privacy policy

Last Updated: 14th June 2021

Thank you for deciding to share your personal data with us!

who we are

This privacy policy is issued on behalf of Recomposer FZE, PO Box 4422, Fujairah Creative Tower, Fujairah, UAE. In this Privacy Policy the terms “Recomposer”, “we,” “us” or “our  refer to Recomposer FZE.
For any questions about this policy, including questions about your rights under data protection law, please contact our Privacy Officer at: legal@recomposer.com.

about this privacy policy

Recomposer respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our system at https://recomposer.app (“App”, “Website” or “System”) and our help site at https://recomposer.com, and tell you about your privacy rights and how the law protects you.
We keep our privacy policy under regular review and we therefore invite you to regularly review this webpage. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

policy terms

  1. The data we collect about you We may collect, use, store and transfer different kinds of personal data about you, meaning any information that can either directly or indirectly identify you, which we have grouped together as follows:
    • Identity Data and Contact Data includes first name, last name, email  address, phone number, password, date of birth, gender and other similar identifiers.
    • Financial and Transactional Data may include bank account and payment card details and details about payments from you and other details of services you have purchased from us and other similar details. Please note we do not store your full payment card details. This information is stored by our trusted third-party payment processor.
    • Technical and Usage Data includes information about how you use our Website and App such as internet protocol (IP) address, your login data, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform, and other similar technology identifiers on the devices you use to access the Website, the App.
    • Profile Data includes your body composition, diet and training data, and all other similar or related data you provide us with.
  1. We also process Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Profile Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
  2. If you fail to provide personal data
    Where we need to collect personal data and you fail to provide that data, the system will be unable to provide you with it’s services.
  3. How is your personal data collected? Direct interactions. You may give us your Identity and Contact and Financial and Transactional Data by filling in forms or by emailing us from the email associated with your user account in the System.
  4. Automated technologies or interactions. As you interact with our App, we will automatically collect Technical and Usage Data about your browsing and your device. We collect this personal data by using cookies, local storage and other technologies, both proprietary and third-party-sourced. By using our App, you agree to the use of these cookies and technologies.
  5. How we use your personal data Your personal data is used to provide the services of the website and may include use by trusted third party suppliers to assist in providing those services, or in helping us to develop our services.
  6. Disclosures of your personal data Our suppliers
    We use a few different suppliers in order to deliver, develop and promote our services. Some of your personal data may be shared with them for the purposes above. We use suppliers to process payments, to store data in the cloud, to insure our services, to run analytics and data analysis, to provide customer support and to do advertising and marketing.
    All our suppliers have signed data processing agreements with us. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes (unless this is necessary for them to provide their services to us, in which case you will be explicitly informed) and only permit them to process your personal data for specified purposes and in accordance with our instructions.
    Corporate transactions
    We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data.
    Professional advisers and law enforcement
    We may disclose your personal information to the court service or regulators or law enforcement agencies in connection with proceedings or investigations where compelled to do so. We may disclose your personal information to our professional advisors that are usually regulated by a competent authority (legal representatives, accountants, etc.) where that proves necessary.
    Cookies Cookies are most often served by third parties and this usually involves disclosure of Technical and Usage data that is often anonymised. Please use our cookies banner to accept or reject non-essential cookies.
  7. Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
  8. Data retention How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
    In some circumstances we will irreversibly anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case this policy would no longer apply and we may use this information indefinitely without further notice to you.
  9. Your legal rights Recomposer is committed to fulfilling the statutory data protection rights of customers. If you send us a request regarding your rights under UAE law, we will respond within one month from the day of receipt and, where possible, address your request within such time. Where necessary, this period may be extended by up to a further two months in complex cases. Please contact us via email to: legal@recomposer.com, to exercise the following rights in respect of the personal information Recomposer processes about you:
    • to be informed
    • to access (such information)
    • to rectify
    • to erasure
    • to restrict processing
    • to object to profiling
    • to data portability
    • to complain to the data protection authority
    • to withdraw consent

We would appreciate the chance to deal with any concerns you may have before you raise them with your local authority so please contact us in the first instance by emailing us at legal@recomposer.com.