Privacy Policy

1. INTRODUCTION 

We, 10XU Limited Limited, trading as MVMNT, take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).

This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.

We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO/us using the contact information in section 15 of this privacy notice.

‍

2. WHY WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information from you for one of the following purposes:

  • To manage communications between you and us
  • Where we need to perform the contract, we have entered into with you
  • To provide you with information you have requested or which we may feel may be of interest to you 
  • To ensure the safe operation of our website and to monitor the performance of our website
  • To develop new products, services, features, and functionality
  • To communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and advertising purposes
  • To respond to your queries
  • To help improve our services
  • To process your transactions and manage your orders
  • To provide and manage community features, including user interactions and content moderation
  • To facilitate live competitions and display leaderboard rankings.

‍

The Purpose Matrix at the end of this policy gives details of what types of data we may store about you.

3. WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT? 

We may collect, use, store and transfer the following kinds of personal information about you:

  • Information you give us directly. This is information you consent to giving us about you by corresponding with us (for example, by email or chat or using our helpdesk) or by filling in your contact details on a web-based form, so we can send you a link to the App. It includes information you provide when you share information on our social media pages and when you report a problem with the App.
  • Information you provide through the App. This is information you provide about yourself, including fitness level, and personal characteristics in order to make your use of the App more effective.
  • Health Data - Information you provide to us by linking a third party device to your use of the App, such as a heart rate monitor.
  • Device Data. Your Device has an electronic signature which will notify us of its characteristics. This may include a device specific advertising identifier (IDFA,IDFV,AAID,IP & Android ID)
  • Usage Data. We will collect, store and process all interactions that take place with the App on your Device, and on our servers, which may include both the data we collect through your use of the App, competition participation and also health data collected through a third party device linked to the App.
  • Survey and Feedback Data. You may choose to respond to surveys and feedback requests on the App. We will collect store and process any information you provide us.

Community Data. Information you create or share through community features of the App, including posts, comments, reactions, and any communications or content you submit through those features. We may also collect information relating to moderation activities, including reports, content reviews, content removals and account restrictions as required.

4. LAWFUL BASIS OF PROCESSING INFORMATION

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where: 

  • The data subject (you) has given consent to the processing activity taking place.
  • If the processing is necessary for the performance of a contract 
  • If the processing is necessary for compliance with a legal obligation to which the controller is subject
  • If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners
  • If processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
  • If processing is necessary for reasons of substantial public interest

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:

The purpose test – to identify the legitimate interest

Necessity test – to consider if the processing is necessary for the purpose identified

Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment. Where you have given consent for processing in relation to the processing of data, you have the right to withdraw this consent at any time writing to support@mvmnt.com but this will not affect the lawfulness of processing based on consent before its withdrawal.

‍

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations, and professional obligations that we are subject to. All personal information collected has a defined retention period. If you would like to find out how long your information is being retained, please see "additional information", section 14 of this notice.

6. TRANSFERS TO THIRD PARTIES

We may disclose information about you to any of our employees, officers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy notice.  

In addition, we may disclose your personal information:

  • To the extent that we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • In order to establish, exercise or defend our legal rights;
  • To the purchaser, or prospective purchaser, of any business or asset that we are, or are contemplating, selling; and,
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
  • Except as provided in this privacy notice, we will not provide your information to third parties. For the avoidance of doubt, we will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.

7. SECURITY OF YOUR PERSONAL INFORMATION

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

  • We hold your personal information in our database and on our secure servers, or on those allocated to us by our service providers which are protected by both hardware and software firewalls. 
  • We password protect electronic information.
  • We store papers in lockable cabinets in our offices when not being actively used.
  • We ensure that our staff, volunteers, agents and contractors are aware of their privacy and data security obligations.
  • We limit access to your personal information to people who have a need to know.

We have in place procedures to deal with any suspected personal data breach. We will notify the Information Commissioner’s Office (ICO) of a breach (or suspected breach) where we are required to do so. We will also contact you directly if the breach (or suspected breach) results in a high risk to your privacy.

‍

 8. CHILDREN'S INFORMATION

We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay. 

‍

9. YOUR RIGHTS

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under General Data Protection Regulation are:

  • Right to Object
  • Right of Access
  • Right to be informed
  • Right to Rectification
  • Right to Erasure
  • Right to Restrict Processing
  • Right to Data Portability

‍

  • The right to object

You can exercise this right if

  • Processing relies on legitimate interest
  • Processing is for scientific or historical research
  • Processing includes automated decision making and profiling
  • Processing is for direct marketing purposes
  • The right of access
    • You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge. 
    • We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you. 
  • The right to be informed
  • We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right. 
  • The right of rectification
    • If you believe the personal data, we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made. 
  • The right to erasure
    • If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.  

‍

  • The right to restrict processing
    • You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
    • Processing is unlawful
    • We no longer need the personal data, but it is required for a legal process
    • You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made. 
    • If you are exercising your right to rectification
  • The right to data portability
    • You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
    • Processing is based on consent
    • Processing is by automated means (i.e. not paper based)
    • Processing is necessary for the fulfilment of a contractual obligation

‍

If you have any question about these rights, please see "additional information", section 15 of this notice.

‍

10. CONSENT

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

‍

11. FAILURE TO PROVIDE PERSONAL INFORMATION

Where we need to collect personal data by law or in order to process your instructions or perform a contract, we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

‍

12. AUTOMATED DECISION MAKING

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

‍

13. TRANSFER YOUR DATA OUTSIDE THE UK

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).

We may share personal information to third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws. 

Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

  • Standard Contractual Clauses with the UK Addendum
  • International Data Transfer Agreement
  • Binding Corporate Rules
  • An exception as defined in Article 49 of the EU GDPR. For more information about transfers and safeguarding measures, please contact us using the information in section 16.

For more information about transfers and safeguarding measures, please contact us using the information in section 14.

‍

14. ADDITIONAL INFORMATION

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy notice or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on support@mvmnt.com

15. RIGHT TO COMPLAINT

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact us via email on: support@mvmnt.com

Alternatively, you can contact us:

By Post: 10XU Limited, The Carriage House, Mill Street, Maidstone, ME15 6YE

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By Website: Click Here

By Email: Click Here

By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate) 

‍

16. NOTICE REVIEW AND AMENDMENTS

We keep this Notice under regular review. This Notice was last updated on 09/06/2026.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

‍

17. STATE PRIVACY RIGHTS (INCLUDING CALIFORNIA)

Certain US state laws (for example, the California Consumer Privacy Act, as amended (CCPA/CPRA), and similar state laws) may give residents of those states additional rights in relation to their personal information. These may include the right to: (a) request access to the personal information we hold about you; (b) request that we delete certain personal information; (c) request correction of inaccurate personal information; (d) request information about how we collect, use and disclose your personal information; and (e) in some cases, limit the use and disclosure of “sensitive” personal information. You may also have the right not to receive discriminatory treatment for exercising these rights.

To exercise any of these rights (where available), please contact us using the details set out in the “Contact details” section above and state that your request relates to your rights under applicable US state privacy laws. We may need to verify your identity before responding. We will respond to your request within the time period required by applicable law.

‍

18. SALE OR SHARING OF PERSONAL INFORMATION FOR ADVERTISING

We do not sell your personal data in the conventional sense (for money). If and to the extent our use of certain cookies, SDKs or similar technologies is treated under applicable US state law as a “sale” or “sharing” of personal information for cross‑context behavioural advertising, you may have the right to opt out of such sale or sharing. Where required by law, we will provide an in‑App or online mechanism (for example, a “Do Not Sell or Share My Personal Information” link or equivalent preference centre) that you can use to exercise this right, and we will honour any valid browser‑ or device‑based opt‑out preference signals that we are legally required to recognise.

‍

19. US HEALTH AND SECURITY BREACH NOTIFICATION

If we are required under US federal or state law to notify you or any regulator about a security breach involving certain categories of personal data (including Health Data), we will do so in the manner and within the time limits required by those laws. This may include notification to the Federal Trade Commission and/or state authorities where the data falls within the scope of US health‑related breach notification rules for consumer health applications.

Account Creation & Login

  • Purpose / Activity: To create an account with us via a login.
  • Type of Data: You will provide us with your name, an email address, and your date of birth.
  • Lawful Basis for Processing: Your consent.

App Download Link Request

  • Purpose / Activity: To send you a link to download the App.
  • Type of Data: You may have to supply us with your name and email address on a web-based form.
  • Lawful Basis for Processing: Your consent.

App Installation & Registration

  • Purpose / Activity: To install the App, manage payments, and register you as a new App user.
  • Type of Data: This process is managed by the operator of the App Store. We do not have any visibility of or access to any of your personal data processed in this way. If you subsequently use a login to access the App, we will be able to link your app and any Usage Data with you using your Login Data.
  • Lawful Basis for Processing: Your consent.

Installation Attribution Tracking

  • Purpose / Activity: To track your app installation source.
  • Type of Data: We may have access to your IDFA in addition to other data, which may allow us to attach certain attributes to your membership.
  • Lawful Basis for Processing: Your consent.

App Usage Tracking & Feedback

  • Purpose / Activity: To track your use of the App and provide you with feedback about your usage.
  • Type of Data: Profile Data, Usage Data, and Health Data.
  • Lawful Basis for Processing: To perform a contract we have with you; Consent.

Partner Campaigns & Offers

  • Purpose / Activity: Partner campaigns. We may occasionally partner with brands and send you relevant offers.
  • Type of Data: If you have a login or we otherwise have your email address, we will contact you via your email address. In certain circumstances, we may also send information to the device you have logged in to.
  • Lawful Basis for Processing: Your consent.

Relationship Management & Core Updates

  • Purpose / Activity: To manage our relationship with you including notifying you of changes to the App, new features, features that you may not have used or been aware of, usage data and statistics, and changes to our Terms of Use.
  • Type of Data: If you have a login or we otherwise have your email address, we will contact you via your email address. In certain circumstances, we may also send information to the device you have logged in to.
  • Lawful Basis for Processing:
    • We will do this in order to be able to perform a contract with you.
    • In some cases, it will be necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/Services).
    • In other cases, it will be necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).

Subscription Renewals & Reminders

  • Purpose / Activity: To remind you when your subscription is coming to an end, or to prompt you to renew or upgrade your subscription (for example, if it has expired, or if you cease to be associated with the partner organisation or employer through which you originally obtained your subscription).
  • Type of Data: If you have a login or we otherwise have your email address, we will contact you via your email address. In certain circumstances, we also may send information to the device you have logged in to.
  • Lawful Basis for Processing: Our legitimate interests (to market goods and services similar to those already supplied to you).

Surveys, Enquiries, & Communications

  • Purpose / Activity: To enable you to complete a survey, and to respond to enquiries and other communications you direct to us including through our Website.
  • Type of Data: If you have a login, we may contact you via your email address or your device. Communication data.
  • Lawful Basis for Processing: Your consent; Performance of a contract with you; Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business).

Troubleshooting & Administration

  • Purpose / Activity: To identify, diagnose, and fix any problems you may have with using the App, and to administer and protect our business and this App (including troubleshooting, data analysis, and system testing).
  • Type of Data: We will generally use your Login Data or Contact Data. Normally we would not require any personal data to do this.
  • Lawful Basis for Processing:
    • To perform a contract with you (to remedy issues).
    • Your consent (additional communications data).
    • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).

Data Depersonalisation

  • Purpose / Activity: To depersonalise any data, in order to continue to be able to use the data for our internal business purposes, and for marketing and fundraising purposes.
  • Type of Data: Usage Data, Profile Data, and Health Data.
  • Lawful Basis for Processing:
    • Consent, to the depersonalisation.
    • Legitimate interests, to continue to use such depersonalised data for analysing and refining our products and services, and for marketing and fundraising purposes.

Community Features & Moderation

  • Purpose / Activity: To provide and manage community features within the App, including enabling users to create posts, comments and reactions, interact with other users, report content or users, and for moderation and enforcement of community standards.
  • Type of Data: Usage Data, Profile Data, and Health Data.
  • Lawful Basis for Processing: To perform a contract.

‍