LTD Forma Technologies Georgia · Registration Number: 400369828 · Tbilisi, Tskneti Highway 49, Georgia · info@formatech.shop

This Privacy Policy explains how LTD Forma Technologies Georgia (“Forma”, “we”, “us”, or “our”) collects, uses, stores, shares, and protects your personal data when you use the Forma mobile application, visit formatech.shop, connect to a compatible Forma walking pad, participate in workplace activity challenges, or communicate with us.

This Policy applies to the Forma mobile application for iOS and Android, the Forma website, user accounts, workplace challenges, leaderboards, push notifications, customer support, walking-pad connectivity, and any employer or HR dashboard services.

Where an employer or organisation provides access to Forma, that organisation may act as an independent data controller and determine why your data is processed. Forma may process your data on that organisation’s behalf under a data-processing agreement. You should also review your employer’s own privacy notice.

The exact data collected depends on the features you use and how your organisation configures the service.

3.1 Account and Profile Data

3.2 Walking-Pad and Activity Data

Activity metrics are intended for workplace wellness and engagement. They may not be medically accurate and must not be treated as clinical or diagnostic information.

3.3 Device, Technical, and Usage Data

3.4 Communications and Support Data

3.5 Data We Do Not Intentionally Collect

Unless a future feature is clearly presented to you and separately disclosed, Forma does not intentionally collect precise GPS location, contacts, photographs, microphone recordings, payment-card details, Apple Health or HealthKit data, Google Health Connect data, heart rate, blood oxygen, or other body-sensor data through the mobile application.

Depending on circumstances and applicable law — including the Law of Georgia on Personal Data Protection — we rely on one or more of the following legal bases:

You may withdraw consent at any time. Withdrawal does not affect processing that was lawful before withdrawal.

The app requests Bluetooth or nearby-device permission to discover, connect to, and receive activity data from compatible Forma walking pads. This permission is used solely for that purpose and is requested only when needed.

You may disable permissions at any time in your device settings. Doing so may make automatic walking-pad connection and session recording unavailable.

When you participate in a workplace challenge, selected profile and activity information may be visible to other authorised participants in the same organisation, office, team, or challenge. This may include your name or nickname, avatar, points, steps, rank, achievements, and team affiliation.

Employer administrators may view individual or aggregated data depending on the organisation’s configuration and agreement with Forma. The app indicates relevant visibility settings. If you do not want the disclosed information to appear in a leaderboard or report, please contact your administrator or Forma to discuss available options.

Forma automatically calculates points, estimated distance, estimated calories, achievements, and leaderboard positions from recorded activity. These calculations are used solely to operate the service and do not constitute decisions that produce legal or similarly significant effects. Rankings may contain inaccuracies caused by connectivity issues, device limitations, or incorrect use.

We do not sell personal data. We share data only where reasonably necessary with:

The app may include third-party software development kits and services for hosting, authentication, analytics, diagnostics, push notifications, and customer support. These providers may process limited technical or usage information on our behalf.

All third-party SDKs included in the released app are identified in the App Store privacy disclosures and Google Play Data Safety form. Forma uses reasonable contractual and technical safeguards with each provider.

Personal data may be stored or processed in Georgia and in other countries where Forma or its service providers operate. These countries may have different data-protection standards.

Where required, we use appropriate safeguards for international transfers, which may include adequacy decisions, standard contractual clauses, data-processing agreements, encryption, and access controls.

We retain personal data only for as long as necessary for the purposes in this Policy, contractual requirements, security, dispute resolution, and legal obligations. Typical retention periods are:

Data may be deleted, anonymised, or aggregated when no longer needed. Anonymised data that cannot identify a person may be retained for analytics, research, and service improvement.

We apply reasonable technical and organisational measures to protect personal data, including access controls, authentication, encryption in transit, secure hosting, monitoring, backups, staff confidentiality obligations, and vendor reviews.

No internet service is completely secure. You are responsible for keeping your login credentials confidential, securing your device, and promptly notifying us of any suspected unauthorised access.

Subject to applicable law, you may have the right to:

To exercise a right, email info@formatech.shop with the subject line “Privacy Request”. We may verify your identity before acting. Where Forma processes your data solely on behalf of your employer, we may direct the request to that employer or assist it in responding.

If you have a Forma account, you may initiate account deletion directly within the app via Settings > Account > Delete Account. A deletion request may also be submitted to info@formatech.shop or via the account-deletion page at formatech.shop/account-deletion.

After verification, we will delete or anonymise your account and associated personal data unless retention is required by law, necessary for security or dispute resolution, or controlled by an employer with an independent lawful retention obligation. We will explain any material exception where legally permitted.

Uninstalling the app does not automatically delete your account or any server-side data.

The app may send operational notifications such as challenge updates, reminders, achievements, and security alerts. You can manage push notifications through the app or your device settings, although disabling them may reduce functionality.

Optional marketing communications will be sent only where permitted. You may unsubscribe or object at any time. Necessary service and security messages may continue.

Forma is designed for workplace and organisational use and is not directed to children. We do not knowingly permit users under the age of 16 to create independent accounts or knowingly collect their personal data through the app. If we learn that such data was collected without appropriate authorisation, we will take reasonable steps to delete it promptly.

The Forma website may use essential cookies and, with your consent where required, analytics or similar technologies. You can manage non-essential cookies through the consent tool on the website or your browser settings. A separate cookie notice on the website provides additional details where non-essential technologies are active.

We may update this Policy when our service, technology, legal obligations, or data practices change. We will publish the updated version with a revised effective date. For material changes, we will provide an in-app notice, email, or other prominent communication where appropriate.

You may also lodge a complaint with the Personal Data Protection Service of Georgia or any other competent data-protection authority or court under applicable law.