Privacy policy

EFFECTIVE: JUNE 20, 2024

This Privacy Policy (the “Policy”) is designed to help you understand how we generate, collect, use, transfer, and may delete information on our users and customers and “Personal Data” you decide to share, and help you make informed decisions when providing Personal Data or using to any of the websites, services, and mobile apps owned or offered by TRX and its subsidiaries or affiliates in the United States and around the world (collectively, “TRX”). This Policy also serves as an Anti-Spam Policy in jurisdictions where such policies are required to be posted. Certain parts of this Policy may or may not apply to you, which we make clear in the relevant sections. This Policy must be read in conjunction with our Terms of Use, to understand our commitment to responsible and secure data collection, storage, transfer, and deletion practices.

Any question, a desire to opt-out, or to report any issue, please contact privacy@trxtraining.com or our customer service line. You may also contact us by mail at:

TRX Training
1110 S Federal Hwy
Delray Beach, FL 33483, USA

You must provide sufficient information to verify your identity, and describe your request with sufficient detail that allows us to properly respond to it.  IF YOU ARE AN EU OR UK RESIDENT, PLEASE SEE BELOW FOR AN EXPLANATION OF THE LEGAL BASES ON WHICH WE RELY TO PROCESS YOUR PERSONAL DATA.  If you live in the European Union, United Kingdom or Switzerland and efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the ICDR-AAA.

When we refer to “you” in this Policy we mean any individual who is a visitor, a registered or unregistered guest of any of our websites or services, attends any of our digital or in-person events, who holds an account or creates a profile for any service or uses them, who receives any survey, questionnaire, application, or other form of request from TRX via email or any other way, or any individual who comments on, reviews, or who otherwise posts any content generated by the individual on any of our services or social media networks. “Personal Data” also known as “Covered Information” as used in this Policy means information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your first or last name, a home or physical address, an email address, a phone number, a social security number, an identifier that allows a person to be contacted physically or online, you precise geographic location. TRX can create anonymous data from Personal Data by excluding personally identifiable data components that makes the data personally identifiable to you, through one or more secure methods of data anonymization. Our use of anonymized data is not subject to this Policy. 

You request any of the following:

  • View or access what Personal Data 

  • Change or correct any Personal Data 

  • Request us to disclose or delete any Personal Data 

  • Express any concern you have 

If you are a resident of the State of California, under the California Consumer Privacy Act of 2018 (the “CCPA”), we will disclose at a minimum about you: (a) The categories collected, (b) The sources, (c) Our purpose, (d) The third parties with whom we share any data, and (e) The specific pieces collected. TRX will not (i) Deny you goods or services, (ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (iii) Provide you a different level or quality of goods or services, or (iv) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services as a result of any privacy demand. 

EU and UK Residents

If you are a resident of a member nation of the European Union or the United Kingdom, we wish to confirm for you the legal basis on which we process your Personal Data as required by the European General Data Protection Regulation (“EU GDPR”) and the United Kingdom General Data Protection Regulation (“UK GDPR”), together the “GDPR laws”. We only use and process for the following lawful reasons:

  • When it is necessary to process a transaction on your behalf or to perform under a contract, including to enter into a contract with you.

  • When we have a legitimate business interest.  

  • When we receive your prior consent. 

  • When it is necessary for compliance with a legal obligation to which we are subject. 

  • When it is necessary in order to protect vital interests. For example, if we have to recall a product for safety reasons or if there is an emergency during the performance of our Services to you and you are not able to give your consent.

As a resident of a member nation of the European Union or the United Kingdom, we also provide you with the following rights as required by the GDPR Laws:

  • Right to Access of Personal Data

  • Right to Receive Personal Data

  • Right to Request Restriction of the Processing of Personal Data and Right to Withdraw Consent

  • Right to Object to Processing

  • Right to Have Corrections Made to Personal Data

  • Right to Deletion of Personal Data

TRX Privacy Shield Information for EU/UK/Swiss Residents

If you reside in a member country of the EU, the UK or Switzerland, TRX does self-certify that it complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set out by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries and Switzerland.  TRX has self-certified that it adheres to the Privacy Shield Principles of notice, choice, onward transfer (including our Data Processors or other third parties as permitted in this Policy), security, data integrity, access, and enforcement. Under the Privacy Shield’s “Onward Transfer Principle”, we may remain liable for the processing of Personal Data of EU, UK or Swiss residents that we transfer to our Data Processors or other third party service providers or agents. In certain situations, we may be also required to disclose Personal Data in order to comply with lawful requests from public authorities, including to meet national security or law enforcement purposes. To the extent human resources data is transferred by us from the EU, UK or Switzerland in the context of an employment relationship, TRX commits to cooperate with European Union data protection authorities (DPAs), the United Kingdom Information Commissioner (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to the transfer of such human resources data transferred from the EU, UK and/or Switzerland. In order to ensure compliance with the Privacy Shield, we must designate an independent recourse mechanism, so that the complaints or disputes of residents of the EU, UK and Switzerland may be investigated and resolved at no cost to such residents. We have selected the International Centre for Dispute Resolution, which is the international division of the American Arbitration Association (“ICDR-AAA”), to resolve any disputes or complaints that residents of the EU, UK and Switzerland may raise about this Policy or our violation of applicable laws, rules, or regulations in the handling of Personal Data. For more information on the ICDR-AAA and how to file complaints, please visit: https://www.icdr.org/privacyshield. We also would like to inform you that if your dispute or complaint is not resolved either directly with us or through the ICDR-AAA, then under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Additionally, as required by the Privacy Shield, we must inform all residents of the EU, UK and Switzerland that we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

TRX Anti-Spam Efforts

In accordance with Canadian Anti-Spam Legislation (CASL) S.C. 2010, c. 23, the process of account set-up is considered an express opt-in of solicitation efforts and users understand the identity of senders is inherently made clear via the branded services offered. TRX endeavors to offer in Canada single-click opt-out modes to unsubscribe to any promotional message. Such procedure is also in effect in Europe under Directive 2002/58/EC and 2003/58/EC – Amended 68/151/EEC. Such procedure is also in effect in Europe under the Spam Act of 2003. The user also acknowledges that it has been notified in advance that since TRX is an international corporation, recipients in Australia may receive Commercial Communications outside of the hours set by the Spam Act.

Section 1. COLLECTION

We may collect Personal Data in any situation where you voluntarily provide such Personal Data which include:

  • If you register and create a user account and provide information about yourself such as your name, location, email, and create a personalized username and password as well as provide an image or avatar. Payment to TRX may require billing details, a name, address, email address and financial information.

  • At log in, we may collect additional information (which may include achievements, milestones or other indications related to your activity in our systems) and add to your profile. As part of a collective class session, TRX may identify you and therefore you may not be anonymous in that setting. 

  • Attendance, purchase history, events, products or other services can also be added to your user profile. You may also give additional information such as fitness, physical activity, and health-related information. This information may  determine your eligibility to participate in training programs that may be accessed through the corresponding TRX app. We may also seek voluntary disclosure of measurements, height, weight and age as part of the services. Your calories burned, distance traveled and heart rate may be obtained from your mobile device or other data from the Apple HealthKit API or other such external device with your approval and permission.

  • When you choose to voluntarily participate in promotions, contests, sweepstakes, surveys, testimonial processes, or loyalty programs or when you request to receive user or technical support or otherwise communicate with us, data may be added to your personal data. Accessing the services from a computer or mobile phone, tablet, or other devices, may result in collection of certain identifying information of your device. Device ID information may be collected in order to determine the aggregate number of unique devices using a particular service, to track total usage, analyze data, to avoid misuse of a personal subscription model. 

  • Visitors or unregistered guest users are only required to provide as much information as is reasonably necessary to complete any transaction which they have initiated through the services. Unregistered guest information will be stored and may be used for purposes outside of completing the transaction for which it was provided, such as communicating specials, new products or new services (unless you opt out of such communications).

  • We may capture image, name, likeness and voice if you participate in any of our live in-person or digital live or on-demand classes or events and/or call our support or sales team members. When you disclose public information about yourself on TRX’s blogs, social media pages, product or service review pages, messages, community forums, and within video chat sessions, TRX may collect the information. Content considered “public” will not be subject to the privacy protections provided in this Policy. We may use browser session data to manage your shopping cart. We may collect data through cookies and similar files. You can change the browser settings to prevent this or, if you are resident in the EU or the UK, you will be given the option whether or not to allow these cookies. If you arrive from an external source (such as “refer a friend” promotions or “ambassador program”), we may record information about the source that referred you to us.  

  • Our Services may provide links to third-party websites that are outside of our control and not covered by the Policy (e.g. Instagram, Facebook, Twitter, etc.)

Section 2. USE 

TRX has not used any of the information it has collected about its users, clients, and visitors for any non-internal purpose related to its services. It has not sold or provided to third-parties for profit any data. While under this Policy such can be possible, it has not happened and is not contemplated now. Whether you access any of the Services either as a visitor or unregistered guest, or as a registered user, your data is used to generally manage your user information and accounts, respond to questions, comments or other requests, provide the transaction, product or service, allow you to register or give you access to services, including products, content, or other services you may purchase or request or personalize your services. If you choose to create a User Profile, we may additionally use your Personal Data to contact you to remind you about products or Services which remain in your shopping cart or to obtain product or Service feedback or reviews.

Other ways we may use your Personal Data include:

  • Internally to provide and improve the Services, for marketing purposes, develop new products and Services, ensure quality control, or other legitimate business interests (including fraud prevention or compliance with legal obligations). 

  • Share Personal Data with our select business partners with whom we are engaging in collaborative co-branded promotional or marketing programs. 

  • To provide you with offers, products and services that may be of interest, including new content or services.

  • To create non-identifiable information. 

  • To conduct surveys on our behalf to help us better serve individuals by learning more about their needs and the quality of the products and services we provide.

  • To issue periodic emails, newsletters, mailings, text messages from us with information on TRX’s or our business partners’ products and services or upcoming special offers/events that we believe may be of interest. We may require your consent to send these communications to you as required by applicable laws.

  • To process information on our behalf (collectively, “Data Processors”). For example, if we need to ship something to you, we must share your name and address with a shipping company. We require that these Data Processors agree to process Personal Data based on our instructions and in compliance with prevailing privacy laws and any other appropriate confidentiality and security measures.

  • For access by third party applications, such as extensions through services. 

  • Share Personal Data when we have a good faith belief that access, use, or disclosure of such Data is reasonably necessary to satisfy any applicable law, rule, regulation, or enforceable governmental or administrative request, enforce our Terms of Use, including investigation of potential violations, detect, prevent, or address fraud, security or technical issues, or protect against harm to the rights, property or safety of TRX, our users, or the public (collectively, “Legal Requirements”).

  • As part of any corporate process linked with business changes and subject to confidentiality agreement. 

  • To send messages via SMS or other communication.

Section 3. MINOR DATA 

We do not knowingly collect information from or about minors nor willfully enter into any contractual obligation. If you become aware that a minor has provided us with Personal Data without parental consent, please contact us at privacy@trxtraining.com  or mailing address provided above. If we become aware that a minor has provided us with Personal Data without parental consent, we will take immediate steps to remove such Personal Data and cancel the child’s account without notice. To confirm, under GDPR, we do not process the Personal Data of any child who is below the age of 16 years unless we receive the express consent of the parent or authorized guardian of the child.