PRIVACY POLICY FOR GARMIN CLIPBOARD COACHING APP

Last Updated: September 1, 2020

Your privacy is important to Garmin. We developed this Privacy Policy to provide you with information on how we process personal data when you use the Garmin Clipboard coaching app or join a Garmin Clipboard roster as an athlete.

Other Garmin websites, apps and products that do not include a link to this Privacy Policy and include a link to a different Garmin privacy policy are governed by that privacy policy. For example, we have a separate privacy statement that applies to Garmin Connect and its compatible wearables and other devices.

“Personal data” is information relating to an identified or identifiable natural person.

To jump to a specific section of this Privacy Policy, please click on a link below:

Categories of Personal Data Processed by Garmin

Personal data that is processed when you create a Garmin account:

When you create a Garmin account, we ask you to provide your email address and name. You can choose to provide only your first name or a nickname instead of your full name if you wish.

PURPOSES AND LEGAL GROUNDS:

(a) Garmin processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on Garmin’s legitimate interest in protecting the security of your account.

(b) Garmin also processes your email address for the purpose of sending you important information about your Garmin products, apps or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile. The legal ground for processing your email address and name for these purposes is Garmin’s legitimate interest in providing you important safety or other information about your Garmin products, apps or account or material changes to this Privacy Policy.

(c) If you provide your opt-in consent to receiving marketing information from Garmin, Garmin will also process your email address for the purpose of sending you marketing information about Garmin products and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your Garmin account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from Garmin are based on the preferences you provide in your Garmin account, the locale indicated by your Internet Protocol (IP) address, the types of Garmin devices you have added to your Garmin account, and any subscriptions included in your Garmin account. The legal ground for processing this data for this purpose is Garmin’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

(d) Garmin also processes your email address to associate it with your Garmin account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

Personal data that is processed when you communicate with Garmin:

When you interact with our customer support representatives via email, telephone, online or in person, we collect personal data, such as your name, mailing address, phone number, email address and contact preferences; and information about the Garmin products you own, such as their serial numbers and dates of purchase. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys. With your consent, our customer support representatives may sign in to your Garmin account, if appropriate, to help troubleshoot and resolve your issue.

PURPOSE AND LEGAL GROUND:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is Garmin’s legitimate interests in providing quality product support. The legal ground for signing in to your Garmin account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.

Personal data that is processed when you set up a coach profile in the Garmin Clipboard coaching app:

When you use the Garmin Clipboard coaching app, you will be asked to provide your Garmin account credentials or create a Garmin account if you do not have one. You will be asked to provide a coach name and, if desired, a profile image.

PURPOSES AND LEGAL GROUNDS:

(a) Garmin processes your Garmin account information to link your Garmin account with your Garmin Clipboard coach profile. The legal ground for these processing activities is your consent, which you can withdraw at any time by deleting your sports, teams, and data within Garmin Clipboard coaching app settings.

(b) Garmin processes your coach name and profile image, if provided, to display to athletes who are invited to join your roster. The legal ground for this processing activity is your consent, which you can withdraw at any time by removing or changing your coach name or profile image in your Garmin Clipboard coaching app settings.

Personal data that is processed when you set up a roster in the Garmin Clipboard coaching app:

When you set up a roster in the Garmin Clipboard coaching app, you will be asked for your organization name and category, such as school or club, sport type, and team name. You can add additional information to each roster, such as an organization photo, organization colors, or team photo if you choose.

PURPOSES AND LEGAL GROUND:

(a) Garmin processes your organization name and sport type along with your coach name to identify you to athletes who are invited to join your roster. The legal ground for processing this information for this purpose is our legal obligation to gather informed consent from each athlete to share his or her data with a particular roster.

(b) Garmin processes your organization category to tailor the default settings to your organization type and to help us better understand our user base. The legal ground for processing this information for these purposes is our legitimate interests in ensuring we provide a quality experience and relevant features to our users.

(c) Garmin processes your team name to allow you to group athletes in your roster and view aggregated data for that team. You can create multiple teams within your roster and choose which athletes to associate with each team. The legal ground for processing this information for these purposes is performance of a contract.

(d) If you choose to provide them, Garmin processes your organization photo, organization colors, and team photo to personalize the view of your roster or teams if you wish. You can withdraw your consent by modifying or deleting this information within the Garmin Clipboard coaching app settings.

Personal data that is processed when you join a roster as an athlete:

If you are invited by a coach to join a roster and have not linked your Garmin account with Garmin Clipboard, you will be asked to provide your Garmin account information or create a Garmin account if you do not have one. You will also be asked to provide consent to share your activity data from Garmin Connect with Garmin Clipboard. If consent is granted to share your activity data from Garmin Connect with Garmin Clipboard, you will be asked to provide a name or nickname and, if desired, a profile photo. You will also be asked to provide consent to share your activity data from Garmin Clipboard with this roster and coach, and you will have an opportunity to configure stress and sleep data visibility.

PURPOSES AND LEGAL GROUNDS:

(a) Garmin processes your Garmin account information to link your Garmin account with Garmin Clipboard and to allow Garmin Clipboard to retrieve your activity data from Garmin Connect. The legal ground for these processing activities is your consent, which you can withdraw at any time by disconnecting your Garmin account from Garmin Clipboard within your Garmin account.

(b) Garmin also processes your Garmin account information to add you to the selected roster and share your Garmin Connect activity data with the coach associated with this roster. Once linked, your Garmin Connect activity data will be visible to the coach of the roster within the Garmin Clipboard coaching app individually and as aggregated with data shared by other athletes on the team you’ve been associated with by the coach. The legal ground for these processing activities is your consent. You can withdraw your consent at any time by leaving the roster within the Garmin Clipboard Athlete Portal, which can be found here or through the Garmin Clipboard link in your Garmin Connect settings, or by deleting your profile and data through the Garmin Clipboard Athlete Portal.

(c) Garmin processes your settings for stress and sleep data to filter the information shown to the coach in the Garmin Clipboard coaching app. You can change these settings within the Garmin Clipboard Athlete Portal, which can be found here or through the Garmin Clipboard link in your Garmin Connect settings. The legal ground for this processing activity is our legitimate interest in allowing you to configure sharing additional contextual data with the coach if desired.

(d) Garmin processes your name or nickname and profile photo, if provided, to display to the coach in the Garmin Clipboard coaching app. The legal ground for this processing activity is your consent, which you can withdraw at any time by removing or changing your name or nickname or profile photo in the Garmin Clipboard Athlete Portal, which can be found here or through the Garmin Clipboard link in your Garmin Connect settings.

Categories of Recipients of Personal Data

Coaches:

When you join a roster, the coach associated with that roster will process your Garmin Connect activity data, including stress and sleep data if you choose, your name or nickname, and, if provided, your profile photo.

Service providers:

Garmin uses a third party, Amazon Web Services (AWS), to host uploaded profile images and organization, team, or profile photos. Garmin also uses third-party service providers to help us better understand usage of our websites and apps.

Other disclosures:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Garmin’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Transfers of Personal Data

Garmin is a global business. To offer our products, apps and services, we may need to transfer your personal data to other Garmin companies in other countries. View Garmin-owned companies. For customers outside of China, when you create a Garmin account, add personal data in your account profile, or upload data to your Garmin account, your personal data will be collected and stored on Garmin International Inc.’s servers in the U.S. and Garmin (Europe) Ltd.’s servers in the U.K. For customers in China, when you create a Garmin account, add personal data in your account profile, or upload data to your Garmin account, your personal data will be collected and stored on Garmin China Shanghai RHQ Co. Ltd.’s servers in China.

Personal data regarding individuals who reside in a country in the European Economic Area ("EEA"), the United Kingdom ("U.K.") or Switzerland is controlled by Garmin Würzburg GmbH and processed on its behalf by Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. Where your data is transferred to an entity that is not in the EU or a jurisdiction deemed adequate by the European Commission, Würzburg GmbH has entered into model contractual clauses approved by the European Commission, including with Garmin International, Inc.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. comply with the EU-U.S. and Swiss-U.S. Privacy Shield principles regarding the collection, use, sharing and retention of personal information from the EEA, U.K. and Switzerland, as described in our EU-U.S. Privacy Shield certification and Swiss-U.S. Privacy Shield certification. Learn more about Privacy Shield.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. are subject to the oversight of the U.S. Federal Trade Commission and remain responsible for personal data transferred to third parties that process it on our behalf. If you have a complaint about our Privacy Shield compliance, please contact us at [email protected]. You can also refer a complaint to our chosen independent dispute resolution body, JAMS, and in certain circumstances, invoke the Privacy Shield arbitration process.

All Garmin companies are required to follow the privacy practices set forth in this Privacy Statement.

Cookies and Similar Technologies

We collect data from users about their usage of the Garmin Clipboard coaching app. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the mobile device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. Garmin uses this data to improve the quality and functionality of the Garmin Clipboard coaching app and other Garmin apps; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our apps so we can enhance the user experience and functionality of our products, apps and websites.

Here are examples of third-party providers of analytics and similar services we currently use:

ANALYTICS SERVICES:

Children

We request individuals under the age of 13 in the U.S. and under the age of 16 in the rest of the world not provide personal data to Garmin. If we learn that we have collected personal data from a child under the age of 13 in the U.S. or under 16 in the rest of the world, we will take steps to delete the information as soon as possible.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the Garmin websites and apps that link to this Privacy Policy.

Retention of Personal Data

We will retain your personal data as long as your Garmin account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

If you reside in a country in the EEA, U.K. or Switzerland, then your personal data collected by Garmin is controlled by Garmin Würzburg GmbH, which is located at Beethovenstraße 1a+b, 97080 Würzburg, Germany. The company's EU Data Protection Officer is located at the same address and can be reached by email at [email protected]

If you reside in China, then your personal data collected by Garmin is controlled by Garmin China Shanghai RHQ Co. Ltd, located at 37F, Tower A, New CHJ International Business Center, No 391, Guiping Road, Xuhui District, Shanghai 200233, China, which you can contact by email at [email protected].

If you reside outside of the EEA, U.K., Switzerland and China, then the personal data collected by Garmin is controlled by Garmin International, Inc., 1200 E. 151st St., Olathe, Kansas 66062, which you can contact by email at [email protected].

Your Rights

If you reside in the European Union or U.K., you have the right, subject to the conditions set out in the General Data Protection Regulation (GDPR) or U.K. Data Protection Act 2018 to request from Garmin access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. For more information about these rights, please visit the European Commission’s “My Rights” page relating to GDPR, which can be displayed in a number of languages. If you reside outside of the European Union and U.K., you may have similar rights under your local laws.

To request access to or rectification, portability or erasure of your personal data, or to delete your Garmin account, visit Account Management Center.

If you live in the European Union or U.K. and you wish to exercise your right to restriction of processing or your right to object to processing, please contact the company's EU Data Protection Officer at Garmin Würzburg GmbH at Beethovenstraße 1a+b, 97080 Würzburg, Germany, or by email at [email protected].

If you live in China and you wish to exercise any of your data subject rights, please contact Garmin China Shanghai RHQ Co. Ltd. at [email protected].

If you do not live in the European Union, U.K., or China, but you believe you have a right to exercise these or any other rights under your local laws, please contact Garmin International, Inc. at [email protected].

Notice for California Residents of Privacy Practices and Rights

If you are a California resident, California law may provide you with additional rights regarding your personal data. To learn more about your California privacy rights, visit the CCPA Privacy Notice.

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