BIOTIME Technogym / Health Data Notice

1. Purpose

BIOTIME uses connected Technogym equipment and digital services as part of its training and onboarding experience. This Notice explains which information is intended to remain within the Technogym environment and how BIOTIME may interact with that environment.

2. Separate Technogym Account

Members are required to create their own Technogym account where necessary to use BIOTIME's connected Technogym equipment and services. The Member creates that account through the Technogym process and separately accepts Technogym's applicable terms and privacy information. Acceptance of BIOTIME documents is not acceptance of Technogym's separate terms.

3. Independent Use of Technogym Account

A Technogym account is not limited to BIOTIME. It may be used by the Member with compatible Technogym products, facilities or services outside BIOTIME, subject to Technogym's own arrangements.

4. Information Intended to Remain in Technogym

BIOTIME's intended architecture is that fitness and health-related information generated through Technogym equipment and services remains within the Technogym ecosystem and is not replicated into BIOTIME's proprietary Member database. This may include Checkup/InBody or body-composition information, pre-exercise or health-screening information, fitness assessments, strength and cardio performance, workout history, training settings, equipment personalization and other Technogym-generated fitness metrics.

5. BIOTIME's Proprietary Member System

BIOTIME's own Member systems are intended principally to process operational Membership information such as name, email address, mobile number, Membership identifiers and status, payment or transaction identifiers, appointments, preferred language, LINE linkage, access identifiers and necessary operational communications or records. BIOTIME does not intend to create a parallel proprietary health-data repository containing Technogym fitness datasets.

6. Mywellness and BIOTIME Personnel

Mywellness is part of the Technogym environment used to support Member assistance and training operations. Authorized BIOTIME trainers or personnel may access, input, review or use information within Technogym/Mywellness where reasonably necessary for onboarding, pre-exercise screening, training configuration, equipment personalization, Member assistance, safety or related fitness services.

7. Processing Does Not Require Local Copying

The fact that information remains hosted in the Technogym environment does not necessarily mean that BIOTIME personnel never process it. Viewing, entering, reviewing or using information in Mywellness may constitute processing under applicable data-protection law even where BIOTIME does not copy that information into its own database.

8. Health and Sensitive Personal Data

Health information and certain other categories may constitute sensitive personal data under Thai law. Where BIOTIME personnel process sensitive information within the Technogym environment, BIOTIME will apply the legal basis, access restrictions, confidentiality and safeguards required under applicable law and the relevant Technogym contractual arrangements.

9. Pre-Exercise Screening

Applicable pre-exercise or health screening is intended to be conducted within the Technogym/Mywellness environment. Members should answer screening questions accurately. The purpose is fitness safety and appropriate service delivery, not medical diagnosis.

10. Medical Clearance

Where screening information or other circumstances reasonably indicate an elevated exercise risk, BIOTIME may require appropriate medical clearance before allowing or continuing particular activities. BIOTIME trainers do not diagnose medical conditions merely by conducting screening or assisting with Technogym services.

11. Checkup and Body-Composition Information

Where a Member uses Technogym Checkup, InBody or other compatible assessment functionality, resulting measurements and scores are intended to be handled within the Technogym ecosystem and made available through the applicable Technogym services. BIOTIME does not intend to replicate those measurements into its proprietary Member database.

12. Connected Training Equipment

Connected strength, cardio and other Technogym equipment may use the Member's Technogym profile to personalize settings, record training or support progression. Those equipment-generated data are intended to remain within the Technogym ecosystem rather than being copied into BIOTIME's proprietary database.

13. Emergency Contact

Where supported by Technogym/Mywellness, a Member may optionally provide an emergency contact. The information should be limited to what is reasonably necessary for emergency purposes. BIOTIME does not intend to duplicate that emergency-contact record into its proprietary Member database unless a separate operational need and lawful basis are established.

14. Access Controls

Access by BIOTIME personnel to Technogym/Mywellness information should be limited to authorized personnel who need the information for legitimate Member-service, training, safety or operational purposes. BIOTIME will apply role-based access, confidentiality obligations and other reasonable safeguards appropriate to the information and available system controls.

15. No Marketing Use of Health Data by Default

BIOTIME does not intend to use Technogym health, body-composition, screening or workout data to create marketing profiles or personalize commercial offers merely because BIOTIME personnel can access those data for training assistance. Any materially different marketing use would require a separate legal-basis, transparency and sensitive-data assessment.

16. No BIOTIME Sale of Health Data

BIOTIME does not intend to sell Technogym health, fitness, screening or workout data or make such data available to unrelated third parties for their independent advertising purposes.

17. Technogym's Own Processing

Technogym processes information within its ecosystem under the terms, privacy notices, technical architecture and contractual arrangements applicable to its services. Members should review the Technogym Thailand privacy policy and terms presented through the Technogym service. BIOTIME does not replace those Technogym notices.

18. Controller and Processor Roles

The precise legal roles of Amintara Group Co., Ltd., Technogym entities and any relevant service providers depend on the actual contracts, system configuration and purposes of processing. BIOTIME will maintain and update its privacy documentation and contractual arrangements to reflect the legally applicable roles.

19. International Processing

Technogym or its service providers may process or store data using infrastructure outside Thailand. Applicable cross-border transfer obligations and safeguards are governed by the relevant Technogym arrangements and, where Amintara Group has responsibility for a transfer, by BIOTIME's obligations under Thai law.

20. Data Subject Rights

Rights concerning data held in the Technogym ecosystem may need to be exercised with Technogym, BIOTIME or both depending on the relevant processing role. BIOTIME will reasonably assist Members in identifying the appropriate route where a request concerns information accessed or used by BIOTIME personnel.

21. Security and Confidentiality

BIOTIME personnel must use Technogym/Mywellness information only for authorized purposes and must follow applicable account-security, confidentiality and access-control requirements. Credentials must not be shared and access should be removed when no longer required.

22. Data Breaches and Incidents

If BIOTIME becomes aware of an incident involving Technogym/Mywellness data to which BIOTIME personnel have access, BIOTIME will assess and escalate the incident under applicable contractual and legal procedures and cooperate with Technogym or other responsible parties as appropriate.

23. Relationship to BIOTIME Privacy Notice

BT-PP-1.0 explains BIOTIME's broader processing of Member data. This Notice provides additional transparency about Technogym/Mywellness and health-related information. Where a specific processing activity requires separate explicit consent under applicable law, that consent will be obtained separately and will not be implied merely from Membership purchase.

24. Changes to This Notice

BIOTIME may update this Notice if the Technogym implementation, equipment, data flows, contractual roles or applicable law change. The current version and effective date will be identified.

25. Language

This Notice is available in Thai and English. Both versions are intended to communicate the same substantive information. If interpretation differs, the Thai version prevails to the extent required or permitted by Thai law.

26. Contact

Questions about BIOTIME's interaction with Technogym/Mywellness data should be directed through BIOTIME's official privacy/contact channels published on biotime.club. Questions concerning the Member's independent Technogym account may also need to be directed to Technogym through its official channels.