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PRIVACY POLICY

Last Updated: April 2, 2024

This Privacy Policy (“Privacy Policy” or “Policy”) explains how Zwift, Inc. (
“Zwift,” or “we,” or “us,” or “our”) collects personal information based on your
interactions with us online, including on our websites and applications to
provide our virtual cycling and running experiences and other workout games,
including, the Zwift App, the Zwift Companion App and Zwift Power, and other
services (the “Services”). This Policy applies to our collection and use of
personal information in connection with the Services and describes rights you
may have with respect to your personal information we collect about you. By
using our Services and otherwise interacting with us, you agree to the terms of
our Terms of Service, including this Policy.

This Policy does not cover the personal information we collect about employees
and independent contractors, or job applicants.


NOTICE AT COLLECTION: PERSONAL INFORMATION WE COLLECT

We collect the following categories of personal information:

 * Personal identifiers: name; date of birth; email address; your home or
   billing address; telephone numbers; customer number; account log in
   information and password; IP address

 * Protected class information: age; gender (self-identified)

 * Customer record information: height, weight, and health information such as
   heart rate, total output and calories burned during your workout;
   participation or registration in cycling events; race results and cycling
   performance information (e.g., rankings, ride-related information);
   information relating to in-app chats and other communications with Zwift
   users

 * Commercial information: information regarding the Services with which you
   engage, including rides or runs taken, participation in Zwift Academy and
   other events; in-app shopping histories including products ordered or
   considered; and payment information

 * Financial information: method of payment and payment-related information

 * Internet or other electronic activity information: information about your
   computer or mobile application and browsers you use to access our Services;
   mobile network information; app version you use; your browsing and search
   history on our Services; log information about your use of the Services; and
   information regarding your interaction with our Services

 * Professional information: job title; information about your employer

 * Audio and visual information: recordings of customer service calls for
   quality assurance purposes; profile pictures; avatars; information about
   screen shots you take

 * Inferences drawn from personal information we collect

 * Sensitive personal information: account log in information and password;
   health-related information such as your height, weight, heart rate

 * Location information: in order to allow Bluetooth pairing if you choose to
   connect Zwift to your smart fitness device via Bluetooth, geolocation
   information. 
   
   We have collected the same categories of personal information in the 12
   months prior to the date of this Privacy Policy.


NOTICE AT COLLECTION: PURPOSES FOR COLLECTION OF PERSONAL INFORMATION

We collect your personal information to provide our Services to you; to fulfil
customer orders and requests; to contact you from time to time; to provide you
with information about our business; for customer support; to deliver
advertisements and marketing promotions and offers about products we think may
be of interest to you; to facilitate contests, sweepstakes, and promotions and
process and deliver entries and rewards; to respond to your inquiries; to
customize your experience; and to audit and analyze the placement and
effectiveness of our advertisements and other marketing efforts.

We also use personal information to monitor or improve our Services; for
internal business analysis; to prevent fraud, activities that violate our Terms
of Service or other contracts, or that are illegal; and to protect our rights
and the rights and safety of our users or others.

For those who interact with us in a commercial capacity, we use your personal
information to engage in business transactions with the entity you represent and
market to or engage in diligence with the entities you represent.


NOTICE AT COLLECTION: CATEGORIES OF PERSONAL INFORMATION WE SELL OR SHARE AND
RELATED INFORMATION

When we engage in digital advertising, we may sell the following categories of
personal information (according to the broad definition of “sell” under select
state privacy laws) and share them for purposes of cross-context behavioral
advertising: personal identifiers (IP address) and internet or other electronic
activity information.

These categories of personal information are sold to or shared for cross-context
behavioral advertising to advertising networks and other companies that
facilitate digital advertising. We engage in such sales and sharing to
facilitate digital advertising that is able to reach people that are most likely
to be interested in the Services we provide. We do so by allowing third parties
to place cookies or other tracking technologies on our website that may collect
information about your online activities over time and across different websites
or applications. For more information about the use of cookies and other
tracking technologies, see the section “Our Use of Cookies and Analytics” below.

We do not sell or share for cross-context behavioral advertising any of the
other categories of personal information we collect.


NOTICE AT COLLECTION: RETENTION PERIODS

We generally retain the categories of personal information we collect for the
length of time necessary to provide our Services and to comply with legal
obligations or to protect our legal rights.

We retain information about your use of the Services until you delete your
account with us. Personal information included in in-app chats is deleted after
90 days.


SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION

We collect personal information directly from you, from devices and hardware you
use to access or link to our Services, from other users who may include you on
their team, and representatives of entities with which we do business or may do
business, and from tracking technologies such as cookies, web beacons, and
pixels. We may also collect information about you from social media sites you
use to log into your account or from other fitness services that you authorize
to share your information with us.


USE OR DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

We do not use or disclose sensitive personal information to create profiles
about individuals or for any purposes other than providing our Services.


DISCLOSURE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES IN THE PAST 12 MONTHS

The following chart describes the categories of personal information we
disclosed to third parties for a business purpose in the 12 months prior to the
date of this Policy:

Categories of Consumers’ Personal InformationCategories of Third Parties to
Which We Disclosed Personal Information for Business PurposesPersonal
identifiers: name; date of birth; email address; your home or billing address;
telephone numbers; customer number; account log-in information and password; IP
address.Service providers that process payments; verify customer information;
manage customer information and provide customer service (including through our
call center); fulfill orders; facilitate email communications; facilitate
contests, sweepstakes, and promotions; provide security services and cloud-based
data storage; host our website and assist with other IT-related functions;
advertise and market our Services; provide analytics information; and provide
legal and accounting services. Certain personal identifiers are also shared with
other Zwift users and any third-party fitness apps connected to your Zwift
account.Protected class information: age; sex/gender.Service providers that
manage customer information, advertise and market our products; provide
analytics information. Age and sex/gender information may be shared with other
Zwift users and any third-party fitness apps connected to your Zwift
account.Customer record information: height, weight, and health information such
as heart rate, total output and calories burned during your workout;
participation or registration in cycling events; race results and cycling
performance information (e.g., rankings, ride-related information); information
relating to in-app chats and other communications with Zwift usersService
providers that process payments; verify customer information; manage customer
information and provide customer service (including through our call center);
fulfill orders; facilitate email communications; provide security services and
cloud-based data storage; host our website and assist with other IT-related
functions; advertise and market our Services; provide analytics information;
review chat data to ensure compliance with Terms of Service; and provide legal
and accounting services. Certain personal identifiers are also shared with other
Zwift users and any third-party fitness apps connected to your Zwift
account.Commercial information: information regarding the Services with which
you engage, including rides or runs taken, participation in Zwift Academy and
other events; in-app shopping histories including products ordered or
considered; and payment informationService providers that process payments;
verify customer information; manage customer information and provide customer
service (including through our call center); fulfill orders; facilitate email
communications; provide security services and cloud-based data storage; host our
website and assist with other IT-related functions; advertise and market our
Services; provide analytics information; and provide legal and accounting
services. Certain personal identifiers are also shared with other Zwift users
and any third-party fitness apps connected to your Zwift account.Financial
information: method of payment and payment-related informationPayment
processorsInternet or other electronic activity information: information about
your computer or mobile application and browsers you use to access our Services;
mobile network information; app version you use; your browsing and search
history on our Services; log information about your use of the Services; and
information regarding your interaction with our ServicesService providers that
provide security services and cloud-based data storage; host our website and
assist with other IT-related functions; advertise and market our products; and
provide analytics informationAudio and visual information: recordings of
customer service calls for quality assurance purposes; profile pictures;
avatars; information about screen shots you takeService providers that manage
customer information and provide customer service (including through our call
center).Inferences drawn from personal information collected Service providers
that advertise and market our Services; provide analytics informationSensitive
personal information: account log in information and password; health
information such as your height, weight, heart rate, and information related to
your workoutsSee above

BUSINESS PURPOSES FOR SUCH DISCLOSURES

We disclosed the aforementioned categories of personal information to the
categories of third parties identified above for the following purposes: to
manage customer, supplier and vendor accounts and relationships; process
payments; verify customers’ identities; fulfill orders and transactions; engage
in advertising and marketing; provide you with our Services and facilitate any
information sharing directed by you; operate our IT systems and secure our
systems; prevent fraud and other illegal activities; and to obtain professional
advice about legal and accounting matters.

ADDITIONAL INFORMATION ABOUT HOW WE MAY DISCLOSE PERSONAL INFORMATION AND
PURPOSES FOR DISCLOSURES

We may also disclose your personal information as required or permitted by law
to comply with a subpoena or similar legal process or government request, or
when we believe in good faith that disclosure is legally required or otherwise
necessary to protect our rights and property or the rights, property or safety
of others, including to law enforcement agencies, and judicial and regulatory
authorities. We may also disclose your personal information to third parties to
help detect and protect against fraud or data security vulnerabilities. And we
may disclose or transfer your personal information to a third party in the event
of an actual or potential sale, merger, reorganization of our entity or other
restructuring.


OUR USE OF COOKIES AND ANALYTICS

We may use cookies, pixel tags, web beacons and other similar tracking
technologies (“tracking technologies”) to automatically collect information
through our Services. Tracking technologies are small data files placed on your
computer, tablet, mobile phone, or other devices that record certain pieces of
information when you visit our website. We may use these tracking technologies
to help identify irregular behavior, prevent fraudulent activity and improve
security, as well as making it possible for you to save your preferences and
help us understand how you interact with our website.

We also allow third parties to use tracking technologies on our websites and
applications for analytics and advertising purposes. They assist in helping
display advertisements, tailor advertisements to your interests and to assist in
determining if you require assistance or are having problems navigating on our
website. Some of these third parties use the tracking technologies to collect
information about how you interact with other websites and advertisements across
the Internet in order to provide advertising that is tailored to your interests
and which may appear on our website or on other website or platforms.

You may set your browser to notify you when you receive a cookie. Many web
browsers also allow you to block cookies. You can disable cookies from your
computer system by following the instructions on your browser or at
www.allaboutcookies.org.

We use Google Analytics to evaluate the use of our website. Google Analytics
uses cookies and other identifiers to collect information, such as how often
users visit a Site, what pages they visit when they do so, and what other
websites they visited prior to visiting our Site. For information about Google’s
privacy practices, please refer to the Google Privacy Policy:
https://policies.google.com/privacy?hl=en-US#infocollect.


PERSONAL INFORMATION OF MINORS

While children can use our Services, we do not direct our Services to children
under age 13. If you, as a parent or guardian, would like to set up a Zwift
account for your child who is under 13, please first review our direct notice to
parents. Our separate Zwift Children’s Privacy Policy explains the limited ways
in which we will use and share your child’s data, as well as the rights you have
with respect to that data. If you believe a child under 13 (in the United
States) or 16 (in the EEA) has submitted personal information to us without
their parent’s consent, please contact us at privacy@zwift.com and we will use
our best efforts to promptly remove such information from our files.

We do not knowingly sell or share for purposes of behavioral advertising the
personal information of minors, including minors under 16 years of age.


DO NOT TRACK AND OTHER UNIVERSAL OPT OUT SIGNALS

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. Please note that we do not respond to or honor DNT signals. We observe
the Global Privacy Control (“GPC”) signal with respect to all IP addresses in
the US.


HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

We implement and maintain reasonable security appropriate to the nature of the
personal information that we collect, use, retain, transfer or otherwise
process. However, there is no perfect security, and reasonable security is a
process that involves risk management rather than risk elimination. While we are
committed to maintaining a reasonable information security program, no such
program can be perfect; in other words, all risk cannot reasonably be
eliminated. Data security incidents and breaches can occur due to factors that
cannot reasonably be prevented. Accordingly, it cannot be assumed that the
occurrence of any given incident or breach results from our failure to implement
and maintain reasonable security.


THIRD PARTY WEBSITES, APPLICATIONS AND SOCIAL MEDIA PLATFORMS

The Services may offer social sharing features, links to third-party websites or
applications, and other integrated tools (such as the Facebook “Like” button),
which let you share actions you take on our Services with other media or visit
the websites of other businesses. Your use of social sharing features enables
the sharing of information with your friends or the public, depending on the
settings you establish with the entity that provides the social sharing feature.
While we may include opportunities to use or connect to these third-party
features or third-party websites and applications, we do not control these sites
and are not responsible for their data use practices or their use of your
information. Please review those entities’ privacy policies for information
about how they collect, use and share your personal information.


CHANGES TO THIS POLICY

We will review and update this Policy from time to time. If changes are made, we
will update the Privacy Policy and reflect the date of such modification in the
date above. If the changes are material, you will be notified via email or a
notice on our website.


ACCESSIBILITY

We are committed to ensuring that our communications are accessible to people
with disabilities. To make accessibility-related requests or report barriers,
please contact us at info@zwift.com.


CONTACT US

If there are any questions regarding this Privacy Policy or to request a copy of
this Privacy Policy in another format you may contact us at privacy@zwift.com.

You can also contact us here:

 * 111 West Ocean Blvd. Suite 1800, Long Beach, CA 90802 USA

 * 150 Long Lane, London, SE1 4BS, United Kingdom


US STATE DATA PRIVACY RIGHTS

Laws in certain US states give residents of those states specific rights with
respect to the personal information collected about them. See below for more
information.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, the California Consumer Privacy Act (“CCPA”)
and other laws provide you with the following rights with respect to your
personal information:

YOUR RIGHT TO KNOW ABOUT PERSONAL INFORMATION WE COLLECT

You can ask us for the following information from us with respect to the
personal information we have collected about you in the 12 months prior to our
receipt of your request:

 * Specific pieces of personal information we have collected about you;

 * Categories of personal information we have collected about you;

 * Categories of sources from which such personal information was collected;

 * Categories of personal information that the business sold or disclosed for a
   business purpose about the consumer;

 * Categories of third parties to whom the personal information was sold or
   disclosed for a business purpose; and

 * The business or commercial purpose for collecting or selling your personal
   information.

YOUR RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION WE HAVE COLLECTED FROM
YOU

Upon your request and subject to exceptions in the law, we will delete the
personal information we have collected from you.

YOUR RIGHT TO REQUEST TO CORRECT PERSONAL INFORMATION WE HOLD ABOUT YOU

You have the right to request that we correct personal information we hold that
you believe is not accurate. We will take steps to determine the accuracy of the
personal information that is the subject of your request to correct, and in
doing so will consider the totality of the circumstances relating to the
personal information you have identified as being incorrect. We may ask that you
provide documentation regarding your request to correct in order to assist us in
evaluating the request.

YOUR RIGHT TO ASK US NOT TO SELL OR SHARE PERSONAL INFORMATION WE HAVE COLLECTED
ABOUT YOU

With respect to those categories of personal information that we sell to third
parties or share with third parties for the purpose of cross-context behavioral
advertising, you have the right to opt out of such sales and sharing.

CALIFORNIA SHINE THE LIGHT

California Civil Code Section 1798.83, also known as the “Shine the Light” law,
permits California residents to annually request, free of charge, information
about the personal information (if any) disclosed to third parties for direct
marketing purposes in the preceding calendar year. To make a request, please
contact us at privacy@zwift.com.

OUR COMMITMENT TO HONORING YOUR RIGHTS

If you exercise any of the rights explained in this Privacy Policy, we will
continue to treat you fairly. If you exercise your rights under this Privacy
Policy, you will not be denied or charged different prices or rates for goods or
services, or provided a different level or quality of goods or services than
others.

EXERCISING YOUR RIGHTS AND HOW WE WILL RESPOND

To exercise your rights to know, delete or correct your personal information, or
to ask a question, contact us at privacy@zwift.com. For such requests, we will
first acknowledge receipt of your request within 10 business days of receipt of
your request. We will then provide a substantive response to your request as
soon as we can, generally within 45 days from when we receive your request,
although we may be allowed to take longer to process your request in certain
jurisdictions or under certain circumstances. If we expect your request is going
to take us longer than normal to fulfill, we will let you know.

If you use a browser or a plug-in that recognizes the Global Privacy Control
universal opt-out preference signal (“GPC”), we will recognize the signal as
applied to the browser and device from which the signal is sent. Browsers and
extensions that currently recognize the signal can be found here:
https://globalprivacycontrol.org/#download. We recognize the GPC signal in a
“frictionless” manner, which means we do not collect additional information from
you in order to associate the GPC signal with your account.

We usually act on requests and provide information free of charge, but we may
charge a reasonable fee to cover our administrative costs of providing the
information in certain situations. In some cases, the law may allow us to refuse
to act on certain requests. When this is the case, we will endeavor to provide
you with an explanation as to why.

VERIFICATION OF IDENTITY – REQUESTS TO KNOW, DELETE OR CORRECT

We will ask you for two pieces of personal information and attempt to match
those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required,
we will not be able to respond to the request. We will notify you to explain the
basis of the denial.

AUTHORIZED AGENTS

You may designate an agent to submit requests on your behalf. The agent can be a
natural person or a business entity.

If you would like to designate an agent to act on your behalf, you and the agent
will need to comply with our verification process:

 * Requests to Know, Delete or Correct Personal Information: If the agent
   submits a request, the agent will need to provide us with your signed
   permission indicating the agent has been authorized to submit the request on
   your behalf. We will also require that you verify your identity directly with
   us or confirm with us that you provided the agent with permission to submit
   the request.

 * Requests to Opt Out of Sale or Sharing: If the agent submits a request to opt
   out of the sale of your personal information or the sharing of your personal
   information for purposes of cross-context behavioral marketing, the agent
   will need to provide us with your signed permission indicating the agent has
   been authorized to submit the opt-out request on your behalf.

Please note that this subsection does not apply when an agent is authorized to
act on your behalf pursuant to a valid power of attorney. Any such requests will
be processed in accordance with California law pertaining to powers of attorney.

VIRGINIA PRIVACY RIGHTS

The Virginia Consumer Data Privacy Act (“VCDPA”) grants Virginia residents the
following rights with respect to their personal information we collect:

 * Right to Know: The right to confirm whether or not we are processing their
   personal information and to access such data.

 * Right to a Copy: The right to a portable copy of the personal information we
   have collected from them.

 * Right to Delete: The right to request deletion of their personal information
   that we have collected about them and to have such information deleted,
   subject to certain exceptions.

 * Right to Correct: The right to ask that we correct inaccuracies in their
   personal information, taking into account the nature of personal data and
   purposes of processing such information.

While Virginia law provides the right to opt out of the sale of personal
information, we do not sell personal information consistent with the definition
of “sale” under Virginia law.

Please note that for purpose of this section of this Policy, we consider
“personal information” to have the same meaning as “personal data” as defined
under the VCDPA.

EXERCISING YOUR RIGHTS AND HOW WE WILL RESPOND

Contact us at privacy@zwift.com to exercise the right to know, obtain a portable
copy of, delete, or correct your personal information. We will respond to such
requests within 45 days from when we receive your request, although we may be
allowed to take longer to process your request under certain circumstances. If
we expect your request is going to take us longer than normal to fulfill, we
will let you know.

We usually act on requests and provide information free of charge, but we may
charge a reasonable fee to cover our administrative costs of providing the
information in certain situations.

VERIFICATION OF IDENTITY – REQUESTS TO KNOW, DELETE, CORRECT

We will ask you for two pieces of personal information and attempt to match
those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required,
we will not be able to respond to the request. We will notify you to explain the
basis of the denial.

WHEN WE DO NOT ACT ON A REQUEST – APPEAL PROCESS

In some cases, we may not act on your requests (e.g., if we cannot do so under
other laws that apply). When this is the case, we will explain our reasons for
not providing you with the information or taking the action (e.g., correcting
data) you requested.

Additionally, you have the right to appeal our decision by contacting us at same
method used to submit requests within 30 days after your receipt of our
decision. Please provide us with information the company needs (e.g., reference
number) to identify denial of request. We will respond to your appeal within 60
days of our receipt of the request.


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