Privacy Policy

Last Updated On: 09^th September 2025

My Whoosh Technology Services LLC (hereinafter referred to as “we”, “us”, “our”, “company”, “MyWhoosh”), based in Abu Dhabi, UAE is a limited liability company and the ‘data controller’ in respect of your personal information. We specialize in developing and maintaining a virtual cycle platform (MyWhoosh) through our applications (Apple, Android, Windows and MacOS) and website. Our services encompass the application, its services, features, etcetera (collectively referred to as “Services“, “App”) and www.mywhoosh.com (“Site”).We are committed to protecting your privacy and handling your personal data in compliance with all applicable laws, including the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL), and the EU General Data Protection Regulation (GDPR). By using our Services, you agree to the collection and use of your information as described in this Privacy Policy.

We understand the importance of protecting the personal information of our customers (hereinafter referred to as “Customer”, “you”, “user”, “Data Subject”). This Privacy Notice outlines how we process any personal information collected from you, third parties, or provided by you. We encourage you to read this Privacy Notice thoroughly so that you are familiar with our practices concerning your personal information, privacy, and security while using MyWhoosh.

For general queries, please use the “Contact Us” section of the website or App and concerns related to data privacy, please reach out to the MyWhoosh Data Protection Office at privacy@mywhoosh.com.

WHAT PERSONAL INFORMATION WE COLLECT

We collect the following categories of personal information:

Personal Identifiers: Name, date of birth, country, location, billing address, email address, and phone number.
Protected Class Information: Age and gender (self-identified).
Sensitive Personal Information: Height, weight, heart rate, race results, and cycling performance information (ride-related data such as scores and rankings, etcetera).
Account Login and Device Information: User ID and encrypted password, IP address, device details, and web browser information.
Audio and Visual: Video recordings and photographs (as part of live stream for verification purposes to participate in any premium event) and, recordings of customer service calls for training and quality purposes.
Customer Satisfaction Survey: Answers to any customer satisfaction surveys or market research (unless these are provided anonymously).
Financial Information: Bank account details (for the purpose of prize money payouts) and In-App purchases.
Cryptocurrency Wallet Information: If you participate in the Treasure Hunt feature and qualify for Bitcoin rewards, you will be required to provide your Binance wallet public key in your profile. Additional personal verification details such as passport information, Binance verification screenshot with registered email, and explicit consent will also be collected for compliance and security purposes.
Marketing Preferences: Marketing preferences that you may choose during the account registration process and any modifications made to them by you at a later stage.
Cookie Data: We store certain data that gets collected automatically at our end, for example through cookies and other similar technologies. You have full control to customize non-essential cookies. For more information on the cookies, please refer to the Cookie Notice.

HOW AND WHEN WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information when you:

Visit our website or use the application, including activities such as registering on our website or in the application, leaving reviews or comments, filling in forms (e.g., signing up for newsletters, entering events or championships such as competitions, contests, prize draws, raffles, or sweepstakes), and engaging in workouts.
Process In-App purchases from our application or subscribe to any of our paid services.
Attend our cycling and other events.
Contact us through the “Contact Us” form, reach out to the Customer Service Department via email, online Chat Support, call, or request information through any other means.
Participate in our customer satisfaction surveys or other market research initiatives.
Communicate with us through social networking websites, third-party applications, or similar technologies.
When you participate in the Treasure Hunt feature, we collect personal and ride-related data, including location tracking for eligibility verification and transaction details for Bitcoin payouts.

We may also collect information about you from third-party sources, such as from your use of other websites/applications, the use of devices and hardware to access and use the services and application, from tracking and rider profile platforms (e.g., Strava), and from social media platforms (e.g., Instagram, Facebook, and any social rider communities and events.) In such cases, we ensure that the proper legal basis and/or prior consent is in place before collecting such information. It is important to note that you have control over your access and consent for each of these platforms and companies. You can revoke consent at any time if you choose not to have the data controller process and share your information.

WHY WE COLLECT YOUR PERSONAL INFORMATION

MyWhoosh uses the data collected from the users and visitors as well as other relevant individuals to maintain our website and supply relevant support and services to them.

The personal information we gather and/or otherwise receive is processed for the following purposes:

Allowing new users to register to our website and/or application and allow existing users to register for premium events.
Authenticating and recognizing you as a separate user and distinguishing you from other users.
System administration and internal operations including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
Analyzing your preferences to personalize your training regime.
Supplying technical and non-technical support related to MyWhoosh ensuring a satisfactory level of customer service.
Customizing marketing or advertising to be more relevant to you.
Letting you know of all developments and/or any changes to keep you informed.
Sending news, updates, and marketing communications related to MyWhoosh to the registered email address.
Letting you know about upcoming events and community rides in your location.
Analyzing race performance to validate results and prevent cheating.
Making the experience free of bullying, illicit usage, and abuse, ensuring security and fraud prevention, and monitoring to police our races to prevent cheating.
Ensuring that our Site and App are safe, secure, and free of glitches and errors, catering to the diverse needs during your usage of the App.
Monitoring your use of our Site and the App to improve the user experience and ensure that content is presented in the most effective manner for you and your device.
Ensuring compliance with applicable laws and regulations.
To verify eligibility and participation in the Treasure Hunt feature, process Bitcoin payouts securely, and ensure compliance with applicable cryptocurrency regulations.

We may also match personal information that you provide to us directly with other information about you obtained from or held by third-party sources (such as social media, training, and fitness platforms). This may include your contact details, demographic data, your social media interactions, preferences, geographic location, and age or age range. We may use this personal information to predict and analyze your performance or to tailor and show advertisements more relevant to you either on our website and/or application or on third-party websites (including social media platforms).

Automated Decision-Making: MyWhoosh may use automated processing and artificial intelligence (AI) in limited ways to operate and enhance the Services; In general, automated decisions that could significantly affect you (such as banning an account for misuse) involve human review or are made under our Terms of Service enforcement framework.

No Legal or Profound Impact without Human Oversight: We do not make solely automated decisions that produce legal effects or similarly significant impacts on you without human involvement, unless such processing is necessary as part of the Service you request (like participating in an event to identify and monitor your participation) or we have your explicit consent, in accordance with Article 22 of the GDPR and Article 18 of the UAE PDPL. This means any decision significantly affecting your rights including but not limited to participating in events, height and weight verification, will involve appropriate human review. You also have the right to object to any automated decision-making or profiling that you feel is unjustified (see Your Rights below).

LEGAL BASIS FOR COLLECTING AND PROCESSING YOUR PERSONAL INFORMATION

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

Consent: For example, where you have provided your consent to receive certain marketing from us and/or where you have provided your explicit consent for us to process certain physical information as part of your use of the App (as described above).
Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services, and effectively operate as an indoor fitness and cycle racing app, provided in each case that this is done in a legitimate way that does not unduly affect your privacy and other rights.
Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, when you may purchase products/services from us, and we need to use your contact details and payment information in order to process your order.
Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation. We process cryptocurrency-related data to comply with anti-money laundering (AML) laws, KYC (Know Your Customer) regulations, and to prevent fraudulent transactions.
Restrictions on marketing: We do not allow behavioral or targeted advertising for users under the age of 18 unless verifiable parental consent is obtained. Any such advertising must comply with applicable requirements. Without consent, tracking technologies for targeted ads will be disabled for these users.
Vital interests: In some limited cases, we may need to process your personal information where it is necessary to protect your vital interests or the vital interests of another person.

For example, we may need to process your personal information to provide you with medical assistance in an emergency.

We will always take steps to ensure that the processing of your personal information is fair and lawful, and that it does not unduly affect your privacy. You have a number of rights in relation to your personal information, including the right to access, correct, and delete your personal information. You can exercise these rights by contacting MyWhoosh Data Protection Office at privacy@mywhoosh.com.

HOW LONG WE STORE YOUR PERSONAL INFORMATION

We take diligent measures to ensure that the personal information you provide to us is retained only for as long as necessary for the purpose for which it was collected.

We may keep a record of our correspondence with you, such as in the case of a complaint, for as long as is necessary to protect us from potential legal claims. If we have gathered your personal information based on your consent and lack any other lawful basis to continue processing, and if you subsequently withdraw your consent by writing to us at privacy@mywhoosh.com, requesting deletion, we will promptly delete your personal information.

Please be aware that in the event of your unsubscribing from our marketing communications, we will retain a record of your email address to ensure that no further marketing emails are sent to you in the future.

This Section Pertains to Users in the UK and/or the EEA.

The personal information we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries that have less strict, or no data protection laws compared to those in the EEA or the UK. Whenever we transfer your information in this manner, we will take steps that are reasonably necessary to ensure adequate safeguards are in place to protect your personal information and to ensure it is treated securely and in accordance with this Privacy Notice. When relevant, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are situated in the UK or the EEA, you can reach out to us at privacy@mywhoosh.com to request a copy of the safeguards we have implemented to protect your personal information and privacy rights under these circumstances.

PERSONAL INFORMATION OF CHILDREN

We are deeply committed to safeguarding the privacy of children and ensuring compliance with applicable laws pertaining to the collection and processing of the personal information of children. We do not intentionally or knowingly collect any personal information related to children or individuals under the age of 6, nor do we encourage their usage of the website and application. If you have not reached the age of 6, you are prohibited from using the website and application unless supervised by an adult. By accessing the MyWhoosh website and application, you affirm and guarantee that you are 6 years of age or older. We hold no liability for any unsolicited information provided by you, and you consent to the usage of such information in accordance with this Privacy Notice.

For users between the ages of 6 and 18, we may require verifiable written consent from their parents or guardians through a consent verification process. When a child attempts to register for our services, the parent will receive an email clearly specify the categories of personal data that will be collected from the children during registration and use of the services, including but not limited to name, email address, age, gender, height, and weight; and Inform the parent or guardian that their supervision is required during the setup and configuration of any devices or hardware associated with the children’s use of the services. Parental consent is required to activate the child’s account. If the company becomes aware that a child under the age of 6 has given their personal information, MyWhoosh reserves the right to promptly delete the information collected from its records. We remain steadfast in our commitment to safeguarding the privacy needs of children and encouraging parents and guardians to actively participate in the online activities and interests of their children.

If the winner of any premium race event is between the ages of 6-18, we may require either (a) consent from their parents or legal guardian or (b) the personal (financial) information from their parents or legal guardian before awarding them the prize money. Such personal information will be stored for audit and legal record purposes.

For registered users aged between 6 and 18, we may share account-related information, including usage data and activity logs, the date of consent verification, and the parent/guardian’s email address with their parent or legal guardian in accordance with applicable data protection laws. This is to ensure transparency, compliance, and the safety of children users on the platform.

Privacy Provisions for Child Users (Aged 6 to 18)
We are committed to protecting the privacy of younger users and ensuring compliance with applicable child data protection laws. For users aged 6 to 18, the following additional privacy measures apply:

Parental Consent Required: Account creation requires verifiable consent from a parent or legal guardian, which is collected via the parent’s registered email address. Parental/Guardian consent shall be reaffirmed on an annual basis through an email communication, to ensure transparency and continued lawful use of the child’s account.
Ongoing Consent for Key Actions: Certain activities—such as participating in events, updating profile information, or enabling data sharing features—may require additional parental approval, which will be requested via email.
Account Monitoring: We may share certain account information, usage data, and activity logs, together with date of consent and guardian email, with the registered parent or guardian to ensure transparency and safety.
Limited Data Collection: We collect only the minimum necessary personal information from child users and handle such data in accordance with applicable privacy laws.
Database Separation: Data of child users is stored in a separate database from adult users.

PARENTAL CHOICES AND CONTROLS

At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.

Parents can request access to and delete their child’s personal information by contacting us on support@mywhoosh.com. A valid request to delete personal information will be accommodated within a reasonable time.

When your child turns 18, he or she will be eligible to independently manage his or her account which shall be considered as an account of major.

SECURITY MEASURES

MyWhoosh is committed to safeguarding and protecting personal information. We have implemented and maintained appropriate technical and organizational measures to ensure a level of security that is fitting to protect any personal information provided to us. This includes protection against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information during transmission, storage, and processing.

On our website and application, you may find links to third-party websites and services, including our business partners and advertisers. It is important to note that these third-party entities have their own privacy notices, and we do not bear any responsibility or liability for them. We strongly advise reviewing the privacy notices of these third-party websites or services before submitting any personal information to them.

INFORMATION SHARING

We prioritize the security and privacy of your personal information. In certain circumstances, we may share your personal information within our group of companies, which includes our subsidiaries. Additionally, we may share your personal information with our suppliers, business partners, and service providers. This sharing may occur, for example, with providers of fitness tests and other functionalities, as well as entities helping us in marketing, advertising, and delivering our services to you. These companies do not have any independent right to further share or disseminate this information.

We may also share your personal information as follows:

a. FOR COMMUNITY BUILDING: Given our emphasis on bringing your fitness community to your home, we share specific information with other users when you connect with them. For instance, when you challenge someone or engage in a conversation in the application’s chat section. The credentials made available to other users include your name, gender, age, height, weight, and the country from which you are operating. No further information is shared with the community unless you explicitly enable it.

b. FOR SOCIAL SHARING: MyWhoosh facilitates connections with various social fitness apps such as Today’s Plan, Training Speaks, and Strava, along with other social networking apps. When you connect your MyWhoosh account with these apps, some of your information will be shared with them. You maintain control over this information, as the decision to link your MyWhoosh account with such apps is entirely yours. Once connected, you can share your training records, gaming feats, and similar information on these apps.

c. USE OF PRIVATE CHAT FEATURE: Users are advised not to share personal or sensitive information, avoid misconduct, and refrain from sharing critical data while using the Private Chat feature. Misuse or violations may result in action per our Terms and Conditions. Please note, the Private Chat feature will not be available for users between the ages of 6 to 18, in line with our safety and compliance policies.

d. FOR BROADCASTING RACES: Subject to your explicit consent, we may share your personal information, including actual and generated workout details and in-app activity data, with broadcasters and other content platforms. This sharing enables them to broadcast, stream, or otherwise provide live data when you participate in our races.

e. OTHER: We may share your personal information with affiliates, partners, service providers, group entities, and non-affiliated companies under various circumstances, including:

Financial information (e.g., method of payment and payment-related information) with payment processors and gateways for secure transactions.
We may share information with statutory authorities, government institutions, law enforcement agencies, or other bodies where required for compliance with legal requirements.
We may use the information to respond to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights, or defend against legal claims.
We may share information where we believe it is necessary in order to investigate, prevent, or take action against any illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
We may share information where we believe it is necessary in order to protect or enforce MyWhoosh’s rights, usage terms, intellectual or physical property, or for the safety of MyWhoosh or associated parties.
We may share information about you if MyWhoosh is acquired by or merged with another company after ensuring such company offers an equivalent level of protection for personal data.
We may share information about you for research, evaluation, and analysis purposes.

YOUR RIGHTS

You have certain rights in relation to the personal data we store about you. These rights are derived from global data protection standards and may vary depending on your country of residence.

A. General Rights (Applicable to All Users)

All users are entitled to the following rights:

Right to be informed: Clear and transparent information about how your data is used.
Right of access: Obtain a copy of the personal data we hold about you.
Right to rectification: Correct inaccurate or incomplete data.
Right to erasure (“right to be forgotten”): Request deletion of your personal data when no longer necessary or upon withdrawal of consent.
Right to restrict processing: Request that we limit how we use your data in certain circumstances.
Right to object: Object to processing based on legitimate interests or direct marketing.
Right to data portability: Receive your data in a structured, machine-readable format and transfer it to another controller.
Right not to be subject to automated decision-making: Avoid decisions made solely by automated means that significantly affect you.
Right to withdraw consent: Withdraw previously given consent at any time without affecting prior lawful processing.

B. Additional Country-Specific Rights

Depending on your country of residence, you may have additional rights under local laws, including but not limited to:

EEA, UK & UAE: All general rights above apply, including enhanced safeguards for automated decision-making.
Kuwait: Right to erase, destroy, or anonymize personal data if consent is withdrawn or data is no longer required.
Bahrain: Right to block or suspend processing of inaccurate, incomplete, or outdated data; right not to be subjected to automated decision-making.
Oman: Right to be notified of data breaches or changes in data processing; right to request modification of outdated or incomplete data.
Qatar: Right to object to processing where not necessary; right to request omission or erasure of personal data.
Saudi Arabia: Right to request destruction of data; right to limit or restrict processing under certain circumstances; right to be informed if data is shared or sold.

To exercise any of your rights, please contact us at privacy@mywhoosh.com. Please note that before responding to any requests to exercise your rights, we will require you to provide us with proof of identity and your address. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended in certain circumstances with prior notification to the requestor).

You will have control over changing your account particulars, including your height, weight, and other profile information through your profile settings. Similarly, you will also have the choice to unsubscribe from promotional emails by clicking on the “unsubscribe” link in each email. You may, however, still receive non-promotional emails, for instance, of updates available, password changes, etcetera. You may also opt out of push notifications generated by the App by changing your device settings. Please note that even after you remove certain information, we may still retain some of it to fulfill certain legal requirements in accordance with our data retention policy.

INTERPRETATION

This policy is written in English and supersedes any other translated version of the same document or the meaning it may imply.

CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice from time to time. If there are any changes, you will be notified via email, or a notice will be displayed on the MyWhoosh website. The date this Privacy Notice was last updated appears at the top of this document.