Privacy

Policy

EN

last

update

:

June

9, 2026

Respecting

your

privacy

is

of

paramount

importance

to

us

.

At

United

Heroes

,

we

apply

several

fundamental

principles

:

We

do

not

ask

you

for

personal

information

unless

we

really

need

it

.

We

do

not

sell

your

personal

information

to

third

parties

for

commercial

purposes

.

We

treat

your

personal

information

with

the

utmost

respect

for

security

and

privacy

.

These

principles

are

described

in

more

detail

in

this

policy

.

Capitalized

terms

in

this

Privacy

Policy

(

hereinafter

the

"

Policy

")

refer

to

terms

as

defined

in

the

United

Heroes

Terms

of

Use

(

hereinafter

the

"

TOU

").



What

is

United

Heroes

and

how

does

it

work

?

United

Heroes

is

a

digital

services

platform

that

enables

its

Users

to

develop

their

sporting

activities

.

The

Platform

is

accessible

to

anyone

who

has

created

a

User

Account

in

accordance

with

the

Terms

of

Use

.

Through

their

User

Account

,

Users

can

access

the

Platform

from

:

United

Heroes

websites

and

United

Heroes

Applications

,

for

Services

developed

by

United

Heroes

on

its

own

behalf

:

United

Heroes

:

Service

that

Users

can

use

when

they

are

Employees

of

a

Subscribing

Company

by

logging

into

their

User

Account

;

VRace

:

Service

provided

by

United

Heroes

at

the

request

of

a

partner

company

that

the

User

can

use

spontaneously

or

after

being

invited

by

a

partner

company

,

by

logging

into

their

User

Account

.

Sites

and

applications

developed

,

operated

,

and

managed

by

a

white

-

label

partner

company

integrating

the

United

Heroes

platform

(

or

"

partner

platform

"):

Virtual

Club

:

Service

that

a

User

can

use

by

logging

into

their

User

Account

spontaneously

or

after

being

invited

to

do

so

by

a

partner

company

.

Privacy Policy EN

1

United

Heroes

guarantees

the

continuity

of

this

Policy

on

all

means

of

access

to

the

Platform

that

we

offer

,

both

for

United

Heroes

Sites

and

for

United

Heroes

Applications

,

and

when

the

Platform

is

integrated

into

a

Partner

Company

'

s

Application

or

Site

.

Roles

and

Responsibilities

(

Data

Controller

and

Data

Processor

)

When

using

the

Platform

,

two

situations

should

be

distinguished

:

United

Heroes

as

Data

Controller

:

United

Heroes

acts

as

Data

Controller

with

regard

to

the

creation

and

management

of

your

User

Account

,

the

provision

of

basic

Services

(

activity

tracking

,

access

to

social

features

),

and

the

security

of

your

data

.

As

registration

is

a

voluntary

process

on

the

part

of

the

User

(

even

when

by

invitation

),

United

Heroes

determines

the

means

and

purposes

of

this

processing

.

United

Heroes

as

a

Processor

:

For

certain

specific

features

activated

by

the

Subscribing

Company

(

such

as

specific

reporting

,

management

of

internal

communication

campaigns

,

or

custom

settings

),

United

Heroes

acts

on

the

instructions

and

on

behalf

of

the

Subscribing

Company

,

which

is

then

the

Data

Controller

.

United

Heroes

undertakes

to

process

this

data

in

accordance

with

the

customer

'

s

documented

instructions

.

United

Heroes

'

contact

details

are

as

follows

:

United

Heroes

8

Rue

de

Sofia

, 75018

Paris

France

help

@

united

-

heroes

.

com

United

Heroes

is

committed

to

respecting

your

right

to

privacy

and

the

security

of

the

Personal

Data

you

provide

via

the

United

Heroes

Websites

and

Applications

or

the

Application

and

Website

of

a

Partner

Company

that

is

part

of

the

Platform

.

This

Policy

sets

out

the

guidelines

established

by

United

Heroes

to

protect

the

Personal

Data

you

provide

when

visiting

the

Platform

.

Privacy Policy EN

2

In

the

context

of

providing

the

Services

,

United

Heroes

collects

personal

data

,

within

the

meaning

of

Article

4.1

of

the

GDPR

,

concerning

Visitors

and

Users

(

hereinafter

"

Personal

Data

"

)

under

the

conditions

detailed

below

.

In

particular

,

United

Heroes

may

collect

the

following

personal

data

:

Concerning

Visitors

:

Data Goals Justifications

/

Legal

Basis

Browsing

data

Audience

and

traffic

measurement

Free

,

informed

,

unequivocal

,

and

retractable

consent

of

the

User

Personal

data

provided

voluntarily

in

the

contact

form

Contact

United

Heroes

to

respond

to

the

visitor

'

s

request

and

follow

up

on

it

.

Provision

of

services

and

responses

to

visitors

Regarding

Users

:

Data Goals Justifications

/

Legal

Basis

Identification

data

Creation

of

the

account

and

management

of

United

Heroes

'

relationship

with

Users

Need

to

provide

the

User

with

services

the

use

of

their

account

Data

provided

voluntarily

and

optionally

by

the

User

on

their

User

account

or

in

one

of

the

application

'

s

discussion

threads

.

Personalization

of

services

and

rewards

Fulfillment

of

United

Heroes

'

legitimate

interests

in

adapting

and

measuring

the

conditions

of

use

of

its

services

Data

relating

to

sporting

activities

provided

by

the

User

or

generated

on

the

platform

Taking

into

account

activities

and

calculating

points

Need

to

provide

the

User

with

services

the

use

of

their

account

Data

collected

via

third

-

party

applications

if

the

User

chooses

to

connect

them

to

the

platform

Recording

of

activities

and

calculation

of

points

Free

,

informed

,

unambiguous

,

and

retractable

consent

of

the

User

Identification

data

and

statistical

data

on

the

Activity

report

on

the

use

of

services

,

when

requested

by

the

Legitimate

interest

for

United

Heroes

and

the

need

to

perform

its

contract

with

Privacy Policy EN

3

sporting

activity

of

employees

or

Users

Subscribing

Company

or

partner

company

.

the

Subscribing

Company

or

partner

company

Account

Management

and

Deletion

In

order

to

ensure

sound

data

management

(

principle

of

minimization

),

the

Sport

Heroes

account

lifecycle

is

linked

to

the

User

'

s

activity

on

experiences

:

Multi

-

experience

User

:

If

a

User

is

registered

for

several

experiences

,

the

deletion

or

termination

of

one

of

them

does

not

result

in

the

deletion

of

their

Sport

Heroes

account

,

which

remains

active

for

access

to

other

experiences

.

Single

-

experience

user

:

If

a

User

is

only

linked

to

a

single

experience

,

the

deletion

or

termination

of

that

experience

will

result

in

the

automatic

and

simultaneous

deletion

of

their

Sport

Heroes

account

,

thus

avoiding

the

retention

of

inactive

accounts

("

ghost

accounts

").

Invitation

The

United

Heroes

service

allows

subscribing

companies

to

invite

employees

to

join

the

applications

.

If

an

Employee

is

invited

in

this

way

,

United

Heroes

will

retain

the

email

address

of

the

invited

Employee

and

the

message

sent

to

them

in

order

to

track

their

registration

(

and

,

where

applicable

,

to

enable

a

reply

message

to

be

sent

).

The

legal

basis

for

this

is

the

fulfillment

of

United

Heroes

'

legitimate

interests

and

the

need

to

perform

its

contract

with

the

Subscribing

Company

.

United

Heroes

will

inform

the

invitee

who

invited

them

and

allow

them

to

request

that

their

information

be

deleted

from

our

systems

by

submitting

a

request

to

help

@

united

-

heroes

.

com

.

Health

data

None

of

the

Personal

Data

collected

by

United

Heroes

,

nor

that

resulting

from

its

processing

,

constitutes

health

data

as

defined

by

the

GDPR

.

Anonymous

data

United

Heroes

may

use

this

data

by

aggregating

it

in

such

a

way

that

the

individuals

concerned

can

no

longer

be

identified

,

for

statistical

purposes

and

to

improve

the

quality

of

its

Services

.

Geolocation

data

Privacy Policy EN

4

United

Heroes

does

not

use

your

GPS

tracks

or

your

precise

location

to

provide

the

Service

.

However

,

certain

third

-

party

connectors

(

smartwatches

,

third

-

party

applications

)

send

us

these

GPS

coordinates



GPX

/

TCX

files

)

by

default

via

their

APIs

when

synchronizing

activity

.

This

transmission

constitutes

incidental

technical

collection

.

United

Heroes

does

not

use

this

location

data

:

we

only

extract

the

metadata

necessary

for

the

Service

(

distance

,

duration

,

etc

.)

and

immediately

delete

the

raw

GPS

coordinates

from

our

active

servers

.

This

data

is

not

stored

,

displayed

,

or

shared

with

the

Subscribing

Company

.

Activity

details

and

timing

Detailed

activity

data

,

including

precise

timestamps

(

start

time

,

end

time

,

detailed

chronology

of

the

effort

),

are

strictly

linked

to

your

personal

User

Account

.

It

is

processed

to

enable

you

to

track

your

history

and

personal

progress

.

These

time

details

are

not

part

of

the

employee

experience

provided

to

the

Subscribing

Company

.

Therefore

,

in

accordance

with

the

principle

of

data

minimization



GDPR

,

this

granular

time

information

is

never

communicated

to

the

Subscribing

Company

,

which

only

has

access

to

aggregated

or

summarized

data

(

e

.

g

.,

total

number

of

hours

per

month

),

unless

explicit

consent

is

given

in

the

context

of

a

specific

Challenge

(

see

dedicated

section

).

Interaction

between

Users

and

social

features

On

United

Heroes

applications

,

Users

can

interact

with

Users

of

the

same

solution

.

Special

case

of

United

Heroes

:

Users

can

only

interact

with

members

of

the

same

company

.

United

Heroes

applications

are

separate

from

each

other

.

Due

to

its

objectives

of

inclusion

and

cohesion

,

United

Heroes

integrates

social

features

into

its

applications

(

sending

messages

,

photos

,

reacting

to

and

sharing

activities

).

Discussion

forums

and

moderation

Discussion

forums

(

chat

,

comments

,

news

feed

)

are

moderated

social

spaces

.

United

Heroes

and

the

Subscribing

Company

reserve

the

right

to

remove

any

content

that

does

not

comply

with

Privacy Policy EN

5

the

Terms

of

Use

(

hate

speech

,

illegal

content

,

harassment

)

and

the

Subscribing

Company

'

s

internal

practices

.

Voluntary

disclosure

of

sensitive

data

or

health

data

United

Heroes

does

not

request

or

process

sensitive

data

(

political

or

religious

opinions

,

detailed

health

data

,

etc

.)

on

the

Platform

.

If

you

choose

to

disclose

such

information

(

for

example

,

by

discussing

your

recovery

or

state

of

health

),

you

acknowledge

that

this

data

is

clearly

made

public

by

you

voluntarily

within

the

meaning

of

Article

9.2.

e

of

the

GDPR

.

We

recommend

that

you

exercise

the

utmost

caution

when

sharing

private

information

.

Sharing

multimedia

content

and

external

links

By

sharing

photos

,

videos

,

or

links

on

the

Platform

,

you

guarantee

that

you

have

the

necessary

intellectual

property

rights

(

copyright

,

image

rights

of

visible

persons

).

It

is

strictly

prohibited

to

share

hyperlinks

to

sites

whose

content

is

illegal

,

malicious

(

phishing

,

viruses

)

or

contrary

to

the

rules

of

the

United

Heroes

community

or

the

Subscribing

Company

.

Any

content

identified

as

such

will

be

immediately

deleted

and

may

result

in

the

suspension

of

the

User

Account

.

United

Heroes

accepts

no

responsibility

for

the

content

of

third

-

party

sites

shared

by

Users

.

Message

translation

using

Artificial

Intelligence

(

AI

)

United

Heroes

provides

Users

with

a

feature

for

automatically

translating

messages

exchanged

in

the

discussion

spaces

(

chat

),

based

on

Artificial

Intelligence

technology

.

Operation

and

strictly

optional

nature

:

This

feature

is

never

triggered

automatically

.

It

is

only

activated

when

the

User

explicitly

chooses

to

translate

a

specific

message

into

the

destination

language

corresponding

to

their

device

settings

.

Only

the

message

thus

selected

by

the

User

is

processed

by

the

AI

and

then

displayed

in

the

destination

language

.

In

the

absence

of

a

translation

request

from

the

User

,

no

message

is

transmitted

to

the

AI

system

.

Data

processed

:

The

only

content

transmitted

to

the

AI

system

is

the

text

of

the

message

that

the

User

has

requested

to

be

translated

.

No

data

is

processed

for

Privacy Policy EN

6

purposes

other

than

providing

the

requested

translation

.

Processor

:

The

translation

processing

is

carried

out

by

OpenAI

,

acting

as

a

processor

for

United

Heroes

within

the

meaning

of

Article

28

of

the

GDPR

.

OpenAI

processes

this

data

solely

on

United

Heroes

'

documented

instructions

and

for

the

sole

purpose

of

translating

messages

.

The

transmitted

content

is

not

used

by

the

processor

to

train

its

models

.

Legal

basis

:

The

processing

is

based

on

the

User

'

s

consent



Article

6.1.

a

of

the

GDPR

,

materialized

by

their

explicit

request

to

translate

a

message

.

The

User

remains

free

not

to

use

this

feature

,

in

which

case

no

message

is

transmitted

to

the

AI

.

Transfer

outside

the

European

Union

and

server

location

:

As

translation

requests

are

made

via

OpenAI

'

s

standard

API

,

the

data

(

the

text

of

the

messages

to

be

translated

)

is

transferred

to

and

processed

on

OpenAI

'

s

servers

located

in

the

United

States

.

This

transfer

is

strictly

governed

and

secured

:

Transfer

mechanism

:

It

is

based

on

the

European

Commission

'

s

adequacy

decision

regarding

the

EU



US

Data

Privacy

Framework



DPF

,

a

mechanism

to

which

OpenAI

is

certified

.

As

an

additional

safeguard

,

the

transfer

is

also

covered

by

the

European

Commission

'

s

Standard

Contractual

Clauses



SCC

 

Module

2

Controller

to

Processor

)

incorporated

into

OpenAI

'

s

Data

Processing

Addendum



DPA

.

Data

retention

:

In

accordance

with

OpenAI

'

s

strict

policy

for

its

API

services

,

the

transmitted

text

is

in

no

way

used

to

train

its

Artificial

Intelligence

models

.

It

is

securely

retained

on

the

US

servers

for

a

maximum

period

of

30

days

,

exclusively

for

security

and

abuse

detection

purposes

,

before

being

permanently

deleted

.

Default

User

Account

Status

In

its

initial

state

,

a

User

'

s

account

is

configured

as

"

public

."

This

allows

the

User

of

a

United

Heroes

experience

to

display

certain

elements

of

their

account

to

other

Users

of

the

same

experience

,

namely

:

Name

Clubs

Summary

of

activities

carried

out

during

the

month

and

year

(

without

time

details

)

Privacy Policy EN

7

Teams

Badges

Accounts

can

be

set

to

private

at

any

time

by

the

User

,

in

which

case

only

the

name

is

displayed

.

Ranking

information

always

displays

the

name

and

is

visible

to

all

Users

of

the

experience

.

List

of

data

provided

by

third

-

party

sports

applications

:

The

United

Heroes

Applications

allow

Users

who

wish

to

do

so

to

connect

one

or

more

third

-

party

sports

applications

to

the

Platform

in

order

to

automatically

retrieve

the

data

listed

below

and

integrate

them

into

the

experiences

and

challenges

offered

by

United

Heroes

.

Connector

Data

collected

and

processed

by

United

Heroes

Apple

Health

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

Coros

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

•

GPS

coordinates

Google

Fit

•

Date

of

activity

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

Privacy Policy EN

8

•

Number

of

daily

steps

(

excluding

activity

)

Garmin

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

•

Activity

entered

manually

or

not

Polar

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

•

GPS

coordinates

Suunto

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

•

Activity

entered

manually

or

not

TomTom

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

Runkeeper

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

Privacy Policy EN

9

•

Type

of

activity

•

GPS

coordinates

Nike

+

•

Date

of

activity

•

Distance

•

Duration

of

activity

•

Type

of

activity

Decathlon

Coach

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

Fitbit

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

Health

Mate

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

•

Number

of

daily

steps

(

excluding

activity

)

Adidas

Running



Runtastic

)

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Type

of

activity

Underarmour

apps



Map

My

Run

,

Map

My

Ride

,

Map

My

Walk

,

Map

my

Fitness

)

•

Date

of

activity

•

Time

zone

•

Distance

•

Duration

of

activity

•

Number

of

steps

•

Type

of

activity

Rouvy

•

Date

of

activity

•

Distance

Privacy Policy EN

10

•

Duration

of

activity

•

Type

of

activity

•

GPS

coordinates

FulGaz

•

Date

of

activity

•

Distance

•

Duration

of

activity

•

Type

of

activity

•

GPS

coordinates

Wahoo

•

Date

of

activity

•

Distance

•

Duration

of

activity

•

Type

of

activity

•

GPS

coordinates

Social

Ride

•

Date

of

activity

•

Distance

•

Duration

of

activity

•

GPS

coordinates

Samsung

Health

•

Date

of

activity

•

Distance

•

Duration

of

activity

•

Type

of

activity

•

GPS

coordinates

•

Number

of

daily

steps

(

excluding

activity

)

Kinomap

•

Date

of

activity

•

Distance

•

Duration

of

activity

•

Type

of

activity

The

connection

to

a

third

-

party

application

is

made

by

the

User

and

can

be

disabled

at

any

time

by

the

User

.

The

data

listed

above

is

processed

by

United

Heroes

for

the

sole

purpose

of

providing

the

Services

.

Any

processing

of

data

by

third

-

party

applications

for

their

own

purposes

is

subject

to

the

terms

of

use

and

privacy

policies

of

each

third

-

party

service

,

which

the

User

is

invited

to

read

.

Activity

data

(

such

as

steps

,

distances

,

or

sports

activities

)

collected

via

the

Solution

is

directly

and

technically

linked

to

the

End

User

'

s

unique

Sport

Heroes

account

,

and

not

exclusively

to

the

Experience

or

white

label

.

As

a

result

,

the

User

retains

full

control

and

availability

of

their

activity

history

.

Privacy Policy EN

11

This

model

ensures

that

activity

data

remains

linked

to

the

User

regardless

of

the

Experiences

in

which

they

participate

,

thus

ensuring

the

portability

of

their

data

even

if

a

specific

Experience

is

closed

.

2.3

Use

of

data

by

Sport

Heroes

We

use

your

personal

data

in

the

following

cases

and

those

defined

in

the

terms

of

use

for

the

following

purposes

:

Operation

of

the

service

:

Providing

and

improving

the

service

Providing

you

with

information

about

our

services

;

Establishing

and

maintaining

your

User

profile

on

the

service

;

Communicate

with

you

about

the

service

,

including

sending

you

announcements

,

updates

,

security

alerts

,

or

other

support

information

;

Communicate

with

you

about

events

and

contests

in

which

you

have

participated

;

Better

understand

your

needs

and

interests

and

thus

personalize

your

experience

on

the

service

and

in

our

communications

with

you

;

Provide

you

with

support

and

maintain

the

service

;

Respond

to

your

questions

,

requests

,

or

feedback

.

Research

and

development

:

We

analyze

the

use

of

the

service

in

order

to

improve

it

and

provide

new

and

products

,

including

by

analyzing

the

demographics

of

our

Users

and

their

usage

habits

.

This

analysis

is

performed

on

anonymous

data

.

Legal

compliance

:

The

data

processed

may

be

transmitted

to

the

competent

authorities

,

at

their

request

,

in

the

context

of

legal

proceedings

,

in

the

context

of

judicial

investigations

and

requests

for

information

from

the

authorities

,

or

in

order

to

comply

with

other

legal

obligations

.

Finally

,

it

may

be

transmitted

to

third

parties

authorized

by

a

court

decision

.

Security

and

fraud

prevention

:

We

monitor

interactions

with

United

Heroes

services

in

order

to

prevent

abuse

and

limit

security

risks

to

United

Heroes

services

or

Users

.

The

data

processed

may

also

be

used

to

build

a

case

file

for

fraud

investigations

.

These

security

and

fraud

aspects

relate

to

the

risks

of

cyber

attacks

or

abuse

.

Privacy Policy EN

12

United

Heroes

Applications

allow

Users

who

wish

to

do

so

to

connect

one

or

more

third

-

party

sports

applications

to

the

Platform

in

order

to

automatically

retrieve

the

data

listed

below

and

integrate

it

into

the

experiences

and

challenges

offered

by

United

Heroes

.

Special

case

of

third

-

party

connection

connectors

You

can

link

your

third

-

party

account

to

a

United

Heroes

service

.

By

linking

these

services

,

you

authorize

us

to

collect

,

store

,

and

use

the

information

they

may

provide

us

(

e

.

g

.,

your

email

address

).

By

registering

or

logging

in

,

Users

allow

United

Heroes

to

identify

them

and

give

them

access

to

dedicated

services

.

As

described

below

,

third

parties

may

provide

registration

and

authentication

services

.

In

this

case

,

United

Heroes

may

access

certain

data

stored

by

these

third

-

party

services

for

registration

or

identification

purposes

.

Some

of

the

services

listed

below

may

also

collect

personal

data

for

targeting

and

profiling

purposes

(

independent

data

controllers

);

for

more

information

,

please

refer

to

the

description

of

each

service

.

Google

OAuth

Google

OAuth

is

a

registration

and

authentication

service

provided

by

Google

and

is

connected

to

the

Google

network

.

Personal

data

processed

:

different

types

of

data

as

specified

in

the

privacy

policy

of

the

service

.

Place

of

processing

:

Ireland

-

Privacy

policy

(

https

://

policies

.

google

.

com

/

privacy

).

The

use

by

United

Heroes

and

the

transfer

to

any

other

application

of

information

received

from

Google

APIs

complies

with

the

rules

relating

to

the

processing

of

user

data

of

the

Google

API

services

,

including

limited

use

requirements

.

Login

with

Facebook

Connect

is

a

service

provided

by

categories

of

cookies

or

trackers

are

implemented

within

the

United

Heroes

Sites

and

Applications

for

the

purposes

described

below

.

For

completeness

,

we

inform

you

,

as

far

as

possible

,

of

the

purpose

of

cookies

or

tracers

placed

or

read

by

third

parties

and

of

the

means

available

to

the

User

or

Visitor

to

make

choices

with

regard

to

these

cookies

.

or

tracers

.

Cookies

strictly

necessary

for

the

operation

of

the

Sites

These

are

cookies

essential

for

browsing

the

United

Heroes

Sites

and

Applications

which

allow

the

User

or

Visitor

to

use

the

main

functionalities

of

the

United

Heroes

Sites

and

Applications

and

to

secure

their

connection

.

More

precisely

,

these

cookies

allow

in

particular

:

Privacy Policy EN

16

to

adapt

the

presentation

of

the

United

Heroes

Sites

and

Applications

to

the

display

preferences

of

the

Terminal

(

language

used

,

display

resolution

,

operating

system

used

,

etc

.)

when

using

the

United

Heroes

Sites

and

Applications

,

according

to

the

hardware

and

software

for

viewing

or

reading

that

the

Terminal

includes

;

to

allow

access

to

the

User

Account

on

the

United

Heroes

Sites

and

Applications

;

to

memorize

information

relating

to

the

forms

that

the

User

or

Visitor

has

completed

when

using

the

United

Heroes

Sites

and

Applications

;

to

memorize

the

usage

preferences

,

display

parameters

and

players

that

the

User

or

Visitor

uses

in

order

to

facilitate

their

navigation

during

their

to

the

United

Heroes

Sites

and

Applications

.

Without

these

cookies

the

User

or

Visitor

would

not

be

able

to

normally

use

the

United

Heroes

Sites

and

Applications

.

Consequently

,

their

deposit

or

reading

on

the

Terminal

is

not

a

matter

of

choices

offered

to

the

User

or

Visitor

.

The

main

cookies

(

as

defined

in

Article

5.1)

strictly

necessary

for

the

provision

of

services

and

the

operation

of

the

United

Heroes

Sites

are

as

follows

:

Cookie

issuer Purpose

Concerned

person

Duration

Algolia

Search

functions

in

the

application

Visitor

and

User

12

months

Stripe Bank

fraud

detection Visitor

and

User

12

months

United

Heroes User

ID User

12

months

United

Heroes Experience

ID Visitor

and

User

12

months

United

Heroes User

authentication

token User

12

months

United

Heroes Language

used

for

translation Visitor

and

User

12

months

United

Heroes

Definition

of

the

technical

environment

Visitor

and

User

12

months

Audience

measurement

cookies

strictly

necessary

for

the

proper

functioning

of

the

Sites

The

management

of

United

Heroes

Sites

and

Applications

requires

the

use

of

attendance

and

/

or

performance

statistics

,

without

the

identity

of

the

Visitor

or

User

being

known

to

United

Heroes

.

These

measures

are

essential

to

analyze

Privacy Policy EN

17

the

functioning

of

the

United

Heroes

Sites

and

Applications

,

and

for

the

provision

of

the

United

Heroes

Services

.

Consequently

,

United

Heroes

places

and

/

or

reads

cookies

or

trackers

in

the

Terminal

whose

purpose

is

limited

to

measuring

the

audience

of

the

Sites

,

to

meet

different

needs

:

performance

measurement

,

detection

of

navigation

problems

,

optimization

of

technical

performance

or

ergonomics

,

estimation

of

the

power

of

the

necessary

servers

,

analysis

of

content

consulted

,

etc

.

These

cookies

or

trackers

being

strictly

necessary

for

the

functioning

and

day

-

to

-

day

administration

operations

of

the

United

Heroes

Sites

and

Applications

,

they

are

not

subject

,

in

application

of

article

82

of

the

“

Informatique

et

Libertés

”

law

,

to

the

prior

consent

of

the

'

User

or

Visitor

.

However

,

their

purpose

is

strictly

limited

to

the

sole

statistical

and

aggregate

measurement

of

the

audience

of

the

United

Heroes

Sites

and

Applications

,

for

the

exclusive

account

of

United

Heroes

.

These

cookies

do

not

allow

the

overall

tracking

of

the

navigation

of

the

User

or

Visitor

,

in

particular

when

he

uses

other

mobile

applications

or

browses

different

websites

outside

of

the

United

Heroes

Services

.

Likewise

,

these

cookies

are

only

used

to

produce

anonymous

statistical

results

,

and

the

data

collected

is

not

cross

-

checked

with

other

processing

operations

or

transmitted

to

third

parties

.

The

audience

measurement

cookies

strictly

necessary

for

the

proper

functioning

of

the

United

Heroes

Sites

and

Applications

are

as

follows

:

Cookie

issuer Purpose

Concerned

person

Duration

Sentry Crash

report Visitor

and

User

24

months

Mixpanel

Product

improvement

and

statistics

Visitor

and

user

12

months

Braze

Newsletters

/

application

push

notification

User

12

months

Privacy Policy EN

18

Analytical

and

performance

cookies

Analytical

and

performance

cookies

allow

us

to

:

know

the

use

and

performance

of

the

United

Heroes

Sites

and

Applications

;

to

establish

statistics

,

measurements

of

attendance

and

use

of

various

elements

making

up

the

United

Heroes

Sites

and

Applications

(

content

visited

,

routes

,

etc

.)

for

the

purposes

of

improving

the

interest

and

ergonomics

of

our

Services

(

the

pages

or

the

most

frequently

consulted

sections

,

the

most

read

articles

,

etc

.);

count

visitors

to

a

page

;

improve

the

interest

and

ergonomics

of

our

Services

(

the

pages

or

sections

most

often

consulted

,

the

most

read

articles

,

highlighting

a

challenge

,

etc

.);

prevent

computer

fraud

.

The

fact

of

refusing

or

not

accepting

the

implementation

of

such

cookies

or

deleting

them

has

no

impact

on

the

navigation

of

the

User

or

Visitor

on

the

United

Heroes

Sites

and

Applications

,

but

it

is

of

a

nature

to

prevent

United

Heroes

from

ensuring

the

best

quality

of

Services

that

it

wishes

to

offer

to

its

Visitors

and

Users

.

The

main

analytical

and

performance

cookies

used

are

as

follows

:

Issuer

you

cookie Purpose

Concerned

person

Duration

Plausible Count

visitors Visitor

and

User

30

days

Google

Tag

Manager

Tracking

aggregator Visitor

and

User

30

days

Adjust

Campaign

/

course

monitoring

Visitor

and

User

7

days

Hubspot Audience

measurement Visitor

and

User

7

days

Sharing

cookies

(

social

networks

)

United

Heroes

may

include

on

its

United

Heroes

Sites

and

Applications

,

computer

applications

from

third

parties

,

which

allow

the

User

or

Visitor

to

share

content

from

said

United

Heroes

Sites

and

Applications

with

other

people

or

to

make

known

to

the

latter

its

consultation

or

its

opinion

concerning

the

content

of

the

United

Heroes

Sites

and

Applications

.

Privacy Policy EN

19

Some

of

our

Sites

may

therefore

contain

sharing

links

to

Facebook

,

Twitter

and

other

similar

social

networks

,

which

allow

the

User

or

Visitor

to

share

content

from

United

Heroes

Sites

and

Applications

with

other

people

.

When

the

User

or

Visitor

uses

these

sharing

buttons

,

a

third

-

party

cookie

from

the

social

network

concerned

is

installed

,

but

only

if

the

User

or

Visitor

uses

these

buttons

,

or

if

the

User

or

Visitor

has

previously

consented

on

a

Site

or

United

Heroes

Application

to

the

installation

of

cookies

by

these

social

networks

.

If

the

User

or

Visitor

is

connected

to

the

social

network

when

browsing

the

United

Heroes

Sites

and

Applications

,

the

sharing

buttons

allow

the

content

consulted

on

our

United

Heroes

Site

or

Application

to

be

linked

to

the

user

account

of

the

social

network

concerned

. .

If

the

User

or

Visitor

has

refused

the

implementation

of

social

network

cookies

or

if

they

have

not

previously

consented

,

the

User

or

Visitor

must

authenticate

with

their

social

network

account

during

each

operation

.

sharing

that

he

wishes

to

make

to

the

network

(

s

)

concerned

.

The

social

network

providing

such

an

application

button

is

likely

to

identify

the

User

or

Visitor

thanks

to

this

button

linked

to

the

User

'

s

or

Visitor

'

s

account

on

this

social

network

,

even

if

the

User

or

Visitor

has

not

used

this

button

when

consulting

one

of

our

United

Heroes

Sites

or

Applications

.

Indeed

,

this

type

of

application

button

can

allow

the

social

network

concerned

to

follow

the

navigation

of

the

User

or

Visitor

on

the

United

Heroes

Sites

and

Applications

,

simply

because

the

social

network

account

concerned

was

activated

on

the

Terminal

(

open

session

)

during

the

User

'

s

or

Visitor

'

s

navigation

on

said

United

Heroes

Sites

and

Applications

.

United

Heroes

invites

its

Users

and

Visitors

to

consult

the

privacy

protection

policies

of

these

social

networks

in

order

to

be

aware

of

the

purposes

of

use

,

in

particular

advertising

,

of

the

navigation

information

that

they

can

collect

thanks

to

these

sharing

buttons

with

these

networks

.

These

data

protection

policies

must

in

particular

allow

the

User

or

Visitor

to

exercise

the

choices

offered

to

them

by

these

social

networks

,

in

particular

by

configuring

the

usage

accounts

of

each

of

these

networks

.

The

refusal

,

absence

or

withdrawal

of

consent

from

the

User

or

Visitor

with

regard

to

these

social

network

cookies

has

no

impact

on

the

use

of

the

United

Heroes

Sites

and

Applications

.

The

main

social

media

cookies

used

are

as

follows

:

Cookie

issuer Purpose Concerned

person Duration

Privacy Policy EN

20

Facebook

Connect SSO

connection Visitor

and

User

24

months

Google

Connect SSO

connection Visitor

and

User

24

months

Apple

Connect SSO

connection Visitor

and

User

24

months

Facebook Content

sharing Visitor

and

User

24

months

Facebook

Messenger Content

sharing Visitor

and

User

24

months

Twitter Content

sharing Visitor

and

User

24

months

Cookie

management

All

of

the

rights

recognized

are

also

applicable

to

the

User

or

Visitor

.

The

User

and

the

Visitor

have

different

means

to

manage

the

implementation

of

cookies

subject

to

their

choice

.

The

User

and

the

Visitor

can

at

any

time

choose

to

deactivate

the

implementation

of

cookies

subject

to

their

choice

or

to

delete

those

which

have

already

been

installed

on

their

Terminal

by

using

the

corresponding

function

in

their

account

setting

in

the

mobile

application

or

via

the

dedicated

button

in

the

website

access

.

The

settings

of

the

User

'

s

and

Visitor

'

s

navigation

software

may

modify

the

conditions

of

access

to

the

Services

when

the

use

of

certain

cookies

is

necessary

,

while

the

settings

of

the

navigation

software

or

the

Terminal

'

s

operating

system

prevent

the

deposit

or

reading

of

these

cookies

or

trackers

.

In

addition

,

if

the

User

'

s

or

Visitor

'

s

Terminal

is

used

by

several

people

and

when

the

same

Terminal

has

several

navigation

software

,

United

Heroes

cannot

ensure

with

certainty

that

the

services

intended

for

the

Terminal

of

the

The

User

and

the

Visitor

correspond

to

their

own

use

of

this

Terminal

and

not

to

that

of

another

user

of

this

Terminal

.

To

whom

,

and

how

,

does

United

Heroes

transfer

my

Personal

Data

?

Main

data

flows

In

order

to

provide

Users

with

the

Services

and

functionalities

relating

to

their

use

of

the

Services

,

United

Heroes

may

transfer

or

make

accessible

certain

User

data

,

strictly

necessary

for

this

purpose

,

to

the

following

category

of

activity

(

ies

)

practiced

).

They

only

provide

an

overview

of

the

aggregate

engagement

per

month

.

These

reports

do

not

in

any

way

affect

the

User

'

s

rights

over

their

data

,

as

detailed

in

section

10

of

this

privacy

policy

.

The

legal

basis

for

this

processing

is

the

need

for

United

Heroes

to

perform

its

contract

with

the

Subscriber

Company

or

partner

company

.

The

User

must

contact

the

Subscriber

Company

or

partner

company

in

order

to

assert

their

rights

regarding

the

use

of

their

data

provided

in

these

reports

,

as

the

Subscriber

Company

or

partner

company

becomes

responsible

for

the

processing

of

this

data

upon

receipt

of

these

reports

.

Transfer

to

third

parties

Privacy Policy EN

23

United

Heroes

may

transfer

data

to

its

service

providers

.

A

list

of

all

providers

to

whom

we

transfer

subsets

of

data

can

be

found

in

the

appendix

.

Furthermore

,

in

the

context

of

certain

Challenges

,

and

subject

to

the

express

consent

of

the

User

,

United

Heroes

may

transfer

the

User

'

s

contact

details

to

the

Partner

Company

in

the

organization

of

the

Challenge

.

This

Partner

Company

may

then

,

subject

to

the

User

'

s

consent

,

contact

the

User

again

for

promotional

and

advertising

purposes

.

When

the

User

uses

the

Services

through

a

Partner

Platform

:

The

User

'

s

Personal

Data

may

be

exchanged

between

United

Heroes

and

this

Partner

for

the

purposes

of

providing

the

Services

to

the

User

.

Said

Partner

may

share

Personal

Data

with

other

third

parties

of

its

choice

,

provided

that

the

User

has

expressly

and

previously

consented

to

the

sharing

of

their

Personal

Data

within

our

Services

or

on

the

Partner

Platform

.

In

this

case

,

the

third

party

recipient

of

the

Personal

Data

remains

responsible

for

processing

the

Personal

Data

concerned

.

The

Personal

Data

of

Users

may

be

transmitted

to

Partners

so

that

the

latter

can

,

if

necessary

,

manage

support

requests

in

connection

with

the

Services

.

Transfer

outside

the

European

Union

All

User

Personal

Data

is

stored

within

the

European

Union

,

on

AWS

servers

in

Dublin

and

Frankfurt

.

Automatic

backups

of

Data

are

also

carried

out

within

the

European

Union

.

United

Heroes

undertakes

not

to

carry

out

any

transfer

of

Personal

Data

outside

the

European

Union

without

implementing

appropriate

guarantees

in

accordance

with

the

Applicable

Regulations

as

interpreted

by

the

CNIL

and

the

Court

of

Justice

of

the

European

Union

,

in

particular

by

concluding

contractual

clauses

based

on

the

models

adopted

by

the

European

Commission

.

What

does

United

Heroes

do

to

protect

the

data

I

transmit

to

it

?

United

Heroes

attach

particular

importance

to

the

security

of

your

Personal

Data

.

United

Heroes

has

implemented

appropriate

and

stringent

security

measures

intended

to

prevent

your

Personal

Data

from

being

deleted

,

altered

,

lost

,

used

,

Privacy Policy EN

24

extracted

,

modified

,

disclosed

or

accessed

without

authorization

and

fraudulently

.

These

measures

are

adapted

according

to

the

level

of

sensitivity

of

the

data

processed

and

the

level

of

risk

.

In

particular

,

United

Heroes

has

implemented

procedures

to

detect

,

analyze

and

deal

with

any

suspected

violation

of

your

Personal

Data

,

and

notifies

you

and

any

relevant

supervisory

authority

of

a

violation

when

United

Heroes

is

legally

or

contractually

required

to

do

so

.

In

addition

,

United

Heroes

limits

access

to

your

Personal

Data

only

to

employees

,

subcontractors

and

other

third

parties

who

need

access

to

it

to

carry

out

their

missions

.

They

are

subject

to

an

obligation

of

confidentiality

.

United

Heroes

also

requires

its

co

-

contractors

to

respect

the

security

of

the

Personal

Data

of

its

Users

and

Visitors

and

to

process

them

in

accordance

with

the

data

protection

laws

in

force

.

To

this

end

,

United

Heroes

ensures

that

it

works

with

partners

who

have

certification

to

guarantee

these

levels

of

security

,

favoring

companies

certified

with

ISO

27001,

SOC

2

or

other

certification

standards

for

security

management

.

The

Sites

use

the

industry

standard

Transport

Layer

Security



TLS

)

to

encrypt

Personal

Data

,

including

your

name

and

address

.

The

Sites

are

also

registered

with

website

identification

authorities

so

that

your

browser

can

confirm

the

identity

of

United

Heroes

before

any

Personal

Data

is

sent

.

Personal

Data

is

also

encrypted

when

recorded

on

storage

media

(

hard

drives

).

This

encryption

uses

the

AES

256

standard

.

Finally

,

the

banking

data

collected

by

our

online

sales

service

providers



Stripe



are

subject

to

a

level

of

security

adapted

to

the

risk

associated

with

the

processing

of

this

data

.

United

Heroes

only

stores

an

identifier

specific

to

our

online

sales

service

providers



Stripe



and

does

not

have

unencrypted

access

to

this

data

.

What

can

I

do

to

help

keep

my

data

secure

?

Here

is

a

non

-

exhaustive

list

of

measures

you

can

take

to

secure

your

experience

on

the

United

Heroes

Applications

:

Use

a

reputable

and

secure

web

browser

,

such

as

Google

Chrome

or

Mozilla

Firefox

,

and

keep

it

up

to

date

with

the

latest

updates

and

security

Privacy Policy EN

25

patches

.

Use

a

strong

,

unique

password

for

every

online

account

and

website

,

and

use

a

password

manager

to

store

and

manage

your

passwords

securely

.

Avoid

clicking

on

suspicious

links

or

downloading

unknown

files

as

they

may

contain

malware

or

others

.

Install

and

regularly

update

antivirus

and

anti

-

malware

software

on

your

computer

,

and

regularly

scan

your

computer

for

viruses

and

other

threats

.

Keep

your

computer

and

mobile

operating

system

and

other

software

up

to

date

with

the

latest

patches

and

security

updates

.

Update

United

Heroes

apps

when

a

new

version

is

available

.

In

case

you

notice

any

security

issue

,

you

can

report

it

to

United

Heroes

Support

at

the

following

address

:

help

@

united

-

heroes

.

com

United

Heroes

cannot

be

held

responsible

for

any

compromise

of

your

data

which

may

have

been

intercepted

due

to

your

use

of

an

unsecured

browser

or

subpar

security

practices

(

ie

.

weak

password

,

credential

sharing

).

Does

United

Heroes

offer

to

unsubscribe

from

communications

?

Yes

.

If

you

no

longer

wish

to

receive

emails

from

United

Heroes

,

we

invite

you

to

:

to

follow

the

unsubscribe

instructions

accessible

in

each

email

;

Or

to

send

an

email

to

the

email

address

:

help

@

united

-

heroes

.

com

In

such

a

case

,

United

Heroes

will

not

provide

or

share

its

mailing

lists

or

other

information

about

you

to

any

other

company

or

service

for

promotional

purposes

.

What

are

my

rights

?

In

accordance

with

the

Applicable

Regulations

,

you

benefit

at

any

time

and

free

of

charge

from

a

right

of

access

,

rectification

,

modification

,

deletion

(

right

to

be

forgotten

),

limitation

of

processing

,

opposition

and

,

where

applicable

,

limitation

of

processing

and

portability

(

in

JSON

format

)

of

Personal

Data

concerning

you

,

subject

to

the

rights

and

freedoms

of

third

parties

and

the

obligations

incumbent

onUnited

Heroes

.

Privacy Policy EN

26

You

also

have

the

right

to

define

directives

relating

to

the

fate

of

your

Personal

Data

after

your

death

.

When

processing

is

based

on

consent

,

the

User

may

,

at

any

time

,

request

withdrawal

of

consent

,

it

being

specified

that

processing

carried

out

prior

to

withdrawal

remains

lawful

.

Users

can

exercise

their

rights

:

By

sending

an

email

to

the

following

address

:

help

@

united

-

heroes

.

com

;

or

By

writing

to

the

postal

address

:

United

Heroes

, 91

rue

Jean

Pierre

Timbaud

, 75011

Paris

-

France

;

Regarding

the

rights

of

rectification

,

modification

and

deletion

,

by

configuring

or

updating

your

profile

in

“

Edit

your

profile

”

on

your

United

Heroes

User

Account

.

If

you

consider

that

United

Heroes

has

failed

to

fulfill

its

legal

obligations

under

the

Applicable

Regulations

,

you

,

or

an

association

mandated

for

this

purpose

,

have

the

possibility

of

lodging

a

complaint

with

the

CNIL

or

the

supervisory

authority

of

the

Member

state

of

the

European

Union

in

which

you

usually

reside

.

Changes

to

the

Privacy

Policy

United

Heroes

may

modify

the

Policy

at

any

time

,

and

therefore

invites

you

to

consult

it

regularly

,

on

the

United

Heroes

Sites

and

/

or

United

Heroes

Applications

that

you

consult

or

use

.

In

the

event

of

a

substantial

modification

of

the

Policy

concerning

your

rights

,

United

Heroes

will

bring

them

to

your

attention

as

soon

as

possible

.

How

do

I

contact

United

Heroes

?

United

Heroes

welcomes

your

questions

and

comments

.

You

can

send

us

your

questions

or

comments

by

email

to

the

email

address

:

help

@

united

-

heroes

.

com

or

contact

our

DPO

at

the

email

address

:

dpo

@

united

-

heroes

.

com

Annex

Data

Card

:

Privacy Policy EN

27

1.

Users

●

First

name

-

public

●

Name

–

public

●

Email

–

private

●

Gender

–

private

or

public

when

the

data

is

deducted

from

registration

for

certain

Challenges

.

(

optional

)

●

Birthday

–

private

or

public

when

the

data

is

provided

for

registration

for

certain

Challenges

(

optional

)

●

Currency

-

public

(

optional

)

●

Language

-

public

(

optional

)

●

Photo

-

public

(

optional

)

●

Facebook

-

private

(

optional

)

○

Identifier

○

Access

token

●

Google

-

private

(

optional

)

○

Identifier

○

Access

token

●

Places

-

public

(

optional

)

○

Location

identity

○

Would

○

Pays

○

Time

zone

○

Code

postal

○

Lat

.

○

Lng

.

●

Apps

-

public

(

optional

)

○

Id

.

they

profile

○

Profile

URL

○

Access

token

●

Company

-

private

(

optional

)

●

Commercial

unit

-

private

(

optional

)

●

Bib

number

-

private

(

optional

)

●

Phone

number

-

private

(

optional

)

●

Postal

address

-

private

(

optional

)

●

Shoe

size

-

private

(

optional

)

●

T

-

shirt

size

-

private

(

optional

)

2.

Activities

-

public

or

private

(

at

the

User

'

s

choice

)

●

Identifier

●

Supplier

●

Distance

●

Duration

●

Climb

●

Descent

●

Departure

date

●

Waypoints

○

Lat

.

○

Lng

.

○

Age

.

○

Time

●

Type

●

Time

zone

●

Calories

●

Number

of

steps

●

Duration

of

activity

List

of

main

third

-

party

providers

to

whom

we

transfer

data

:

Privacy Policy EN

28

Hosting

and

Infrastructure

Subcontractor Service

/

Purpose Data

Location Transfer

guarantees

AWS



Amazon

Web

Services

)

Cloud

hosting

and

server

infrastructure

Ireland



EU



Data

Privacy

Framework



DPF



MongoDB

Atlas Database Ireland



EU



Hosted

on

AWS

EU

infrastructure

CloudAMQP

Queue

management



Message

Queuing

)

Ireland



EU



Hosted

on

AWS

EU

infrastructure

Third

-

party

features

and

services

Subcontractor Service

/

Purpose Data

Localization Transfer

Safeguards

Algolia Internal

search

engine France



EU



N

/

A

Stream

Chat

,

feeds

,

and

social

interaction

management

Ireland



EU



Hosted

on

AWS

EU

infrastructure

Typeform

Forms

and

surveys

Users

Spain



EU



N

/

A

Zendesk

User

support

management

and

ticketing

EU



Germany

/

Ireland

)

Binding

Corporate

Rules



BCR



OpenAI

Automatic

translation

,

at

the

User

'

s

request

,

of

messages

in

the

discussion

spaces

United

States

Data

Privacy

Framework



DPF

 +

Standard

Contractual

Clauses



SCC



Marketing

and

Analytics

Subcontractor Service

/

Purpose Data

location Transfer

safeguards

Braze

In

-

app

content

and

transactional

emails

Germany



EU



Hosted

on

AWS

EU

infrastructure

Mixpanel

Statistical

analysis

of

product

usage

Ireland



EU



Hosted

on

Google

Cloud

/

AWS

EU

infrastructure

Authentication

(

SSO

)

Privacy Policy EN

29

Subcontractor Service

/

Purpose Data

location

Transfer

safeguards