X-Wrist – Privacy Policy

This Privacy Policy explains how we use personal information about you and the steps we take to ensure your personal information is kept secure and confidential. It should be read together with our Terms and Conditions.

If you give us information about another person, in doing so you confirm that they have consented for you to provide the information to us for us to be able to process their personal data, including any “sensitive or special personal data”, and that you have told them who we are and what we will use their data for, as set out in this Privacy Policy.

1. Who are we

1.1 We are NRG CORE GLOBAL S.R.L. (referred to as “X-Wrist”, “we”, “us” and “our” in this Privacy Policy), a company incorporated in Romania, registered with the Trade Register under J2024012419403, VAT number RO50271952, with its registered office at Str. Diaconu Coresi nr. 53, Sector 1, București, România.

1.2 This Privacy Policy applies to all products and services offered by us through any websites, web applications, mobile applications or similar devices, channels, platforms, service applications or other applications operated by or on behalf of us or which reference these terms and conditions (“Services”).

1.3 We are the data controller in relation to the processing of the personal information that you provide to us. Our contact details are as follows:

Address: Str. Diaconu Coresi nr. 53, Sector 1, București, România
Telephone number: 0757.711.765
Email address: support@x-wrist.com (please include “Personal Data Request” in your subject heading)

1.4 Our Data Protection Officer is Costin Nita. His contact details are as follows:

Telephone number: +40 740 151 626
Email address: gdpr@x-wrist.com

2. How we collect your information

2.1 The information we hold about you comes from the way you engage with us, for example by:

providing us with information in the course of registering for and/or using our Services;
using your X-Wrist wearable technology device and the associated mobile applications;
when you make a purchase using your X-Wrist device;
taking part in surveys, posting on message boards, or entering competitions;
downloading information or participating in interactive areas of our applications;
interacting with us using social media; and/or
contacting us offline, for example by telephone, SMS, email or by post.

2.2 We may also obtain information about you from credit reference agencies and fraud prevention agencies.

2.3 The information we collect may include:

basic personal details such as your name, date of birth or age, address, email address, telephone number, gender and marital status;
your national insurance number;
the Internet Protocol (IP) address attached to your device and other device identifiers;
your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and certain device information;
sensitive or special personal information;
your marketing preferences; and
your location.

3. What we use your information for

3.1 We may use your information to provide you with our wearable technology device services, including to:

create, develop, operate, deliver, and improve our wearable technology devices;
verify identity and determine appropriate services;
send you important notices and communications;
conduct auditing, data analysis, and research to improve our products;
enable health tracking, dietary tracking and sleep tracking features.

3.2 In order to prevent or detect fraud or to comply with any legal or regulatory requirements, we may collect, analyse or carry out research in respect of your information.

4. Our legal grounds for processing your information

4.1 By proceeding to use your X-Wrist device, you give us your permission to process your personal information for the purposes set out in this Privacy Policy, on the basis that it is necessary for the performance of a contract or for the purpose of providing you with the services.

4.2 In certain circumstances we will only collect and process your personal information if you have provided consent:

sensitive or special personal information – we require your consent to collect this category of data;
market analysis and emails – we will only send marketing emails if we have your consent.

4.3 For all other processing where consent is not required, we will only do so in accordance with data protection laws, including if it is in our legitimate business interests.

5. Sensitive or special category data

5.1 We may need to collect information defined as “sensitive or special personal information”, including information regarding:

your diet;
your workout routine;
your sleeping routine; and
your health data.

5.2 To process this data and allow access to associated features, we require your explicit consent for the purpose of providing personalised health and fitness applications.

5.3 We will ask for your explicit consent when you pair your account to your device. You can withdraw your consent at any time, but this may affect some features of your X-Wrist device.

6. Sharing your information

6.1 We may share and aggregate information about you with any company within the NRG CORE GLOBAL S.R.L. group for the purposes set out in this Privacy Policy.

6.2 If you purchase a product or service, your personal information may be shared with:

our associated companies and partners;
regulators or other third parties for statutory or regulatory reporting or the detection or prevention of unlawful acts;
our e-token payment provider;
credit reference and fraud prevention agencies;
any third party in the context of actual or threatened legal proceedings;
our professional advisors and auditors;
our service providers and agents who process information on our behalf;
third parties where you have consented to us sharing information;
third parties for marketing purposes (with your consent); and
another organisation in connection with a sale or transfer of our business.

6.3 We may share non-personally identifiable information publicly or with third parties, but this will not include information that can identify you.

7. International Transfers

We will not transfer personal data to a country outside the European Economic Area (EEA) unless:

the country is covered by an adequacy decision of the Commission under GDPR Article 45;
appropriate safeguards have been put in place meeting the requirements of GDPR Article 46; or
one of the derogations under GDPR Article 49 is applicable, including where the transfer is necessary for the performance of a contract with you, for the establishment or defence of legal claims, or where you have provided explicit consent.

8. How long will we keep your information for?

8.1 Unless required or permitted by law to hold data for a specific period, we will only hold your personal information for 12 months following completion of our Services to you or termination of your account, or until you request it is deleted.

8.2 Contact information held for marketing purposes will be held for so long as we believe the information to remain accurate and it is in our legitimate business interest, or until you opt out.

8.3 Where we no longer need your personal information, we will dispose of it in a secure manner.

9. Security

9.1 We keep your information protected by taking appropriate technical and organisational measures, including:

data encryption where appropriate;
use of HTTPS to help keep information secure;
safeguards in relation to access and confidentiality; and
frequent risk assessments and audits to monitor and review threats and vulnerabilities.

9.2 While we will do our best to protect your personal information, we cannot guarantee the security of information transmitted via the internet.

9.3 Please keep your username, password and other identification information confidential and do not share them with anyone.

10. Marketing

10.1 From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you.

10.2 You have the right at any time to stop us from contacting you for marketing purposes by sending an email to support@x-wrist.com.

10.3 You can also unsubscribe from any electronic marketing communications using the links provided in the emails we send to you.

11. Your rights to your personal data

11.1 You have certain rights under data protection laws, including:

Right to access: the right to request access to and copies of your personal information;
Right to rectification: the right to have your personal information corrected if it is inaccurate or incomplete;
Right to erasure: the right to request that we delete or erase your personal information from our systems;
Right to restriction: the right to stop us from using your personal information or limit the way in which we can use it;
Right to data portability: the right to request that we return your information in a structured, machine-readable format; and
Right to object: the right to object to our use of your personal information.

11.2 If you withdraw your consent to the use of your personal information, we may not be able to provide you with access to all parts of our Services.

11.3 If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the Romanian supervisory authority, ANSPDCP: www.dataprotection.ro.

12. Changes to this Privacy Policy

12.1 We may amend this Privacy Policy from time to time to keep it up to date, to implement technical adjustments, or to comply with legal requirements. We will always update this Privacy Policy on our website.

Last updated: September 2026