YOUR PRIVACY AND COVID-19
In an effort to keep our SoulCycle community safe in light of the COVID-19 pandemic, we are collecting additional information from our riders, employees, and other studio visitors. Our transparency is key to maintaining your trust, and during these unprecedented times, we are especially mindful of striking the right balance between ensuring the health and safety of our riders, employees and the public and respecting your privacy. Accordingly, effective as of May 21, 2020, the following privacy notice (the “Privacy Notice”) shall apply in addition to our existing Privacy Policy, set forth below, which will continue to otherwise govern our collection, use and other processing of your information.
As the current circumstances and the needs of our community evolve, this Privacy Notice may be modified or updated in SoulCycle’s sole discretion. If we make any changes to our Privacy Notice, we will post the revised document here and such changes will be effective immediately upon that posting. Please review this Privacy Notice periodically to ensure you are aware of any changes.
What Information We’re Collecting: We may collect certain information about your potential exposure to COVID-19 and health through periodic health declarations we ask you to complete. We may also collect measurements of your body temperature when you are at a studio. We will not record or store your body temperature measurement, but if your body temperature registers higher than our permitted threshold for studio access, we reserve the right to record and indicate in our system that you were denied entrance and are not eligible to return for 3 days. In addition, we may collect information provided by you, or a public health authority or other government agency, if you test positive for COVID-19, including information about how you interacted with SoulCycle during the time in which you may have been infected with COVID-19. All of the foregoing is referred to in this Privacy Notice as “Screening Information”.
What We’re Doing with Screening Information: We collect and use Screening Information to help provide a safe environment for our employees, riders, and other studio visitors and to administer your access to our studios. We will use Screening Information in furtherance of those legitimate interests and business purposes. We will not use your Screening Information for any marketing or promotional purposes.
How We May Share Screening Information: While we generally will not share your Screening Information without your consent, we reserve the right to disclose this information, and other related information, to government and regulatory authorities, such as the Centers for Disease Control and Prevention and state and local health authorities, or as otherwise necessary or appropriate in furtherance of public health or safety. If we are notified that you tested positive for COVID-19 within 14 days after your last visit to SoulCycle, or if we otherwise determine that you may pose a risk to our community, we reserve the right to disclose to our employees, riders, and other studio visitors that an individual who tested positive, or otherwise poses a risk to our community, was in our facilities and while we will not disclose your name unless legally required to do so, we may disclose information such as the date and time of your visit, your gender, and studio areas you used. We share this information to help ensure our studios remain safe for our employees and other riders. We may also share your Screening Information and other related information with service providers, advisors or consultants who are performing services on our behalf and for other reasons in accordance with applicable law, as further described in the “How We Share Your Information” section of our Privacy Policy below. Please note we may disclose aggregated, de-identified information for any other lawful purpose.
How We Retain Screening Information: Your Screening Information will be protected as described in our Privacy Policy below, and will be retained only as long as we determine reasonably necessary to ensure the health and safety for our riders, employees, other studio visitors and in accordance with applicable law. As noted above, your body temperature measurement will not be stored unless required by applicable law, but we will retain your acknowledgements of the health declaration, as well as any records (if any) that you were denied entrance and not permitted to return for 3 days. Any information that we retain will be stored for a reasonable period of time, including as we determine necessary to comply with applicable law or to establish or defend our legal rights.
Your Options: At this time, SoulCycle requires you to provide Screening Information as a condition of entry to its studios. However, if you are uncomfortable with providing any requested Screening Information or do not wish to consent to this Privacy Notice, we will refund your class package purchase. Please contact yoursoulmatters@soul-cycle.com if you have any questions regarding our screening procedures or would like a refund of your purchase.
EFFECTIVE DATE: January 1, 2020
SoulCycle values your privacy. The primary purpose of this Privacy Policy ("Policy") is to describe our collection, use, and disclosure of information we collect about users of our website, www.soul-cycle.com (our "Website"), and our App (collectively for purposes of the Policy the "Services"). Our Website is operated by SoulCycle Inc. which includes SoulAnnex and subsidiaries of SoulCycle Inc. ("SOUL," "we," "us," or "our"). Also, we briefly describe our practices with regard to our offline collection of information. By visiting the Website, using or downloading the App, or visiting a studio that makes this Policy available to you, you agree that your information will be handled as described in this Policy. Your use of our Website and App or interacting with us offline, and any dispute over privacy, is subject to this Policy and to our Terms & Conditions, including its applicable limitations on damages and the resolution of disputes. The SOUL Terms and Conditions are incorporated by reference into this Policy.
Important note about children's privacy: We take children's privacy very seriously. Our Services are not targeted to children, and we will not collect personal information from any users who we know to be under 13 years old, unless we first obtain verifiable parental consent as required by the Children's Online Privacy Protection Act Rule (COPPA). Please review our Children's Privacy Policy for more information, which applies to our collection, use and disclosure of personal information from children we know to be under 13. If you believe that we have collected personal information from a child under 13 without parental consent, you may report this to us at privacy@soul-cycle.com.
The Information We Collect About You
Our Use of Cookies and Other Tracking Mechanisms
Social Media and Technologies Integrations
Links to Other Websites, Platforms, and Services
Security of My Personal Information
Access to My Personal Information
What Choices Do I Have Regarding Promotional Emails?
Additional Disclosures for Nevada Residents
Additional Disclosures for California Residents
We collect information about you directly from you (both online and in store) and from other sources, as well as automatically through your use of our Website, App, or Services.
We collect information from you when you contact us, register with our Website or App, reserve classes, make a purchase, or otherwise interact with our studio staff, Website or our App. The type of information that we collect varies based on your interaction with us and may include: your name, email address, password, and phone number, date of birth, gender, and, if you make a purchase from us, payment information, purchase history, and shipping address. To create an account and participate in one of our classes, we need emergency contact information for our customers. We also may collect information about your workout preferences, such as your bike size and settings, and your shoe size preferences. If you provide this information directly to one of our studio attendants, we may associate this information with your account (e.g., if you sign up for a class while you are in the studio).
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
We also collect information from other sources. The following are the categories of sources we collect information from:
Our customers, who provide the name and phone number of an emergency contact when they create an account with us, and who also may provide us information about their friends, e.g., so that we can invite others to try our classes.
Data brokers or resellers from which we purchase data to supplement the data we collect.
Social Networks when you engage with our content, reference our Services, or grant us permission to access information from the social networks.
Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
Publicly-available sources, including data in the public domain.
Advertising Partners when you engage with our advertisements and take actions on our site.
We automatically collect information about your use of our Website and App through cookies, web beacons, and other technologies, including technologies designed for mobile apps. We combine this information with other information we collect about you as well as use this information to identify you across your multiple devices. Please see the section Our Use of Cookies and Other Tracking Mechanisms below for more information.
Website:
Domain name.
Your browser type and operating system.
Web pages you view; links you click; your IP address.
The length of time you visit our Website and or use our Services.
The referring URL or the webpage that led you to our Website.
App:
Mobile device ID; device name and model; operating system type, name, and version.
Language information.
Activities within the App; and the length of time that you are logged into our App.
Location information. With your permission, we will collect location information from your mobile device to help you locate the nearest SOUL location and to send you push notifications, such as promotional notices when you are near a studio. You may turn off this feature through the location settings on your mobile device.
Calendar. With your permission, we may access your mobile device's calendar to help you keep track of your upcoming classes.
Contact list. With your permission, we may access your contacts to allow you to identify your emergency contact and upload their contact information.
Photos. With your permission, we may access your photos and videos to allow you to save and share content from the app.
Automatically Collected In-Store Information. Our studios are monitored 24 hours a day by closed circuit television. We use this information predominantly for loss prevention and safety purposes. We may share this information as permitted by law to protect our rights and interests, the rights and interests of others, and as otherwise permitted by law.
If you participate in certain classes in identified SoulCycle studios where we have installed connected equipment such as bicycles and wearable devices, we may also collect information about your performance in particular SoulCycle classes, including but not limited to your distance, power/effort, cadence, speed, beat match, and heart rate. If you reserve a bike for one or more other individuals, this kind of information will be shared with you regarding their performance metrics. When you book a bike on behalf of another individual, you represent and warrant that you have the consent of that individual for SoulCycle to share this information with you.
We collect and use information for the following business and commercial purposes described below, and in accordance with the practices described in this Policy:
To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Website and App.
For marketing and promotional purposes. For example, as permitted by applicable law, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about products and services from other entities. We also may use the information that we learn about you to assist us in advertising our services on websites and social networking sites owned and operated by other entities.
To send you push notifications (you may opt-out through the settings in your device).
To better understand how users access and use our Website and App, both on an aggregated and individualized basis.
To evaluate, improve, or modify our Website, App, and Services, including our services offered in our studios.
For research and analytical purposes.
To administer our Spread the Soul and other customer loyalty programs.
To administer surveys and questionnaires.
To comply with applicable legal obligations, including responding to a subpoena or court order.
For other business related purposes, including, for example, in the context of merger, acquisition, sale/purchase of assets, or bankruptcy.
To protect us and others.
To provide you with information, if you request it, regarding your performance in connected SoulCycle classes.
To fulfill any other business or commercial purposes at your direction or with your notice and/or consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
We may share your information as follows:
We disclose the information we collect from you to our affiliates or subsidiaries, including for business purposes such as customer support, marketing, and technical operations. We also share information with affiliates for commercial purposes, including their own direct marketing purposes.
We may disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. For example, we share your information, both on an individual basis or in the aggregate, with our service providers to assist us in advertising our products and services and to assist us in determining relevant advertising. These service providers may include entities that assist us and other companies with communicating with you and serving advertisements to you, including advertisements on websites and social media platforms owned and operated by other entities, as well as through push notifications and email. Please see Social Media and Technologies Integrations for additional information about Website and App advertising.
We also share information in the following circumstances:
We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information.
We may disclose the information we collect from you with our partners, including for their own direct marketing purposes. For example, we disclose information to our partners in connection with offering co-branded services, selling or distributing products or services, or engaging in joint marketing activities or promotions.
If we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or of this Policy, or as evidence in litigation in which SOUL is involved.
We may disclose the information we collect from you with your consent or to facilitate your requests.
We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
We and our service providers use cookies and other tracking mechanisms to automatically collect information about your use of our Website and our App. We may combine this information with other information we collect from you (and our service providers may do so on our behalf).
Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and our App, while others are used to enable a faster log-in process or to allow us to track your activities at our Website or our App.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse certain areas of the Website, but some features may not function.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Website and our App to, among other things, track the activities of our Website visitors and App users, help us manage content, and compile statistics about Website and App usage. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. We also use SDKs to, among other things, track our conversions, associate with your account how you use our Website and our App when you are not logged in to the account, and bring you advertising both on and off our Website and our App.
We use the information that we collect about you (whether directly from you from our Website, App, or in-store purchase activities, through your device(s), or from another source) to help us identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We also use the cross-device tracking and other information we learn about you to serve targeted advertising on your devices, to send you push notifications, and to send you emails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Social Media and Technologies Integrations section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt-out each browser or device that you use.
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Website and, to the extent permitted, our App. We also use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance, and user experiences. These entities use cookies and other tracking technologies to perform their services.
There is no industry do-not-track standard; SOUL has processes in place that are designed to recognize web browser "do-not-track" signals. The Help portion of the toolbar on most browsers will tell you how to use your web browser's do-not-track feature. Please be advised that we cannot guarantee that our processes will capture all such do-not-track signals. You also may disable certain tracking as discussed in this section (e.g., by disabling cookies); you may opt-out of targeted advertising by following the instructions in the Social Media and Technologies Integrations section.
As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies.
We use other entities such as network advertisers and social media networks, including Facebook, to serve advertisements on websites or other media (e.g., social networking platforms) operated or controlled by other entities. This enables us and these other entities to target advertisements to you for products and services in which you might be interested. Other entities such as ad network providers, advertisers, sponsors and/or traffic measurement services use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you to assist us with this advertising.
We also offer content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated by SOUL in accordance with this Policy. Also, if you publicly reference our Services on social media (e.g., by using a hashtag associated with SOUL in a tweet or post), we may use your reference on or in connection with our Services.
Please note that when you interact with other entities, including when you leave our Services, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
Users in the United States may opt out of many ad networks, including those we work with on our Website and App. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.
We use audience matching services to serve advertisements targeted to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases ("Matched Ads"). This is done by us uploading a customer list to a technology service (such as through Facebook Custom Audiences or Google Customer Match) or incorporating a pixel from a technology service on our Services, and the technology service matching common factors between our data and their data. We also work with partners to deliver Matched Ads based on data about you and others in those partners' own databases or match the partner's data against our own customer lists. To opt-out of us using your data for Matched Ads, please contact us as at privacy@soul-cycle.com and specify that you wish to opt-out of Matched Ads. We will request that the applicable technology services not serve you Matched Ads based on information we provide to it. You may also contact the applicable technology service to opt-out. We are not responsible for such technology service’s failure to comply with our or your opt-out instructions.
Our Website and App may contain links to websites platforms, and other services not operated or controlled by us. Any access to and use of such linked websites, platforms, and services is not governed by this Policy, but instead is governed by the privacy policies of those websites, platforms, and services. We are not responsible for the information practices of such websites, platforms, or services.
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite these measures, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website or App for a period of time.
We may send periodic promotional emails to you. You may opt-out of our promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
Upon completion of a SoulCycle challenge, SoulCycle will send one email to challenge participants, including those who have unsubscribed from general marketing messages, with his/her rewards details. Challenge participants can unsubscribe from receiving the rewards notification at any time by emailing privacy@soul-cycle.com.
For information regarding texts and calls, please see the “Texts and Calls” section of our Terms and Conditions.
By participating on a team during any SoulCycle challenges, your teammates may see your name, riding goal and riding progress. Not all members of a team are invited and some individuals may join a team through a random coding process. The creator of a SoulCycle team may remove any teammate from his/her team at any time at his/her sole discretion.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at privacy@soul-cycle.com.
This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at privacy@soul-cycle.com.
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Website and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website and App.
Nevada consumers may submit requests directing a business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at privacy@soul-cycle.com.
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
Although the information we collect is described in greater detail in “The Information We Collection About You” above (Section A), the categories of personal information that we have collected in the past 12 months – as described by the CCPA – are:
Identifiers, including name, email address, and IP address.
Customer records, phone number, billing and shipping address, and credit or debit card information.
Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
Commercial information, including purchases and engagement with the Services.
Biometric information, if you use the identified connected equipment or wearable devices at certain SoulCyle studios, we may collect heart rate information and performance metrics.
Internet activity, including your interactions with our Services.
Audio or visual sensory data, including pictures or videos you post on our Services and closed circuit monitoring of our studios.
Geolocation data, including location enabled services such as WiFi and GPS.
Employment and education data, including information you provide when you apply for a job with us.
Inferences, including information about your interests, preferences and favorites.
For more detail on the information we collect and when, including the sources we receive information from, please review The Information We Collect About You above. In the past 12 months, we have collected and used information from all of the above categories for the business purposes described in the How We Use Your Information section, including to provide and manage our Services.
SOUL does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the Analytics, Social Media and Technologies Integrations, Our Use of Cookies and Other Tracking Mechanisms, and Customer Matching sections as a “sale,” we will comply with applicable law as to such activity.
SOUL discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, behavioral data, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Services. Please review the How We Share Your Information section for more detail about the parties we have shared information with and the purposes underlying those disclosures.
California residents have the right to delete the personal information we have collected from you and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
The categories of personal information we have collected about you;
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business purpose or sold;
The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
The business or commercial purpose for collecting or selling the personal information; and
The specific pieces of personal information we have collected about you.
To exercise any of these rights, please submit a request through our online form available here, call our toll free number at 1-800-887-7540, or make a request at one of our locations. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific account information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
To the extent SOUL sells your personal information as the term "sell" is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out at one of our locations.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and will verify your identity directly.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
We collect and maintain information on riders who are minors under the age of 16. We do not knowingly sell personal information of minors under 16 years old, however, to the extent we knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents, we either obtain prior affirmative authorization from such minor to the opt-in to the sale of the minor’s personal information or obtain affirmative authorization from the minor’s parent or guardian. A minor, or parent/guardian, who has opted in to the sale of the minor’s personal information has the right to opt-out at any time. To exercise your right to opt-out see the Right to Opt-Out section above.
California's "Shine the Light" law permits customers who reside in California to request, once per year, disclosure regarding how we share certain of their information with third parties and affiliates for those third parties' and affiliates' own direct marketing purposes.
We may share personal information as defined by "Shine the Light" with third parties and/or our affiliates for such third parties' and affiliates' own direct marketing purposes. If this law applies to you and you wish to obtain further information about our sharing, you may make one request each year by contacting us at privacy@soul-cycle.com or 609 Greenwich Street, Attn: Legal Department, New York, NY 10014. Requests must state "California Shine the Light Request" in the subject line or first line of the description and also include your name, street address, city, state, and ZIP code. We are not required to respond to requests made by means other than through the provided email or mail addresses.