This Privacy Policy explains how Powersoft Computer Solutions Ltd ("Powersoft", "we", "us", "our") collects, uses, stores, shares, and protects personal data when you use the PowerSoft Gym Demo Application (the "App").
This policy applies solely to the PowerSoft Gym Demo Application and related backend services, unless stated otherwise. The App is a gym-oriented demo and evaluation application used to present features such as user accounts, classes, bookings, cancellations, waitlists, and related support functionality.
If a customer later launches a separate production or white-label version of the app, that production version may be subject to a different privacy policy issued for that specific deployment.
1. Data Controller
Powersoft Computer Solutions Ltd Powersoft Tower Leoforos Larnakos 39-41 1046 Nicosia Cyprus
General privacy contact: admin@powersoft.com.cy Data Protection Officer (DPO): Neophytos Panayiotou DPO email: np@powersoft.com.cy Telephone: +357 22 410 000
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us using the details above.
2. Categories of Personal Data We Collect
Depending on how you use the App, we may collect the following categories of personal data:
A. Data you provide directly
- first name and last name;
- email address;
- phone number;
- login credentials or authentication-related information;
- profile information you choose to provide;
- support or contact messages you send to us;
- information you submit when creating, changing, or cancelling a booking.
B. Data generated through use of the App
- class bookings;
- booking history;
- cancellations;
- waitlist activity;
- attendance-related records, where enabled;
- account settings and preferences;
- tenant or gym affiliation where relevant to the service.
C. Technical, device, and usage data
- IP address;
- device type;
- mobile operating system;
- app version;
- language and region settings;
- date and time of access;
- diagnostic, crash, and error logs;
- system logs and maintenance data;
- information about interactions with the App required for operation, security, troubleshooting, and service improvement.
D. Data received through connected business systems
Where the App is connected to PowerSoft backend systems or integrated business systems, we may receive account, membership, booking, or other service-related information necessary to provide the App’s functionality.
Unless otherwise specified, data requested by the App may be mandatory where needed to provide the service. If required data is not provided, some parts of the App may not function properly.
You are responsible for ensuring that any third-party personal data you provide to us has been shared lawfully and with appropriate authorization.
3. Data We Do Not Intentionally Collect in the Current App Setup
Under the current app setup, we do not intentionally collect any of the following unless the App is changed and this Privacy Policy is updated accordingly:
- precise location data;
- contacts or address book data;
- camera images, photo library content, or microphone recordings;
- payment card or bank account information;
- health or fitness sensor data;
- special category data, unless explicitly required and lawfully collected for a clearly stated purpose.
Please do not submit medical or other sensitive information through the App unless specifically requested by us for a clearly disclosed and lawful reason.
4. Purposes of Processing
We process personal data in order to provide the App and for purposes including:
- creating and managing user accounts;
- authenticating users and securing access to the App;
- enabling users to browse classes and make, manage, or cancel bookings;
- operating waitlists and attendance-related workflows;
- responding to support requests and communicating with users;
- maintaining, monitoring, troubleshooting, and improving the App;
- protecting the App, backend systems, and users against misuse, fraud, abuse, or unauthorized access;
- complying with legal, regulatory, and contractual obligations;
- establishing, exercising, or defending legal claims.
We do not sell personal data.
We do not use personal data collected through the App for cross-app tracking or third-party advertising unless this is expressly disclosed and the App, this policy, and the relevant app-store disclosures are updated accordingly.
5. Legal Bases for Processing
We may process personal data where one or more of the following legal bases applies:
- you have given consent for one or more specific purposes;
- processing is necessary for the performance of an agreement with you or for steps requested before entering into an agreement;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary for the purposes of our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms.
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6. How We Process and Protect Personal Data
We process personal data using computers, mobile services, databases, and IT-enabled systems, following organizational and technical procedures strictly related to the purposes described in this policy.
We take appropriate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures may include, where appropriate:
- authenticated access controls;
- role-based access restrictions;
- encrypted transport over HTTPS/TLS;
- tenant-level logical data separation;
- server-side credential handling;
- logging and monitoring;
- secure hosting and infrastructure controls;
- review and maintenance of security practices.
No method of transmission over the internet or method of electronic storage is completely secure. While we seek to protect personal data, we cannot guarantee absolute security.
7. Where Data Is Processed
Personal data is processed at our operating offices and in other locations where the parties involved in the processing are located, including infrastructure and hosting environments used to operate the App and related services.
Depending on your location and the services used, personal data may be transferred to and processed in countries other than your own. Where required, we take reasonable steps to ensure that such transfers are subject to appropriate safeguards and protections under applicable law.
8. Who May Access or Receive Personal Data
Personal data may be accessible to:
- authorized employees, contractors, and personnel involved in administration, support, legal, security, or system administration;
- third-party technical service providers, hosting providers, IT companies, cloud infrastructure providers, communications providers, and similar service providers acting on our behalf;
- integrated backend or business systems where necessary to provide App functionality;
- public authorities, regulators, courts, or law enforcement where disclosure is required by law or is necessary to protect rights, safety, systems, or legal claims.
Where third parties process personal data on our behalf, we expect them to provide an appropriate level of protection for that data consistent with applicable law and our contractual requirements.
We do not publish or publicly disclose personal data collected through the App except where required by law or authorized by the user.
9. Data Retention
Personal data is retained for as long as required for the purposes for which it was collected.
In general:
- personal data processed for account creation, bookings, and App functionality is retained for as long as needed to provide those services;
- personal data processed for our legitimate interests is retained only as long as necessary to fulfill those interests;
- we may retain data for a longer period where required by law, to comply with legal obligations, for security, fraud prevention, dispute resolution, recordkeeping, or the establishment, exercise, or defense of legal claims;
- once retention is no longer necessary, personal data will be deleted, anonymized, or securely restricted.
Because some records may be required for legal, audit, security, or operational reasons, immediate deletion of all associated data may not always be possible.
10. Account Deletion and Data Deletion Requests
If you have created an account in the App, you may request deletion of your account and associated personal data by contacting us at:
- admin@powersoft.com.cy, or
- np@powersoft.com.cy
Where available, you may also use any account deletion option provided within the App or through an associated web page.
When we receive a valid deletion request, we will delete the account and associated personal data unless we are required or permitted to retain certain information for legitimate reasons, including security, fraud prevention, legal compliance, dispute resolution, or recordkeeping.
Temporary deactivation, suspension, or disabling of an account is not the same as deletion.
11. Your Rights
Subject to applicable law, you may have the right to:
- withdraw consent at any time;
- object to processing of your personal data;
- access your personal data and obtain a copy of it;
- verify and request correction of inaccurate or incomplete data;
- request restriction of processing;
- request deletion of your personal data;
- receive your personal data in a structured, commonly used, and machine-readable format and request transfer to another controller where applicable;
- lodge a complaint with a competent data protection authority.
Requests may be exercised free of charge by contacting us using the details in this policy. We may need to verify your identity before responding.
We aim to respond as early as possible and, where applicable, within the time required by law.
12. Complaint to the Cyprus Supervisory Authority
If you believe your personal data has been processed unlawfully, you may lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus:
Office of the Commissioner for Personal Data Protection Iasonos 1 1082 Nicosia Cyprus
Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus Telephone: +357 22 818 456 Fax: +357 22 304 565 Email: commissioner@dataprotection.gov.cy
You may also contact your local supervisory authority where applicable.
13. Children’s Privacy
The App is not directed to children under the age required by applicable law for independent consent in their jurisdiction.
We do not knowingly collect personal data from children in violation of applicable law. If you believe that a child has provided personal data improperly, please contact us so that we can review the matter and take appropriate action.
14. Automated Decision-Making
We do not intentionally use solely automated decision-making that produces legal effects or similarly significant effects on users in the ordinary operation of this App.
If this changes for a specific feature or service, we will update this Privacy Policy and provide any additional notices required by law.
15. Additional Information About Data Collection and Processing
Personal data may be used for legal purposes by Powersoft in court proceedings or in the stages leading to possible legal action arising from improper use of the App or related services.
For operation and maintenance purposes, the App and related services may collect system logs and other technical data, such as IP address and event logs.
More details concerning the collection or processing of personal data may be requested from us at any time using the contact details provided in this policy.
16. Changes to This Privacy Policy
We reserve the right to make changes to this Privacy Policy at any time by publishing the updated version on the page where this policy is made available and, where appropriate, by notifying users through the App or other contact details available to us.
If changes affect processing carried out on the basis of consent, we will obtain new consent where required by law.
You should review this Privacy Policy periodically to remain informed about how we protect personal data.
17. Contact
Powersoft Computer Solutions Ltd Powersoft Tower Leoforos Larnakos 39-41 1046 Nicosia Cyprus
Email: admin@powersoft.com.cy DPO: Neophytos Panayiotou DPO Email: np@powersoft.com.cy Telephone: +357 22 410 000