Terms of use and privacy notice

Draft for the COACHINT pilot, reviewed for the main GDPR and Italian consumer-law points but not by a lawyer. Have it checked before real people use the site. Replace the parts in [square brackets] with your own details.

This page has two parts: the terms of use (part A), which you accept, and the privacy notice (part B), which tells you how your data is handled. Your consent to the processing of your health data is asked for separately, with its own box, when you accept.

Part A: Terms of use

A1. What COACHINT is, and who runs it

COACHINT is a pilot ("proof of concept") run by [FULL NAME OF THE ORGANISER, ADDRESS, CONTACT EMAIL] ("we", "us"). It reads the training and wellness data you choose to bring, learns your personal baseline and explains what changed. It is offered free of charge to a small group of invited people, for a limited time, to test the idea. Features can change, and the pilot can end; we will tell you before it ends.

A2. Who can use it

You must be at least 18 years old.
Bring only your own data. Do not upload data about other people.
Keep your sign-in to yourself. If you think someone else used it, tell us at once.

A3. What COACHINT is not

It is not a medical device and does not give medical advice. It is meant for sport and general wellness only. It is not intended to diagnose, prevent, monitor, treat or relieve any illness or injury. A flag (for example "resting heart rate up" or a note mentioning pain) only says that something differs from your usual pattern; it is not a diagnosis.
If you feel unwell, are injured or are unsure, stop and ask a doctor or another qualified professional. Do not delay or ignore medical advice because of something COACHINT shows.
The chat is an AI system. Its answers are written by an AI model, can be wrong or incomplete, and are training suggestions, not instructions. Each answer says which model wrote it.

A4. Using the service fairly

Do not try to access data you are not allowed to see, interfere with the site, or use it for anything unlawful. Be respectful in comments and messages: no harassment, threats or spam. We may suspend an account that does, after telling you why when we can, and we may remove a comment or a message someone reported to us.

You can block anyone: from then on neither of you writes to the other, finds the other, or sees, claps for or comments on what the other shares. You can report a person, a comment or a message to us.

A5. Responsibility

The pilot is free and experimental: we do our best to keep it working and accurate, but cannot promise that it is always available or free of errors.
We are not liable for decisions you take based on COACHINT's content, except where the law does not allow this limitation.
Nothing in these terms limits or excludes our liability for death or personal injury, for wilful misconduct or gross negligence (art. 1229 of the Italian Civil Code), or any right you have as a consumer under the Italian Consumer Code (Legislative Decree 206/2005) or the law of the country where you live.

A6. Ending

You can stop using COACHINT at any time and delete your account and data yourself, with Withdraw consent and delete my account on your Sharing page, or ask us to (part B, section B7). We can end the pilot or close an account with reasonable notice, or at once for a serious breach of section A4. When the pilot ends, your data is deleted as described in section B6.

A7. Changes

We may change these terms when the pilot changes, for a valid reason. A change is shown to you at your next visit and applies only once you accept it. If you do not accept, you can stop using COACHINT and have your data deleted.

A8. Law and courts

These terms are governed by Italian law. If you are a consumer, you keep the protection of the mandatory rules of the country where you live, and you can bring a claim before the courts of the place where you live (art. 66-bis of the Italian Consumer Code).

Part B: Privacy notice (art. 13 GDPR)

B1. Who is responsible for your data

The data controller is [FULL NAME OF THE ORGANISER, ADDRESS, CONTACT EMAIL]. Write to that address for any question or request about your data.

B2. What we collect

Account: a display name and a user id; if you sign in with a provider (for example Auth0 or Google), the provider's id for your account. If you use a password, we keep only a salted hash of it. COACHINT does not store the provider's tokens, nor your email address unless you give it when you sign up: it is optional, used only to confirm it is yours and to send you a link when you forget your password, never shown to other people, and deleted with your account (legal basis: our contract with you, art. 6(1)(b) GDPR).
Training and wellness data you bring, or that comes from services you connect (files and exports, Intervals.icu, Polar): workouts, heart rate, HRV, resting heart rate, sleep, fatigue, and the notes you write. Much of this is data concerning health (art. 9 GDPR).
Athlete record, if you keep one: medical history (conditions, surgeries, allergies, medication), injuries, illnesses and breaks from training, and past race results. Medical history and injuries are data concerning health (art. 9 GDPR).
Where you trained: when an activity file or Intervals.icu has GPS positions, we keep a simplified route (about 400 points) with the activity, to draw it on a map with your splits. A route can show where you live or work.
Settings and choices: your groups, whether you agreed to share with each group, who sees your activities, your races and each section of your athlete record beyond your page, your own AI model key if you add one (stored, never shown again), the questions you ask the chat while they are answered, and which version of these terms you accepted, when, and your consent.
Technical data: a sign-in cookie that keeps you signed in (no tracking or advertising cookies), and server logs kept by the host.

B3. Why, and on what legal basis

Running your account and the service you ask for (signals, digest, chat, imports): our contract with you (art. 6(1)(b) GDPR) and, for health data, your explicit consent (art. 9(2)(a) GDPR), given with its own box.
Showing your data to a trainer or to members of a group: your consent, given and withdrawn in the app on your Sharing page.
Showing your activities, your races and your past results beyond your page (your contacts' Feed, your card on the People page): your choice in the app, given and withdrawn at any time. Everything starts private.
Sharing your medical history or injuries with your coaches: your explicit consent (art. 9(2)(a) GDPR). These sections can be shared with your coaches at most, never with anyone else. Every section of the record is private until you share it. Before you share your medical history or your injuries, the app asks for this consent separately and records when you gave it. Making the section private again withdraws it at once; this does not end your account, and sharing it later asks again.
Security of the site, and keeping proof of your acceptance and consent: our legitimate interest (art. 6(1)(f) GDPR) and our duty to be able to demonstrate consent (art. 7(1) GDPR).

Giving your data is not a legal obligation. Without it, and without your consent for health data, COACHINT cannot work for you.

We do not sell your data, use it for advertising, or share it for research. Any other use would need your separate consent first.

Automated analysis: COACHINT compares your data with your own past data to show signals and suggestions. This is a form of profiling, but no decision with legal or similarly significant effects on you is taken by automated means (art. 22 GDPR): you decide what to do with it.

B4. Who sees your data

You, always.
Us, as the people running the pilot, to operate and fix the service.
A trainer who follows a group you are in, only after you agreed on your Sharing page. Being in a trainer's group is not enough. A coach you picked yourself sees your data the same way, until you remove them.
Your athlete record is seen only by you and, for each section, by whom you chose: your coaches (the ones you picked and the trainers you agreed to share with) for medical history and injuries; for past results, your coaches, the people you are connected with or share a group with, or everyone signed in to COACHINT who finds your profile. It is not shown in the site's admin pages.
Your activities and races, beyond the people above, by whom you chose on the People page (private, your coaches, your connections, or everyone signed in to COACHINT who finds your profile, which needs it to be discoverable). They see the date, sport, time and distance of an activity, never its heart rate, notes or route. Never by visitors who are not signed in. Whoever sees one of them may clap for it and comment on it; everyone it reaches reads the claps and comments with the names of who gave them, and your own comments are in your data download and go when you leave.
Other members of a group, only if the group has sharing on and both of you agreed. You can stop sharing with trainers or members at any time on your Sharing page; it takes effect at once.
When someone reports you, a comment or a message of yours, we read their report: who they are, their reason and, for a comment or a message, that one text, nothing else of the conversation or the feed. We use it only to decide whether to remove it or suspend an account (legitimate interest in keeping the service safe, art. 6(1)(f) GDPR). It is deleted when we close it, or when either of you leaves. The same applies to what you report.
Notifications tell you who clapped for or commented on what you share, or asked to connect. If you get the daily digest by Telegram or email, they also go there with your new messages, as names and what happened, never what a comment or a message says; you can turn this off under Notifications.
Anyone but you sees your routes without their first and last 200 metres, so they do not show where you start and finish.

B5. Service providers and transfers outside the EU

We use these providers to run COACHINT. Those that act on our behalf (processors) do so under a data processing agreement (art. 28 GDPR):

Hosting: [HOSTING PROVIDER AND COUNTRY, e.g. alwaysdata SARL, France (EU)].
Sign-in: [e.g. Google (Google Ireland Limited) and/or Auth0 by Okta, EU region], if you sign in with it. It keeps your account there (email address and password, or your Google account) and knows when you sign in; COACHINT receives only an id for your account and your name. If you use Google to sign in, Google's own privacy policy applies to your Google account.
Email: [EMAIL SERVICE AND COUNTRY, e.g. your mailbox provider's SMTP service], if you give your email address: it sends the confirmation and password-reset messages.
AI model for the chat: when you ask a question, the part of your data needed to answer it is sent to the model that answers:
this can include your athlete record: all of it when you ask, the sections that reach whoever else asks (your coach, or someone who sees your page);
with your own key, to the provider you chose, under your own agreement with them. We use your key only to answer what you ask (the chat, plan drafts, reading a nutrition label) and to check it works when you save it, never for anyone else or anything else; you pay your provider for those calls, and you can remove the key at any time in Account;
with our key, if we granted it to you, to [PROVIDER, e.g. Anthropic or OpenAI], which may process it in the United States [under the EU-US Data Privacy Framework or standard contractual clauses: CHECK FOR THE PROVIDER YOU USE], with no use of your data to train its models;
otherwise, to an open model [WHERE IT IS HOSTED, e.g. in the EU].
Services you connect (Intervals.icu, Polar): we receive data from them at your request; their own terms and policies apply to your account there.
Street map: a route is drawn without any map unless the person looking at it presses Show street map. Their browser then loads map images of that area from OpenStreetMap (OpenStreetMap Foundation, United Kingdom, a country with an EU adequacy decision), which sees their IP address and which area is shown, but not the route or any other data.

B6. How long we keep it

Your data is kept while you take part in the pilot, and deleted when you ask or when the pilot ends, at the latest [DATE, e.g. 31 March 2027].
Copies in backups are overwritten within [N] days.
A record that you accepted these terms and gave your consent (your name, id, version and time, no health data) is kept for [PERIOD, e.g. 2 years] after deletion, to prove your consent if needed.

B7. Your rights

You can, at any time and free of charge, ask us to: access your data and receive a copy; correct it; delete it; restrict its processing; receive it in a common machine-readable format or have it sent to another service; and object to processing based on our legitimate interest. You can download a copy of your data yourself at any time, as CSV files (routes as a JSON file), with Download my data on your Sharing page.

You can withdraw your consent at any time, as easily as you gave it, with Withdraw consent and delete my account on your Sharing page, or by writing to us at the address in section B1. Withdrawing does not affect what was done before; since COACHINT cannot work without it, withdrawing ends your account and your data is deleted.

We answer within one month. You can also complain to a data protection authority: in Italy the Garante per la protezione dei dati personali (www.garanteprivacy.it), or the one where you live or work.

B8. Security

Data travels encrypted (HTTPS), passwords are stored as salted hashes, and each person sees only what the rules above allow. The data stored on the server, and its backups, are encrypted (AES-256). If a breach is likely to put you at high risk, we will tell you without undue delay.