HOT TECHNOLOGIES LLC. (“HOT”), its subsidiaries and affiliates are committed to managing
personal information in accordance with the General Data Protection Regulation (EU)
2016/679 (GDPR) and in accordance with other applicable privacy laws.
This document sets out our policies for managing your personal information and is referred to
to any individual about whom we collect personal information.
ABOUT HOT DIGITAL
HOT TECHNOLOGIES LLCis an online fitness and wellness program.
HOT TECHNOLOGIES LLCoffers a range of services, including online workouts and ……
WHAT INFORMATION DOES HOT TECHNOLOGIES LLCCOLLECT ABOUT YOU?
MEMBERS AND PROSPECTIVE MEMBERS
When you enquire about our services or when you subscribe or become a member of HOT, a
record is made which includes your personal information. The type of personal information that
we collect will vary depending on the circumstances of collection and the kind of service that
you request from us, but will typically include:
• your age;
• your fitness and nutrition statistics which you provide to us;
• our login details and passwords which you use to access your account with us as well as
your online interactions with us;
• details of the products and services (such as membership options) you have purchased
from us or which you have enquired about, together with any additional information
necessary to deliver those products and services and to respond to your enquiries;
• any additional information relating to you that you provide to us directly through our
websites or by other means such as over the phone, via email or in person;
• information you provide to us via voluntary members feedback or engagement surveys;
• any additional personal information you provide to us, or authorise us to collect, as part
of your interaction or membership with HOT.
PROSPECTIVE EMPLOYEES / APPLICANTS
We collect personal information when recruiting personnel, such as your name, contact details,
qualifications and work history. Generally, we will collect this information directly from you.
We may also collect personal information from third parties in ways which you would expect.
Before offering you a position, we may also collect relevant information from third party
sources such as [LinkedIn] and other professional websites.
HOT TECHNOLOGIES LLCmay collect personal information about other individuals who are not
members of HOT DIGITAL. This includes customers and members of the public who participate
in events we are involved with; individual service providers and contractors to HOT DIGITAL;
and other individuals who interact with HOT TECHNOLOGIES LLCon a commercial basis. The
kinds of personal information we collect will depend on the capacity in which you are dealing
with HOT DIGITAL. Generally, it would include name, contact details, and information regarding
our interactions and transactions with you.
If you are participating in an event we are managing or delivering, we may take images or audiovisual
recordings which identify you.
You can always decline to give HOT TECHNOLOGIES LLCany personal information we request,
but that may mean we cannot provide you with some or all the services you have requested. If
you have any concerns about personal information we have requested, please let us know.
YOUR SENSITIVE INFORMATION:
HOT TECHNOLOGIES LLCmay collect and process your sensitive information or special category
data, such as your health information, generally with your express consent and only as
reasonably necessary for us to provide our services to you. We may also collect such information
about you in an emergency or otherwise with your consent or in accordance with applicable
VISITORS TO OUR WEBSITE:
The way in which we handle the personal information of visitors to our websites is discussed
WHAT HAPPENS IF YOU DON’T PROVIDE YOUR PERSONAL INFORMATION?
You can always decline to give HOT TECHNOLOGIES LLCany personal information we request,
but that may mean we cannot provide you with some or all of the services you have requested
or we may not be able to do business with you effectively. If you have any concerns about
personal information we have requested, please let us know.
HOW AND WHY DOES HOT TECHNOLOGIES LLCCOLLECT AND USE YOUR PERSONAL
HOT TECHNOLOGIES LLCcollects personal information reasonably necessary to carry out our
business, to assess and manage our members’ needs, and provide our services to you. We may
also collect information to fulfil administrative functions associated with these services, for
example billing, entering into contracts with you and/or third parties and managing member
• The purposes for which HOT TECHNOLOGIES LLCusually collects and uses personal
information depends on the nature of your interaction with us, but may include:
• to fulfil obligations under a membership agreement and/or any other contract you may
have with us;
• to provide information about products, services and/or special offers to members;
• to obtain opinions or comments about products and/or services from members;
• to record statistical data for marketing analysis from members;
• responding to requests for information and other general inquiries;
• managing, planning, advertising and administering programs, events, competitions and
• researching, developing and expanding our facilities and services;
• informing you of our activities, events, facilities and services;
• recruitment processes; and
• responding to enquires and complaints.]
In addition, some of your personal information may be used for other business purposes.
Examples of the types of uses are set out below:
• for our reasonable commercial purposes (including quality control and administration
and assisting us to develop new and improved products and services);
• to follow up with you after you request information to see if we can provide any further
assistance (for example if you enquire about a membership package);
• to comply with any requirement of any applicable statute, regulation, rule and/or good
practice, whether originating from [KUWAIT] or elsewhere.
• to fulfil our obligations under any reporting agreement entered into with any tax
authority or revenue service(s) from time to time; to check your instructions to us, to
analyse, assess and improve our services to members, as well as for training and quality
purposes, we may monitor, record and analyse any communications between you and
us, including phone calls;
• to prevent or detect abuse of our services or any of our rights (and attempts to do so),
membership agreement with us) and to protect our (or others’) property or rights;
• to share information with relevant third parties in the context of a sale or potential sale
of a relevant part of our business, subject always to confidentiality obligations;
if instructed to do so by you or where you give us your consent to the use and/or
• to bring to your attention (in person or by post, email or telephone) information about
additional services offered by us and/or our [global affiliates], which may be of interest
to you, unless you indicate at any time that you do not wish us to do so; and
to improve the relevance of marketing messages we may send you (which you can opt
out of as explained below).
HOT TECHNOLOGIES LLCgenerally collects personal information directly from you. We may
collect and update your personal information over the phone, by email, over the internet or
social media, or in person. We may also collect personal information about you from other
sources, for example:
• our affiliated and related companies;
• third party suppliers and contractors who assist us to operate our business.
• HOT TECHNOLOGIES LLCalso collects and uses personal information for market research
purposes and to innovate our delivery of products and services.
• We have a legitimate interest in using your information in the ways listed above. In some
cases, it will be lawful for us to collect and use your personal information, for example
where it is necessary as part of our, or a third party’s, statutory or public functions or
because the law permits or requires us to.
THE TYPES OF COOKIES WE USE
Specifically, we use the following cookies:
• Strictly necessary cookies: are required for the operation of our website, such as
cookies that enable you to log into secure areas of our website (for example, our
• Analytical/performance cookies: allow us to count the number of users and see how
users move around our website when they are using it. This helps us to improve the way
our website works, for example, by ensuring that users are finding what they are looking
• Targeting cookies: these cookies record your visit to our website, the pages you have
visited and the links you have followed. We will use this information, subject to your
choices and preferences, to make our website and any advertising displayed on it more
relevant to your interests.
• Third party/sharing cookies: are cookies that are set by a domain other than the one
being visited by you. If you visit our website and a separate company sets a cookie
through that website this is a third-party cookie. To try to bring you offers and
advertisements that are of interest to you, we have relationships with third party
companies including [Google, Adobe Analytics, Facebook, LinkedIn] (Third Party
Providers) that allow them to place cookies on our websites.
THESE THIRD PARTY PROVIDES MAY:
use Third Party Cookies, web beacons, and other storage technologies to collect or receive
information from our Websites and elsewhere on the internet; compare de-identified
information from us with information collected elsewhere on the internet; and use that
information to provide measurement services and target ads to you.
HOW LONG COOKIES WILL BE STORE ON YOUR DEVICE
Session cookies are temporary. They allow website operators to link the actions of a user during
a browser session, the time period between a user opening a browser window and closing it.
Once closed, the cookies are deleted. Persistent cookies remain on a user’s device for the period
specified in the cookie.
HOW YOU CAN MANAGE YOUR COOKIES.
If you do not wish to receive any cookies (other than those which are strictly necessary) you
may set your browser (such as Firefox, Google Chrome, Internet Explorer or Safari) to either
on our Websites you visit will be available to you. Some of the websites that let you control
what information is collected about you are: allaboutcookies.org youronlinechoices.com If you
do not wish to receive any cookies (other than those that are strictly necessary) you can use
the settings in your browser to control how your browser deals with cookies (e.g. to either
content on our website.
CAN YOU DEAL WITH US ANONYMOUSLY?
HOT TECHNOLOGIES LLC will provide you with the opportunity of remaining anonymous or using
a pseudonym in your dealings with us where it is lawful and practicable (for example, when
making a general enquiry). Generally, it is not practicable for HOT TECHNOLOGIES LLC to deal
with you anonymously. If we do not collect personal information about you, you may be unable
to utilise our services or participate in our events, programs or activities we manage or deliver.
HOW DO WE HOLD INFORMATION?
HOT TECHNOLOGIES LLC stores information in paper-based files or other electronic record
keeping methods in secure databases (including trusted third-party storage providers based in
Kuwait and United States. Personal information may be collected in paper-based documents
and converted to electronic form for use or storage (with the original paper-based documents
either archived or securely destroyed). We take reasonable steps to protect your personal
information from misuse, interference and loss and from unauthorised access, modification or
HOT TECHNOLOGIES LLC maintains physical security over paper and electronic data stores, such
as through locks and security systems at our premises. We also maintain computer and network
security; for example, we use firewalls (security measures for the Internet) and other security
systems such as user identifiers and passwords to control access to our computer systems.
Our websites do not necessarily use encryption or other technologies to ensure the secure
transmission of information via the internet. Users of our websites are encouraged to exercise
care in sending personal information via the internet.
HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT BY HOT DIGITAL
We will only keep the personal information we collect about you for as long as is necessary for
to which we are subject. The retention periods we apply take account of:
• legal and regulatory requirements and guidance;
• limitation periods that apply in respect of taking legal action;
• our ability to defend ourselves against legal claims and complaints;
• good practice; and the operational requirements of our business.
We take steps to destroy or de-identify information that we no longer require or as required by
an applicable law.
DOES HOT TECHNOLOGIES LLCUSE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT
HOT TECHNOLOGIES LLC may use or disclose your personal information for the purpose of
informing you about our services, upcoming promotions and events, or other opportunities that
may interest you or as otherwise permitted under applicable privacy laws.
This means under certain privacy laws we do not always need your consent to send you
marketing communications such as our member newsletter. However, where consent is
required under applicable privacy laws, we will ask for this consent separately and clearly. If
you do not want to receive direct marketing communications, you can opt-out at any time by
contacting us using the contact details below or using the opt-out functionality contained in
the electronic message.
If you opt-out of receiving marketing material from us, HOT TECHNOLOGIES LLCmay still contact
you in relation to its ongoing relationship with you.
We will not use or share your Apple Health Data with advertising platforms, data brokers or
HOW DOES HOT TECHNOLOGIES LLCAND DISCLOSE PERSONAL INFORMATION?
• For members; The purposes for which we may use and disclose your personal
information will depend on the services we are providing you. For example, if you have
engaged us to deliver a service, we may disclose information about you to service
providers (including a personal trainer who is a contractor) where this is relevant to our
services. We will use Apple Health Kit Data for customer relationship management
purposes as well as to improve our services including providing tailored services, i.e.
using your data to provide you with information we believe will be of interest to you
(excluding marketing communications) prior to, during, and after your interactions with
• For customers and participants; If you are a customer or participant in an event, we
may disclose your personal information to venues where this is reasonably necessary
for, and relevant to, the delivery of the event. We may use images or audio-visual
recordings which identify you for promotional purposes where you would reasonably
expect this to occur.
• Disclosure to contractors and other service providers; HOT TECHNOLOGIES LLC may
disclose information to third parties we engage in order to provide our services,
including contractors and service providers used for data processing, data analysis,
customer satisfaction surveys, information technology services and support, website
maintenance/development, printing, archiving, mail-outs, and market research. Personal
information may also be shared between related and affiliated companies of HOT
DIGITAL, located in [Kuwait and USA]. Third parties to whom we have disclosed your
personal information may contact you directly to let you know they have collected your
personal information and to give you information about their privacy policies.
• Use and disclosure for administration and management; HOT TECHNOLOGIES LLC will
also use and disclose personal information for a range of administrative, management
and operational purposes. This includes: administering billing and payments and debt
recovery; planning, managing, monitoring and evaluating our services; quality
improvement activities; statistical analysis and reporting; training staff, contractors and
other workers; risk management and management of legal liabilities and claims (for
example, liaising with insurers and legal representatives); responding to enquiries and
complaints regarding our services; obtaining advice from consultants and other
professional advisers; and responding to subpoenas and other legal orders and
• Other uses and disclosures; We may use and disclose your personal information for other
purposes explained at the time of collection (such as in a specific privacy collection
DOES HOT TECHNOLOGIES LLCDISCLOSE YOUR PERSONAL INFORMATION?
HOT TECHNOLOGIES LLCis a global organisation and works with members, service providers,
sponsors and commercial interests across the globe. It is likely that your personal information
will be disclosed to overseas recipients including service providers who may handle, process or
store your personal information on our behalf.
The recipients of such information may be located in Kuwait or the USA.
Entities, which are related entities of HOT DIGITAL, or are otherwise affiliated with HOT
DIGITAL, have operations in Kuwait and the USA. We generally collect personal information
about you in Kuwait or the jurisdiction in which the HOT TECHNOLOGIES LLCaffiliate you are
dealing with is located.
It is likely that your personal information will be transferred outside of the jurisdiction it was
collected. We only ever disclose your personal information outside the jurisdiction it was
collected where we are permitted to do so under applicable privacy laws. Generally, this means
we will take reasonable steps to ensure your personal information is treated securely and in
accordance with applicable privacy laws, including, where relevant, by entering EU standard
contractual clauses (or equivalent measures) with the party outside the European Economic
Area. The EU standard contractual clauses are available here.
There are circumstances where we may disclose your personal information to an overseas
recipient. For example, you have provided your consent, or we are otherwise permitted to do
so under the Kuwait Privacy Principles or other relevant laws.
RESIDENTS IN THE EUROPEAN ECONOMIC AREA
We have described the purposes for which we may use your personal information. If the GDPR
applies to you, we are permitted to process your personal information in this way, in compliance
with the GDPR, by relying on one or more of the following lawful grounds:
you have explicitly agreed to us processing your information for a specific reason;
the processing is necessary to perform the agreement we have with you or to take steps to
enter into an agreement with you;
• the processing is necessary for compliance with a legal obligation we have; or
• the processing is necessary for the purposes of a legitimate interest pursued by us, which
• to prevent fraud;
• to protect our business interests;
• to ensure that complaints are investigated;
• to evaluate, develop or improve our products; or
• to keep our clients informed about relevant products and services, unless you have
indicated at any time that you do not wish us to do so.
If the GDPR applies to you, you have the following additional and specific rights in relation to
your personal information (where applicable):
• Access: you have the right to request a copy of any personal information we hold about
you. Any request for access to or a copy of your personal information must in writing,
and we will endeavour to respond within a reasonable period and in any event within
one month (in compliance with the GDPR).
• Rectification: you have the right to the rectification of your personal data, if you
consider that it is inaccurate.
• Deletion: you have the right to request that we delete personal information that we
process about you, except we are not obliged to do so if we need to retain such personal
information in order to comply with a legal obligation or to establish, exercise or defend
• Restriction: you have the right to erasure of your personal information, if you consider
that we do not have the right to hold it.
• Portability: you have the right to ask us to transfer a copy of your personal information
to you or to another service provider or third party where technically feasible.
• Objection: you have the right to object to your personal information being processed for
a particular purpose or to request that we stop using your information.
Complaint: If you are unhappy with our treatment of your personal information, and you
have contacted us as set out below, you have the right to lodge a complaint with the
local data protection authority.
If you have consented to our processing of your personal information, you have the right to
withdraw, at any time, any consent that you have previously given to us for use of your personal
information. In certain circumstances even if you withdraw your consent, we may still be able
to process your personal information if required or permitted by law or for the purpose of
exercising or defending our legal rights or meeting our legal and regulatory obligations. To make
a request to exercise any of these rights (where applicable) in relation to your personal
information, please contact us using the contact details below.
HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
You are entitled to access your personal information held by HOT TECHNOLOGIES LLC on
request. To request access to your personal information please contact our Privacy Officer using
the contact details set out below. We will take reasonable steps to ensure that the personal
information we collect, use or disclose is accurate, complete and up to date. You can help us to
do this by letting us know if you notice errors or discrepancies in information, we hold about
you and letting us know if your personal details change. However, if you consider any personal
information, we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading
you are entitled to request correction of the information. After receiving a request from you,
we will take reasonable steps to correct your information. We may decline your request to
access or correct your personal information in certain circumstances in accordance with the
Kuwait Privacy Principles. If we do refuse your request, we will provide you with a reason for
our decision and, in the case of a request for correction, we will include a statement with your
personal information about the requested correction.
WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR
You may contact HOT TECHNOLOGIES LLC at any time if you have any questions or concerns
handled. You may make a complaint about privacy to the Privacy Officer at the contact details
set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or
immediate steps, which can be taken to resolve the complaint. We will generally respond to
your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge
receipt of your complaint within a week and endeavour to complete our investigation into your
complaint promptly. We may ask you to provide further information about your complaint and
the outcome you are seeking. We will then typically gather relevant facts, locate and review
relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the
complaint. If the matter is more complex or our investigation may take longer, we will let you
to you. We recommend that you visit our website regularly to keep up to date with any changes.
a notice up on our website).
HOW CAN YOU CONTACT HOT DIGITAL?
The contact details for HOT TECHNOLOGIES LLC are: