Privacy Policy

Effective Date: December 15, 2025

This Privacy Policy (“Policy”) explains how Peloton (“Peloton”, “we”, “us”, or “our”) processes personal data when you use our website pelotontek.com (the “Website”) and any products, tools or services we provide (collectively, the “Services”).

We are committed to handling your personal data responsibly, transparently, and in accordance with applicable European and Polish data-protection laws, including the General Data Protection Regulation (GDPR) and the Polish Act on Personal Data Protection.

By using our Services, you acknowledge that you have read and understood this Policy.

1. Data Controller

The controller responsible for processing your personal data is:

Peloton
Company Number: RZ.XII NS-REJ.KRS/21992/24/699
Registered Address: JANA III SOBIESKIEGO, house no 17 RZESZÓW, post code 35-002, POLAND
Email: [email protected]

Peloton determines the purposes and means of processing your personal data.

2. Data Protection Officer

If you have questions about this Policy or your rights, you may contact our Data Protection Officer (DPO):

Email: [email protected]

3. Categories of Personal Data We Process

We process personal data that you provide directly, data collected automatically when you use our Services, and data obtained from third-party sources where legally permitted.

3.1. Data You Provide to Us

This includes:

  • Full name
  • Contact information (email, phone number, address)
  • Account registration details
  • Documents for identity verification (e.g., passport, ID card)
  • Date of birth
  • Financial or transaction-related information (if required for providing Services)
  • Communications with our support team
  • Any other information voluntarily submitted when using the Services

3.2. Data Collected Automatically

We may automatically collect:

  • IP address, browser type, device information
  • Website usage data and interaction logs
  • Performance and diagnostic data
  • Cookie identifiers and tracking information (see Section 9)

3.3. Data from Third-Party Sources

Where permitted by law, we may obtain data from:

  • Payment service providers
  • Fraud-prevention databases
  • Verification vendors
  • Public registers
  • Analytics providers

4. Legal Basis for Processing

We process your personal data according to the following legal grounds under GDPR:

Contract Performance (Art. 6(1)(b))

To:

  • Provide and operate the Services
  • Manage your account
  • Process transactions and verify identity
  • Deliver support and technical assistance

Legal Obligations (Art. 6(1)(c))

To:

  • Comply with tax, accounting, AML, or KYC requirements
  • Respond to lawful requests from authorities
  • Maintain mandatory records

Legitimate Interests (Art. 6(1)(f))

For purposes such as:

  • Improving and securing our Services
  • Preventing fraud and abuse
  • Internal analytics and service optimization
  • Communicating important product updates

Consent (Art. 6(1)(a))

For:

  • Marketing communications
  • Use of non-essential cookies

You may withdraw consent at any time.

5. How We Use Personal Data

Peloton uses personal data to:

  • Provide and maintain the Services
  • Verify user identity where required
  • Ensure security, detect fraud, prevent misuse
  • Process transactions and send related notifications
  • Improve the Website and user experience
  • Deliver marketing communications (if consented)
  • Generate aggregated, anonymized insights
  • Comply with applicable legal obligations

We do not sell your personal data.

6. Sharing Your Information

We may share personal data with:

6.1. Service Providers

Such as:

  • IT and infrastructure vendors
  • Cloud hosting providers
  • Payment processors
  • KYC/AML or identity-verification partners
  • Customer support software providers

All vendors operate under contractual Data Processing Agreements (DPAs) ensuring GDPR compliance.

6.2. Authorities and Legal Bodies

When required by law, for example:

  • Courts
  • Supervisory authorities
  • Financial investigation units

6.3. Business Transfers

If Peloton is involved in a merger, acquisition, restructuring or sale of assets, personal data may be transferred to the acquiring entity under contractual safeguards.

We never share personal data without a valid legal basis.

7. International Transfers

If personal data is transferred outside the EU/EEA, Peloton uses one or more of the following safeguards:

  • European Commission Adequacy Decisions
  • Standard Contractual Clauses (SCCs)
  • Additional safeguards where required

You may request a copy of the appropriate safeguards by contacting us.

8. Data Security

We apply technical and organizational security measures aligned with GDPR standards, including:

  • Encryption of data in transit and at rest
  • Access control and authentication procedures
  • Regular security audits
  • Secure development practices
  • Monitoring for suspicious activity
  • Employee confidentiality obligations

No transmission method is fully secure, but we continuously work to minimize risks.

9. Cookies and Tracking Technologies

We use cookies to ensure Website functionality, enhance performance, and analyze usage.

You may manage cookie settings in your browser or decline non-essential cookies via our cookie banner.

For details, please see our Cookies Policy.

10. Your Rights Under GDPR

You have the following rights:

  • Right to access — request copies of your data
  • Right to rectification — correct inaccurate data
  • Right to erasure — ask us to delete data in specific circumstances
  • Right to restrict processing
  • Right to object, including to marketing
  • Right to data portability
  • Right to withdraw consent
  • Right to lodge a complaint with a supervisory authority

To exercise your rights, contact us at: [email protected]

We may require identity confirmation for security purposes.

11. Data Retention

Peloton stores personal data only as long as necessary for:

  • Providing the Services
  • Fulfilling legal obligations
  • Resolving disputes
  • Enforcing agreements

Specific retention periods depend on the category of data and legal requirements.

When data is no longer needed, we securely delete or anonymize it.

12. Automated Decision-Making

Peloton may use automated tools for:

  • Fraud detection
  • Risk scoring
  • Security monitoring

You have the right to request human review of decisions that significantly affect you.

13. Updates to This Policy

We may update this Policy from time to time. The “Effective Date” will be revised accordingly.

If changes significantly affect your rights, we will notify you through the Website or via email.

14. Contact & Complaints

For questions or concerns regarding this Policy, please contact:

Peloton
Email: [email protected]
Address: JANA III SOBIESKIEGO, house no 17 RZESZÓW, post code 35-002, POLAND

If you believe your data protection rights have been violated, you may file a complaint with your local EU supervisory authority, such as the Polish President of the Personal Data Protection Office (UODO).

15. Legal Information

Company Name: Peloton
Company Number: RZ.XII NS-REJ.KRS/21992/24/699
Registered Address: JANA III SOBIESKIEGO, house no 17 RZESZÓW, post code 35-002, POLAND
Email: [email protected]

 

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