services are not directed at children under the age of 13, and We do not knowingly collect personal data from children under 13. If you are under 13, please do not use Our Site or Services or submit any personal data to Us.

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site and Services following the alterations.

If you have any questions about this Privacy Policy or Our treatment of your personal data, please contact us:

• Email: info@soteranalytics.com
• Phone: +1 (808) 646-7289