Privacy Policy

PERSPYRE

Last Updated: July 9, 2026

This Privacy Policy explains how Perspyre Technologies, Inc. handles personal information in connection with the Perspyre platform. In brief: businesses (“Organizations”) use Perspyre to run their operations, and most personal information on the platform belongs to those Organizations’ workspaces — we process it on their behalf and at their direction. For our own websites, marketing, account administration, security, and product improvement, we act as an independent controller. The sections below explain what we collect, how we use and disclose it, and the rights and choices available to you.

1. INTRODUCTION AND SCOPE

This Privacy Policy describes how Perspyre Technologies, Inc., a Delaware corporation (“Perspyre,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information in connection with our multi-tenant software platform, websites, mobile applications, APIs, and related services (collectively, the “Services”).

The Services are used by businesses and other organizations (each, an “Organization” or “Tenant”) to operate their own businesses, and by individuals — such as an Organization’s clients, members, participants, staff, and administrators — who access the Services in connection with an Organization. The Services may be presented under an Organization’s own branding; regardless of branding, this Privacy Policy applies to Perspyre’s handling of personal information through the Services.

This Privacy Policy applies to information we collect through the Services, through our websites and marketing activities, and from third parties in connection with the Services. It does not apply to the independent practices of any Organization or any third party, including how an Organization collects or uses information inside or outside the Services, or to information we collect from our own employees, contractors, and vendors.

“Personal Information” means information that identifies, relates to, or could reasonably be linked to an identified or identifiable individual. Personal Information does not include information that has been de-identified, anonymized, or aggregated such that it can no longer reasonably be linked to an individual.

2. OUR ROLES: PROCESSOR AND CONTROLLER

Processor / Service Provider. In most cases, Perspyre processes Personal Information on behalf of and at the direction of an Organization, which determines the purposes of processing. In these cases, the Organization is the data controller (or “business” under U.S. state privacy laws), and Perspyre acts as a data processor or service provider. Our processing on behalf of Organizations is governed by our agreements with them, including our Data Processing Addendum where applicable. If you are an Organization’s client, member, or staff member, the Organization’s own privacy notice governs its use of your information, and questions or rights requests concerning information in the Organization’s workspace should generally be directed to the Organization.

Controller. In certain contexts, Perspyre determines the purposes and means of processing and acts as an independent controller. These contexts include, for example: operating our own websites and marketing our services to prospective customers; managing our relationships with Organizations’ administrative and billing contacts; account registration, authentication, security, and fraud prevention across the platform; product analytics, research, and development; billing and platform-fee administration; and compliance with our own legal obligations. This Privacy Policy describes our practices when we act as a controller and provides transparency about our processing generally.

3. INFORMATION WE COLLECT

Information You or Your Organization Provide. Depending on how the Services are used, this may include: identifiers and contact details (such as name, email address, phone number, postal address, date of birth, and gender); account credentials and profile information; membership, scheduling, attendance, and activity records; documents, waivers, signatures, notes, photos, videos, and other content submitted to the Services; communications sent or received through the Services (including messages, support requests, and message content routed through SMS, email, and push notification features); emergency contact information; and information your Organization chooses to record about you in its workspace.

Payment Information. When payments are made through the Services, payment card and bank account details are collected and processed by our third-party payment processors (which may include Stripe, Inc.). We do not store full payment card numbers on our systems. We receive limited transaction information from processors, such as transaction amounts, dates, payment method type, card brand, last four digits, payout and dispute status, and identity-verification status for Organizations using connected accounts.

Health, Fitness, and Other Sensitive Information. Some Organizations use the Services to record information such as workout results, body measurements, nutrition information, injury notes, or similar data. We process such information only as enabled by the Organization and provided by or about you, on the Organization’s behalf, and as permitted by law and our agreements. We do not use such information for advertising.

Information Collected Automatically. When you use the Services we automatically collect: device and technical information (IP address, device identifiers, browser type, operating system, language and regional settings); usage information (pages viewed, features used, clicks, session duration, referring URLs, and crash and performance logs); approximate location derived from IP address; and, where you grant device permissions, information from your camera, photo library, or precise location (used only for the requested feature).

Information from AI Features. If you use AI-powered features of the Services, we collect the prompts and inputs submitted, the outputs generated, and related interaction logs.

Information from Third Parties. We may receive information from Organizations (which submit information about their clients, members, and staff), payment processors, identity-verification and fraud-prevention providers, communications providers (such as delivery and opt-out status for SMS and email), analytics providers, integration partners you or your Organization enable, and publicly available sources and business databases used for sales and marketing to prospective Organization customers.

You may decline to provide certain information or to grant certain device permissions, but some features may not function without it.

4. HOW WE USE INFORMATION

We use Personal Information to: provide, operate, maintain, secure, and support the Services and fulfill our contracts with Organizations; register and authenticate accounts and administer workspaces; process transactions, payouts, platform fees, refunds, and disputes through our payment processors; deliver communications initiated through the Services (such as scheduling notices, receipts, reminders, and messages configured by Organizations); provide customer support; monitor, analyze, and improve the Services, including developing new features and products; provide and improve AI features, including logging prompts and outputs for quality, safety, abuse prevention, and support purposes, and using de-identified, anonymized, or aggregated information to develop and improve models and analytics where permitted by law; personalize your experience and remember preferences; send administrative, service, security, and legal notices; market our services to prospective and current Organization customers, subject to opt-out rights; detect, investigate, and prevent fraud, abuse, security incidents, and violations of our terms and policies; comply with legal obligations, enforce our agreements, and protect the rights, property, and safety of Perspyre, our users, and others; and evaluate and complete corporate transactions such as financings, acquisitions, or reorganizations.

Where the GDPR or similar laws apply, we rely on one or more of the following legal bases: performance of a contract, legitimate interests (such as securing and improving the Services and marketing to business contacts), consent (where required, such as for certain cookies or marketing), and compliance with legal obligations.

De-identified and Aggregated Data. We may create and use de-identified, anonymized, or aggregated data (for example, usage trends and benchmarking statistics) for any lawful business purpose. We maintain such data in de-identified form and do not attempt to re-identify it, except as permitted by law to test the effectiveness of de-identification.

5. HOW WE DISCLOSE INFORMATION

To and at the Direction of Organizations. Information in an Organization’s workspace is accessible to that Organization and its authorized administrators and staff, and we disclose information as instructed by the Organization. Organizations control their own workspaces, and their use of information is governed by their own privacy practices.

Service Providers and Subprocessors. We disclose information to vendors that perform services on our behalf, including cloud hosting and infrastructure providers, payment processors, communications providers (SMS, email, voice, and push), AI model providers, analytics and crash-reporting providers, customer-support tooling, security and fraud-prevention providers, and professional advisors. Service providers are bound by contractual confidentiality and data-protection obligations and are permitted to use Personal Information only to provide services to us.

Payment Processors. When payments are enabled, information is shared with our payment processors as necessary to onboard accounts, verify identity, process transactions and payouts, manage reserves and disputes, and comply with financial regulations and card network rules. Processors may act as independent controllers of certain information under their own privacy policies.

Other Users. Some features are social or shared by design (for example, leaderboards, class rosters, community feeds, or shared documents, where enabled by an Organization). Information you post to shared features may be visible to other users of that Organization’s workspace.

Integrations You or Your Organization Enable. If you or your Organization connect third-party applications or integrations to the Services, we disclose information to those third parties as directed by the connection. Their use of information is governed by their own terms and privacy policies.

Legal and Protective Disclosures. We may disclose information where we believe in good faith that disclosure is reasonably necessary to comply with law, regulation, legal process, or enforceable governmental request; to enforce our agreements and policies and investigate potential violations; to detect, prevent, or address fraud, security, or technical issues; or to protect the rights, property, or safety of Perspyre, our users, or the public.

Business Transfers. We may disclose or transfer information in connection with, or during negotiations of, any merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale of all or a portion of our business or assets, subject to reasonable confidentiality protections, and will provide notice of any resulting change in ownership or use of Personal Information as required by law.

Affiliates. We may share information with our corporate affiliates, consistent with this Privacy Policy.

We do not sell Personal Information for monetary consideration.

6. COOKIES AND SIMILAR TECHNOLOGIES

We and our providers use cookies, local storage, software development kits, pixels, and similar technologies to operate and secure the Services, remember preferences and sessions, measure and analyze usage, and, on our marketing websites, measure the effectiveness of our marketing. We classify these technologies as strictly necessary, functional, analytics, and (on marketing properties) advertising.

You can manage cookies through your browser or device settings and, where offered, through our cookie preference tools. Where required by law, we honor recognized universal opt-out signals, such as the Global Privacy Control, as a request to opt out of “sale” or “sharing” for cross-context behavioral advertising for the browser or device sending the signal. Blocking certain cookies may affect the functionality of the Services.

7. YOUR RIGHTS AND CHOICES

Requests Concerning an Organization’s Workspace. If your information is held in an Organization’s workspace, the Organization is generally the party responsible for responding to access, correction, deletion, and similar requests, and we will assist the Organization as required by law and our agreements. We may redirect requests we receive to the responsible Organization.

Requests to Perspyre. Where Perspyre acts as a controller, you may request access to, correction of, deletion of, or a portable copy of your Personal Information, and may object to or request restriction of certain processing, by contacting contact@perspyre.com. We will verify your request and respond as required by applicable law, subject to legal exceptions (for example, information we must retain for security, legal, audit, or dispute-resolution purposes, or information residing in backups pending routine deletion). We will not discriminate against you for exercising your rights. Deleting certain information may limit or prevent your use of the Services.

Marketing Opt-Out. You may opt out of Perspyre marketing emails by using the unsubscribe link in those emails, and out of marketing texts (if any) by replying STOP. Operational and transactional communications will continue as permitted by law. Communications sent by or on behalf of an Organization are the Organization’s responsibility, and you should also use the opt-out mechanisms and contacts the Organization provides.

Account Information. You may review and update certain profile information through your account settings, or contact your Organization to update information it maintains about you.

8. U.S. STATE PRIVACY RIGHTS

Residents of California and certain other U.S. states (including, for example, Colorado, Connecticut, Texas, Utah, and Virginia) have rights under state privacy laws, which may include the rights to know or access, correct, delete, and obtain a portable copy of Personal Information, to opt out of “sale,” “sharing,” and certain targeted advertising or profiling, and to limit use of sensitive personal information, subject to legal exceptions.

With respect to Personal Information we process on behalf of Organizations, we act as a “service provider” or “processor,” process Personal Information pursuant to written contracts, and do not sell or share such information for cross-context behavioral advertising. Please direct requests concerning that information to your Organization; we will assist the Organization as required by law.

With respect to Personal Information for which Perspyre is the “business” or controller (such as marketing and website data), you may submit requests to contact@perspyre.com. We do not sell Personal Information for monetary consideration and do not use or disclose sensitive personal information for purposes requiring a right to limit under the CCPA. If any “sharing” for cross-context behavioral advertising occurs through cookies on our marketing websites, you may opt out through our cookie preference tools or a recognized universal opt-out signal such as GPC. We do not knowingly sell or share the Personal Information of individuals under 16. You may designate an authorized agent to make requests on your behalf as permitted by law, and you may appeal a refusal to act on your request by replying to our response or contacting contact@perspyre.com.

California “Shine the Light.” California residents may request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes; we do not disclose Personal Information to third parties for their own direct marketing purposes.

9. EEA, UK, AND SWISS PRIVACY RIGHTS; INTERNATIONAL TRANSFERS

If you are located in the European Economic Area, the United Kingdom, or Switzerland, applicable data protection laws (including the GDPR and UK GDPR) provide rights of access, rectification, erasure, restriction, portability, and objection, as well as the right to withdraw consent (where processing is based on consent) and the right to lodge a complaint with your supervisory authority. Where an Organization is the controller of your information, please direct requests to the Organization in the first instance; where Perspyre is the controller, contact contact@perspyre.com.

The Services are operated from the United States, and information is transferred to, stored in, and processed in the United States and other countries where we or our service providers operate, which may not provide the same level of data protection as your jurisdiction. Where required by law, we use appropriate safeguards for cross-border transfers, such as the European Commission’s Standard Contractual Clauses (with the UK Addendum or Swiss equivalents where applicable) or other lawful transfer mechanisms. You may contact us for more information about our transfer safeguards.

10. SECURITY

We implement administrative, technical, and physical safeguards designed to protect Personal Information, including encryption in transit, access controls, logging, and organizational security practices appropriate to the nature of the data and the Services. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach of security affecting Personal Information, we will notify affected Organizations, individuals, and regulators as required by applicable law.

You are responsible for maintaining the confidentiality of your credentials and for the security of the devices you use to access the Services.

11. RETENTION

We retain Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services to Organizations, and as required or permitted by law. The criteria we use to determine retention periods include: the duration of our relationship with the applicable Organization and the individual’s activity on the Services; our contractual obligations to Organizations; legal, tax, accounting, audit, security, and dispute-resolution requirements; and the operation of routine backup and archival systems. Information processed on behalf of an Organization is retained, returned, or deleted consistent with our agreements with that Organization and our published policies. We may retain de-identified, anonymized, or aggregated data indefinitely.

12. CHILDREN’S PRIVACY

The Services are not directed to children under 13, and we do not knowingly collect Personal Information from children under 13 (or under a higher applicable minimum age) except where an Organization has enabled minor profiles and appropriate parental or guardian consent has been obtained by the Organization or the parent or guardian as required by law. Organizations are responsible for obtaining any legally required consents for minors they enroll in the Services. Parents and guardians who believe a child’s information has been collected without appropriate consent may contact contact@perspyre.com, and we will take appropriate steps, including deletion where required.

13. THIRD-PARTY SITES AND SERVICES

The Services may link to or interoperate with websites, applications, and services operated by third parties, including integrations enabled by you or your Organization. We are not responsible for the privacy practices or content of third parties, and this Privacy Policy does not apply to them. We encourage you to review the privacy policies of any third-party services you use.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The “Last Updated” date at the top indicates when it was most recently revised. If we make material changes, we will provide notice by reasonable means, such as posting notice within the Services or emailing account contacts, before the changes take effect where required by law. Your continued use of the Services after the effective date of an updated Privacy Policy constitutes acceptance of the update to the extent permitted by law. If you do not agree, you must stop using the Services.

15. CONTACT US

If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, or wish to exercise your rights, contact us at: Perspyre Technologies, Inc., Attn: Privacy, 49 Clarendon St, Watertown, MA 02472, or contact@perspyre.com. If you have an unresolved privacy concern that we have not addressed satisfactorily, you may have the right to contact your local data protection or consumer protection authority.