Privacy Policy

Version 0.2 · Last updated 2026-10-09

⚠️ Draft — under legal review. The data practices described below are current. The health-data consent mechanism (§3) and the international-transfer assessment (§4) are being confirmed with a privacy specialist before public launch. Items marked [pending] still need confirmation.

1. Who is responsible for your data

The data controller is Paul Olyslager, a sole trader established in Germany, operating PacePilot. Registered address: Goethestr. 29a, 13086 Berlin, Germany. For any privacy question, or to exercise your rights, contact contact@pacepilot.cc.

2. What we collect

3. Why we process it, and our legal basis

PurposeData usedLegal basis (GDPR)
Provide the coaching service — build and adapt your plan, generate workouts, analyse rides, answer training questionsAccount, activity, usageArt. 6(1)(b) — performance of our contract with you
Factor recovery, sleep and physiological signals into your coachingHealth / special-category dataArt. 9(2)(a) — your explicit consent, given when you set up your account and confirm the health-data notice
Take payment for the subscriptionBilling dataArt. 6(1)(b) — contract
Keep legally required financial recordsTransaction recordsArt. 6(1)(c) — legal obligation (German tax law)
Understand, in aggregate, how the service is usedAnonymised, non-identifying statisticsArt. 6(1)(f) — our legitimate interest in improving the service

You can withdraw your consent for health-data processing at any time by deleting your account, which permanently erases that data. Withdrawing consent means the coaching features can no longer function. [The consent step in signup is being updated to a separate, explicit opt-in to satisfy GDPR Art. 9 "explicit consent" — pending counsel's confirmation of the required wording and UX.]

4. Who else processes your data (sub-processors)

ProviderLocationRole / what they process
SupabaseEU (Frankfurt)Database and authentication hosting — stores all account, activity and health data
AnthropicUnited StatesGenerates the AI coach's responses. Receives the messages you send and a summary of your recent training context (recent rides, FTP, planned sessions, recovery score). Per Anthropic's commercial terms, this data is not used to train models and is not retained beyond serving the request. EU→US transfer under Standard Contractual Clauses.
VercelEU + global edgeApplication hosting. Processes HTTP requests. Also provides cookieless visitor statistics for the public website (page views, referring site, campaign tags, country, device type) — no cookies, no cross-site tracking, no personal profile.
PayPalUnited States / EUPayment processing and recurring billing. Receives the information needed to take payment and manage your billing agreement. EU→US transfer under Standard Contractual Clauses.
WhoopUnited StatesOptional. If you connect Whoop, we receive the recovery and sleep data you authorise via OAuth. EU→US transfer under Standard Contractual Clauses.
intervals.icuEUOptional. Connected with an API key you provide. We read your completed rides and power / heart-rate streams to analyse your training, and write planned workouts back so they reach your head unit or Zwift.

We do not sell your data and do not share it for advertising. [A transfer impact assessment and signed data-processing agreements for the US processors above are being confirmed with counsel.]

5. AI processing

When you chat with Elena or trigger an AI-generated recommendation, your message and a training-context summary are sent to Anthropic (see §4). Elena is instructed to refuse medical, mental-health and clinical-nutrition questions and to direct you to a qualified professional.

Your training plan and its day-to-day adaptations are generated with AI, but they are advisory: you review and approve schedule changes, and no decision producing legal or similarly significant effects is taken about you solely by automated means.

6. How long we keep it, and your rights

We keep your personal data for as long as your account is active. When you delete your account (Profile → Account) we permanently erase the personal data that identifies you — your profile, training and health data, rides, chats, and connected-service tokens — with no recovery period.

Two things are kept beyond deletion:

Under the GDPR you have the right to access, correct, export (data portability), restrict, and object to the processing of your data, to delete it, and to withdraw consent at any time. Contact contact@pacepilot.cc; account deletion and data export are also available in the app.

If you believe we have not handled your data properly, you can lodge a complaint with your local data-protection authority, or with the competent German supervisory authority (for an operator in Berlin: the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, datenschutz-berlin.de).

7. Cookies and on-device storage

We use your browser's local storage to cache your data on-device for fast loading, and authentication cookies to keep you signed in. We do not use tracking or advertising cookies. On the public website we count visits with Vercel Web Analytics, which sets no cookies and does not follow you across sites. Before you sign up, your browser remembers which site or link brought you to PacePilot (stored locally, sent to us only when you create an account) so we know which channels work.

8. Children

PacePilot is not directed to anyone under 16. Account creation requires a date of birth of 16 or older. If we learn that we have collected data from someone under 16, we will delete it.

9. Changes to this policy

We may update this policy. Material changes are notified in the app and require your re-acceptance before continued use.

Questions about your privacy: contact@pacepilot.cc.

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