Brooks Sports Consumer Health Data Privacy Policy

Brooks Sports, Inc. (“Brooks”) collects and processes personal information when you access and use our websites, mobile apps, and services (collectively, the “Brooks Services”), contact customer support, or otherwise interact with us, including at our stores, at an event, or through our customer feedback programs or customer support channels. Please see our Privacy Policy for more details about our information practices and the privacy rights and choices available to you.

This Consumer Health Data Privacy Policy supplements our general Privacy Policy and applies to personal information that constitutes “Consumer Health Data,” as that term is defined under Washington’s My Health My Data Act and Nevada’s SB 370. We refer to these laws together as the “Consumer Health Data Laws,” and this policy applies only to individuals who are protected by such laws.

We may update this policy from time to time. If we make changes, we will revise the date at the top of the policy. If the changes are material, or if otherwise required by the Consumer Health Data Laws, we will provide you with additional notice of updates, such as by sending you an email.

What Consumer Health Data Does Brooks Collect and from Which Sources Do We Collect It?

Depending on which Brooks Services you use or other offerings you participate in, and how you choose to participate, Brooks may collect personal information that could constitute Consumer Health Data, such as:

• Fitness and health-related information if you enable disclosures to Brooks through wearable fitness tracking integrations we support, including with Strava or other wearable fitness devices you connect using DashLX. The types of data we may receive depend upon the settings you select with Strava and DashLX and can include information such as heart rate, running mileage and duration, precise running routes, and speed.
• Fitness and health-related information we collect, both automatically and directly from you, when you use shoe fit tools we offer, such as Shoe Finder. The types of information we may receive include injury information, physical patterns and rhythms, and other running assessment information.
• Fitness information you provide if you choose to participate in our Run Research surveys or Wear Test program that help us understand and improve the shoes and apparel that we design and offer. The data we may collect includes information about your running habits and other exercise activities, and other information that you choose to include in survey responses.
• Fitness and health-related information we collect if you are selected to visit the Run Research Lab as a research participant, such as biomechanical information including physical patterns and rhythms obtained through technology used in the Lab, which help us understand and improve the shoes and apparel that we design and offer.

How Does Brooks Use Consumer Health Data?

We use Consumer Health Data to provide the products and services you request. For example:

• If you provide fitness information to us through wearable fitness tracking integrations that we support, such as Strava or other wearable fitness devices connected using DashLX, we use such information to provide the Brooks Run Club services you request;
• If you use our shoe fit tools, such as Shoe Finder, we use the information to provide you personalized shoe recommendations; and
• If you participate in our Run Research and/or Wear Test programs, or if you visit the Run Research Lab as a research participant, we use information to improve the shoes and apparel we design.

We may also use Consumer Health Data to prevent, detect, protect against, investigate, and respond to security incidents and fraudulent or other malicious or illegal conduct and to preserve the integrity and security of our products and services.

How Does Brooks Disclose Consumer Health Data?

We may disclose the categories of Consumer Health Data described above to provide you with the products and services you request. For example, we may disclose Consumer Health Data to service providers and vendors (also known as “processors” under the Consumer Health Data Laws) that need access to such data to perform services on our behalf, such as to assist with cloud storage, administering the Brooks Run Club, or to provide us tools we use to communicate with you.

Brooks does not “share” or “sell” Consumer Health Data, as those terms are defined under the Consumer Health Data Laws.

How Can You Exercise Your Rights?

Brooks offers a host of privacy rights and choices to our users, which you can review in our Privacy Policy.

If you are covered by a Consumer Health Data Law, then you have the following additional rights:

• The right to confirm Brooks’ collection of Consumer Health Data about you and to access such data;
• The right to request that Brooks delete Consumer Health Data about you; and
• The right to review and make or request changes to Consumer Health Data about you.

In addition, you can opt out of the collection of Consumer Health Data at any time by ceasing to use the relevant Brooks offerings and contacting us at privacy@brooksrunning.com. Please note that we may take reasonable steps to verify your identity in connection with the request. If we refuse to act on your request, you may appeal such decision by following the instructions we provide in our response.

To stop providing fitness information to Brooks through wearable fitness tracking integrations, please remove Brooks as a recipient in your DashLX or Strava settings. You can also access, update, or correct your Shoe Finder information stored within your online account at any time by logging into your account and updating your preferences. If you participate in our Run Research surveys or Wear Testing program, you may cease such participation at any time.

Under Consumer Health Data Laws, you may also have the right to withdraw consent for certain uses of the Consumer Health Data and to obtain a list of third parties and affiliates to whom your Consumer Health Data has been “sold” or “shared.” Brooks does not engage in such activities. If this changes, we will update this policy and provide you appropriate rights.