In addition, this Policy is guided by the following guidelines: 

• Data that is really necessary for the purpose for which it is intended will be collected and its processing will therefore follow the purposes informed by ENHANCE USA TECHNOLOGIES LLC;

• ENHANCE USA TECHNOLOGIES LLC will not sell your data, but may share your personal information or make it available to partner companies or other companies that work directly with ENHANCE USA TECHNOLOGIES LLC, called affiliates, in order to improve your experience as a user of the site, customer, collaborator, or to partners aimed at the same purpose and principles indicated in this Policy.

General Information

Enhance USA Technologies offers a SaaS enterprise solution for gyms looking to manage their personal training business. The software provides a fully integrated ecosystem for trainers, gyms, and clients. Its three interconnected apps - Trainer App, Client App, and Gym Dashboards - seamlessly address every layer of personal training management. The Trainer App simplifies schedules and program design, while the Client App keeps clients engaged with gamified milestones, progress tracking, and nutrition tools. The Gym Dashboards empower gym owners with real-time operational insights to optimize their businesses.

When accessing our website, we automatically receive your computer's IP address to gather information about your browser and operating system.

This Policy is continuously updated to reflect new technologies, business practices, and market needs. For additional information, questions, concerns, or requests regarding the deletion or correction of your data, please contact us via email.

Fundamental Concepts

Below are some fundamental concepts for understanding this Policy and the LGPD, as well as the processing of your personal data:

1. Data subject: The natural person to whom the personal data being processed refers.

2. Data processing: Any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

3. Sensitive data: Personal data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data relating to health or sex life, genetic or biometric data, when linked to a natural person.

4. Personal data: Information relating to an identified or identifiable natural person, such as name, ID, CPF, e-mail and telephone number;

5. The General Data Protection Regulation (GDPR): is a comprehensive privacy and data protection regulation enacted by the European Union, effective since May 25, 2018. It governs how organizations must handle, protect, and responsibly process personal data of EU citizens and residents, providing individuals with greater control and transparency over their own personal information.

6. Operator: Agent who processes personal data on behalf of the Controller, e.g. vendors.

7. Controller: Agent responsible for making decisions about the processing of personal data.

Who does this privacy policy apply to?

It applies to everyone whose data is processed by ENHANCE USA TECHNOLOGIES LLC, including, but not limited to, users of our platform, customers, employees, suppliers and business partners of ENHANCE USA TECHNOLOGIES LLC.

What kind of personal data do we collect and what do we use it for?

​Enhance USA Technologies LLC collects personal data to provide and improve its services, for example through its partners and/or collaborators, promotional actions, online portals and interaction on social networks.  

The collection of personal data from employees and business partners can also occur through direct contact between the data subject and ENHANCE USA TECHNOLOGIES LLC, as well as through public portals and intermediation by specialized companies. Among the information that may be requested are: name, e-mail, address, telephone, CPF, ID, profession, date of birth, marital status, and financial data. 

Personal data may be processed for the following non-exhaustive purposes: 

• Improving service; 

• Responding to requests more efficiently; 

• Personalizing the user experience; 

• Using the feedback you provide to improve our products and services; 

• To run promotions, competitions and surveys; 

• Send you information that you have previously agreed to receive, on topics that we believe may be of interest to you; 

• Carry out contractual obligations; 

• To comply with legal obligations; 

• For other purposes for which we provide specific notice, or as otherwise authorized or required by law.

• To offer services Enhance USA Technologies LLC services.

• For the Legitimate Interests of Enhance USA Technologies LLC

Our website, systems or business model does not currently require or collect or request information from persons under the age of 18. However, due to the anonymity of the internet, it is possible that someone under the age of eighteen may access our website and provide us with personal information. Should this situation occur, whenever it is brought to our attention, we will not use the information in any way without the prior consent of those legally responsible and we will remove it from our systems, taking all reasonable steps to prevent this from happening again.

What legal bases are applied to the processing of your personal data? 

We process your personal information on the basis of a number of different legal bases, most notably: 

1. Consent: We may carry out processing based on your consent. In such cases, you can withdraw your consent at any time, without affecting the lawfulness of the previous processing. Providing your consent is voluntary. Acceptance of the terms of this Privacy Policy and continued use of our website implies Consent to the processing, use and eventual sharing of your information; 

2. Performance of contract: We may process your personal information as necessary to fulfill or perform contractual obligations; 

3. Regular exercise of rights / Compliance: Your data may be used for the execution of litigation, for example in the civil, advisory and labor spheres; 

4. Legitimate Interest: We may process your personal information as necessary to pursue our legitimate interests. In such cases, we will ensure that your interests do not override our legitimate interests;

What are the rights of data subjects?

We follow LGPD, GDPR, and CCPA principles, specifically:

• Lawfulness, fairness, and transparency: Data processing must be transparent, lawful, and fair.

• Purpose limitation: Personal data should be collected for explicit, specified, and legitimate purposes and not processed further in ways incompatible with these purposes.

• Data minimization: Data collection should be adequate, relevant, and limited to what is necessary.

• Accuracy: Personal data must be accurate and kept up to date.

• Storage limitation: Data must be retained only as long as necessary for the processing purposes.

• Integrity and confidentiality: Appropriate security measures must protect data from unauthorized processing and accidental loss.

• Accountability: ENHANCE USA TECHNOLOGIES LLC is responsible for demonstrating compliance with LGPD, GDPR, and CCPA principles.

Rights of Data Subjects under GDPR

Under LGPD, GDPR, and CCPA, you have the following rights:

• Right to access personal data;

• Right to rectification of inaccurate data;

• Right to erasure ("right to be forgotten");

• Right to restrict processing;

• Right to data portability;

• Right to object to data processing;

• Right to restrict processing;

• Rights related to automated decision-making, including profiling;

• Right to withdraw consent at any time.

ENHANCE USA TECHNOLOGIES LLC will have 15 (fifteen) working days to respond to the requests of the owners and the requests will be analyzed.

Sharing Personal Data

We may share your personal data with group companies, collaborators or business partners who assist us in providing services, products and benefits, as well as in the administration of our operations, who will always be advised of the needs relating to the processing of your data, keeping it secure and complying with the law, as well as being subject to external audits, public bodies or official authorities to comply with legal obligations. 

In general, third parties authorized by us will only collect, use and disclose your information to the extent necessary to enable them to perform the services they provide to us. However, we are aware that these third parties, such as gateways and other transaction processors, have their own privacy policies.  

We therefore recommend that you read the respective privacy policies of these third parties so that you can understand how your personal information will be used by them. In particular, remember that certain suppliers may be located or have facilities located in different jurisdictions. Thus, if you wish to proceed with a transaction involving the services of a third-party provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.  

Accordingly, once you stop browsing the ENHANCE USA TECHNOLOGIES LLC website or are redirected to a third-party application or website, you will no longer be governed by this Privacy Policy or our website's Terms of Service. Thus, when you click on links, they may direct you to an address outside of our site. We are not responsible for the privacy practices of other websites and encourage you to read their privacy statements.

Data Retention

Personal data will be retained only for the necessary period to fulfill its intended purposes and comply with legal or contractual obligations.

Cookies Policy

ENHANCE USA TECHNOLOGIES LLC has a specific cookie policy and may collect cookies on its portals. In short, a cookie is a small amount of data sent from a web server to your browser and stored on your computer's hard disk. We use cookies to understand how our websites are used, which helps us to improve your online experience in our environments.  

In most internet browsers, you can delete them from your computer's hard disk, block them or receive a warning before a cookie is stored on your computer. Please refer to your browser's instructions for more information. We use the following types of cookies: 

• Necessary cookies: These are essential cookies that do not require consent. 

• Analysis cookies: These are non-essential cookies controlled by the cookie banner. 

• Chat flow and/or messaging cookies: This is the cookie used for the chat and/or messaging tool. If you are a visitor, this allows you to chat with a representative. 

• Advertising cookies: These are ad pixel cookies. 

• Cookies from third-party systems: these are sometimes created by third-party companies, other than the company whose website you are visiting.  

On our website, you can manage your cookie preferences via our cookie notice available on our homepage.

Disclosure  

We reserve the right to disclose your personal information if we are required to do so by law, pursuant to a court or administrative order, to fulfill a contractual obligation, at the request of data protection authorities or if you violate our Policies.  

Security Measures

In order to protect your personal information, we take reasonable precautions, including physical, governance and compliance, organizational and technological measures, to make sure that it is not inappropriately lost, misappropriated, accessed, disclosed, altered or destroyed. 

If you provide us with your information, it will be to the extent possible encrypted. ENHANCE USA TECHNOLOGIES LLC follows the standard requirements generally applied by the industry and considered best practice in data protection.  

In addition, we apply appropriate data collection, storage and processing practices, and security mechanisms to protect your data from unauthorized access, alteration, disclosure or destruction. 

We guarantee that the protection of your personal data is one of our priorities and that, should any incident occur, we will take all possible measures to minimize possible damage. 

International Data Transfer

ENHANCE USA TECHNOLOGIES LLC may transfer personal data internationally, provided adequate data protection is ensured as required by LGPD, GDPR, and CCPA, through mechanisms such as standard contractual clauses or adequacy decisions from the European Commission.

For the purposes of this clause

a) International Data Transfer: the transmission of personal data to a foreign country or international organization;

b) Standard Contractual Clauses: model contractual clauses.

Authorization for International Data Transfer

ENHANCE USA TECHNOLOGIES LLC may carry out international transfers of personal data on an occasional basis, provided that:

(a) the recipient country or international organization provides an adequate degree of protection for personal data; or

b) The transfer is based on Standard Contractual Clauses; or

c) It is supported by another hypothesis, including specific and detached consent from the data subject, where applicable.

Additional Guarantees and Transparency

ENHANCE USA TECHNOLOGIES LLC undertakes to:

a) Implement technical and organizational measures to guarantee the security and confidentiality of the personal data transferred;

b) Provide clear and precise information to data subjects about the international transfer, including the purpose, recipient countries and applicable protection mechanisms;

c) Maintain a communication channel to respond to requests from data subjects regarding data transfers.

Responsibilities of Data Recipients

Recipients abroad must adhere to the Standard Contractual Clauses and undertake to protect the personal data transferred, ensuring that processing is carried out exclusively for the purposes authorized by ENHANCE USA TECHNOLOGIES LLC.

Monitoring and Auditing

ENHANCE USA TECHNOLOGIES LLC will carry out periodic audits to ensure that international transfers comply with applicable regulations, and may adopt additional risk mitigation measures if necessary.

In the event of non-compliance with the obligations set out in this clause, ENHANCE USA TECHNOLOGIES LLC may suspend or interrupt the transfer of data, in addition to applying the applicable sanctions set out in the legislation and contracts entered into.

Contact

For questions regarding this Privacy Policy or personal data treatment requests, please contact our Data Protection Officer (DPO), by email (privacy@enhancetech.io): MPuppe & Associados, represented by Matheus Puppe.

Backup contacts: Amanda Tornovsky, Ludmila Filizola, Ingrid Zouain.

Policy Updates

We reserve the right to modify this Policy at any time to better serve our users, customers, and partners. Updates will be communicated as necessary, and users are encouraged to periodically review this Policy.

In case of company acquisition, investment, or merger, your information may be transferred to new owners or stakeholders.

Security of Information

We adopt comprehensive security practices, consistently applying industry standards and best practices to ensure personal data protection.