Privacy Policy

This Privacy Policy applies to:

• Studiom mobile applications for iOS and Android;
• the Studiom Dashboard used by participating studio owners and authorized personnel;
• the Studiom website and support services where personal data is collected; and
• related Studiom services that refer to this Privacy Policy.

This Policy does not replace the privacy notices or policies of individual studios. Participating studios may separately process personal data in connection with their own membership, contractual, legal, or operational obligations.

Depending on the context, Studiom may act in different capacities.

For personal data that a participating studio manages through Studiom in connection with its members, classes, memberships, attendance, or studio operations, the relevant studio will generally determine the purposes for which that information is processed.

In such circumstances, the studio may act as the data controller and Studiom may process data on the studio's behalf as a service provider or data processor.

For information Studiom processes for its own purposes — including platform security, account administration, service delivery, legal compliance, fraud prevention, and operation of the Studiom platform — [LEGAL ENTITY NAME] may act as an independent data controller.

Your rights may therefore need to be exercised either with Studiom or directly with the relevant studio, depending on the type of processing involved.

Depending on how you use Studiom, we may process the following categories of information.

3.1 Member Information

Participating studios may create or manage member records containing information such as:

• full name;
• email address;
• telephone number;
• membership status;
• membership package or type;
• remaining class credits;
• member level or similar membership information;
• studio affiliation; and
• activation or membership identifiers.

Members currently access the Studiom mobile application using a studio-issued membership or activation code. The mobile member application does not require members to create a separate Studiom email-and-password account unless the product is later changed to provide such functionality.

3.2 Studio Owner and Dashboard Account Information

Authorized studio owners or other permitted dashboard users may have Studiom Dashboard accounts. Depending on the authentication system in use, we may process:

• name;
• email address;
• authentication credentials;
• associated studio;
• account identifiers; and
• access and authorization information.

Authentication credentials such as passwords are handled through our authentication infrastructure and are not stored by us in plain text.

3.3 Class, Booking and Attendance Information

We process information required to manage studio classes and member participation, including:

• class name;
• class date and time;
• instructor information;
• studio location;
• booking status;
• booking and cancellation records;
• attendance status; and
• class capacity information.

3.4 Studio Information

We may process information relating to participating studios, including:

• studio name;
• studio branding;
• logo;
• theme or brand color;
• class schedule;
• membership packages;
• studio owner account relationship; and
• other operational information provided through the Dashboard.

3.5 Support and Communications

If you contact us, we may process:

• your name;
• email address;
• studio name;
• message content; and
• any other information you voluntarily provide.

3.6 Technical Information

We may process limited technical information necessary to operate, secure, troubleshoot, and maintain the platform. Depending on the features and service providers enabled at the time, this may include:

• application version;
• operating system information;
• device-related technical identifiers;
• network or request information;
• error information; and
• security-related logs.

We do not intentionally collect precise GPS location information through the Studiom member application unless a specific feature requiring location access is introduced and separately disclosed.

We may use personal data to:

• provide and operate the Studiom platform;
• activate member access;
• authenticate authorized users;
• display studio and membership information;
• provide class schedules;
• process bookings and cancellations;
• calculate and display class credits;
• manage class capacity;
• record attendance;
• generate and validate studio-entry QR codes;
• enable participating studios to manage their members;
• operate the Studiom Dashboard;
• provide technical support;
• troubleshoot errors;
• maintain platform security;
• prevent unauthorized access, abuse, or fraud;
• maintain service reliability;
• comply with applicable legal obligations; and
• establish, exercise, or defend legal claims.

We do not sell personal data to advertisers or data brokers.

Where applicable data protection law requires a legal basis, we process personal data based on one or more of the following grounds:

• performance of a contract or taking steps related to a contractual relationship;
• compliance with legal obligations;
• establishment, exercise, or protection of legal rights;
• legitimate interests, provided that such interests do not override the fundamental rights and freedoms of the individual;
• processing expressly permitted by applicable law; and
• explicit consent, where consent is legally required.

For users in Türkiye, personal data is processed in accordance with applicable provisions of Law No. 6698 on the Protection of Personal Data (“KVKK”) and related legislation.

Where the GDPR or another applicable privacy regime applies, the corresponding legal bases under that legislation will apply.

When you are associated with a participating studio, that studio may have access to information necessary to manage your membership and class participation.

This may include:

• your name;
• contact information;
• membership information;
• class credits;
• bookings;
• cancellations;
• attendance records; and
• information necessary for studio entry.

A studio cannot use Studiom to access the private data of another unrelated studio through ordinary authorized platform functionality.

Participating studios remain responsible for their own use of member information and their compliance with applicable privacy and data protection laws.

Studiom processes booking and attendance data in order to provide core platform functionality.

When you book or cancel a class, Studiom may update:

• your booking record;
• class capacity;
• your applicable class credit balance; and
• the studio's class participation information.

Authorized personnel at the relevant studio may view booking and attendance information necessary to manage classes.

The Studiom member application may generate a rotating QR code associated with your member profile.

The QR code may be used by participating studios to:

• identify your membership;
• facilitate studio entry; and
• support attendance or check-in operations.

QR codes are periodically refreshed as part of Studiom's access-control mechanism.

You should not share your QR code or permit another person to use it on your behalf.

We implement reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include:

• database-level access controls;
• row-level security;
• tenant separation;
• server-side authorization checks;
• controlled access to administrative functionality;
• authenticated access for studio owners; and
• security controls around booking and membership operations.

Studiom is designed so that data belonging to separate participating studios is logically isolated.

However, no internet-based service or electronic storage system can guarantee absolute security.

We may use third-party technology providers to operate Studiom, including providers of:

• cloud hosting;
• database infrastructure;
• authentication;
• email;
• application hosting;
• customer support; and
• technical monitoring.

These providers may process personal data solely to the extent necessary to provide their services to us and subject to applicable contractual and legal safeguards.

Depending on the location of our service providers and infrastructure, personal data may be processed in countries other than the country in which you reside.

Where required by applicable law, we will implement appropriate safeguards for international transfers of personal data.

We may disclose personal data:

• to the studio with which you have a membership or relationship;
• to service providers acting on our behalf;
• where required by law, regulation, court order, or lawful governmental request;
• where necessary to protect the rights, security, or integrity of Studiom, participating studios, or users;
• in connection with a merger, acquisition, restructuring, financing, or transfer of business assets, subject to applicable law; or
• where you have expressly authorized the disclosure.

We do not sell personal data for third-party advertising purposes.

We retain personal data only for as long as reasonably necessary for:

• providing the Studiom services;
• maintaining an active studio or member relationship;
• complying with legal or contractual obligations;
• resolving disputes;
• protecting against fraud or abuse; and
• establishing or defending legal claims.

Retention periods may vary depending on the nature of the information and the requirements applicable to the participating studio.

Where applicable, personal data may be deleted, anonymized, or archived when it is no longer required.

You may request deletion of eligible personal data by contacting: support@studiom.com

Certain information may need to be retained where retention is required or permitted by law.

Depending on your location and applicable law, you may have rights including the right to:

• learn whether your personal data is being processed;
• request information regarding processing;
• access personal data relating to you;
• request correction of inaccurate or incomplete data;
• request deletion or destruction where legally permitted;
• object to certain processing;
• request restriction of processing;
• request data portability where applicable;
• withdraw consent where processing relies on consent;
• object to certain automated processing, where applicable; and
• submit a complaint to a competent data protection authority.

Users in Türkiye may also exercise the rights granted under Article 11 of the KVKK.

Requests may be submitted to: support@studiom.com

We may need to verify your identity before processing a privacy request.

Where the relevant studio is the data controller for the requested information, we may direct your request to that studio.

Studiom is intended for use in connection with participating fitness and wellness studios.

We do not knowingly collect personal data directly from children in circumstances prohibited by applicable law.

Where a participating studio permits minors to become members, the studio is responsible for obtaining any parental or guardian authorization required by applicable law.

If you believe personal data relating to a child has been processed improperly, please contact us at: support@studiom.com

The Studiom website may use strictly necessary cookies or similar technologies required to operate the website.

If analytics, advertising, or other optional tracking technologies are introduced, we will provide any disclosures or consent mechanisms required under applicable law.

We may update this Privacy Policy from time to time.

If changes are material, we may provide notice through the Studiom platform, website, email, or another appropriate method.

The “Last Updated” date at the top of this Policy identifies the most recent revision.

For questions, complaints, or requests regarding privacy or personal data:

[LEGAL ENTITY NAME]
[REGISTERED ADDRESS]
[COUNTRY]
Email: support@studiom.com
Website: https://usestudiom.com