Privacy Policy

TRAIN HARD STAY HUMBLE LLC ("we," "us," or "our") operates the STRENUO website and mobile application (the "Platform"). This Privacy Policy explains how personal information is processed, stored, and protected when you use our Platform.

By using STRENUO, you agree to the processing of personal information in accordance with this Privacy Policy.

1. Data Roles and Responsibilities

STRENUO is a personal coaching platform. In most cases:

• Your Coach acts as the "Data Controller" and determines how and why your personal data is processed for coaching purposes. This includes personal data processed in connection with billing, invoicing, and payment collection.
• TRAIN HARD STAY HUMBLE LLC acts as a "Data Processor" and processes personal data only on behalf of and under the instructions of your Coach.
• We enter into a Data Processing Agreement with Coaches that governs how personal data is processed in accordance with applicable data protection laws.

In limited cases where no Coach is associated with your account, TRAIN HARD STAY HUMBLE LLC acts as the Data Controller solely for the purpose of providing basic Platform functionality.

Important: TRAIN HARD STAY HUMBLE LLC does not provide coaching, medical, or nutritional advice. All coaching services are provided directly by your Coach. TRAIN HARD STAY HUMBLE LLC does not intermediate, verify, or enforce payment arrangements between Coaches and clients.

2. Information Collected

2.1 Information You Provide

#### Account Information

• Email address (required for account creation)
• Name, phone number (optional), gender, date of birth
• Password (stored securely as a hash)
• Profile picture

#### Health and Fitness Data

• Body weight measurements, wellness metrics
• Workout data, check-in information, progress notes
• Nutrition data and food logs

Health-related data is provided voluntarily by you and processed at the direction of your Coach for the purpose of delivering personalized coaching services. TRAIN HARD STAY HUMBLE LLC does not independently determine how this data is used.

#### Media and Communications

• Progress photos and videos you upload
• Messages exchanged with your Coach

2.2 Information We Do NOT Collect

• Precise location data (gym finder uses maps redirect only)
• Third-party analytics or advertising trackers

3. How We Process Your Information

We process personal information solely to provide and operate the Platform and to enable your Coach to deliver coaching services to you. We process only the minimum amount of personal data necessary to operate the Platform and provide its features.

Platform-level purposes include:

• Hosting and storing data securely
• Enabling coach-client communication
• Providing workout, nutrition, and progress tracking tools
• Maintaining and securing the Platform

Payments for coaching services may be processed through third-party payment providers or handled directly by your Coach. Payment information is processed outside of the Platform and is not stored on our servers. Your Coach is responsible for managing payments, invoices, and related financial data, including any personal data processed in connection with billing.

We do not access, review, or use your personal data except as necessary to operate, maintain, and secure the Platform or as required by law.

Legal Basis for Processing

Where applicable under data protection laws, personal data is processed based on:

• Performance of a contract (providing the Platform)
• Your explicit consent (health-related data)
• Legitimate interests (security, fraud prevention, and service improvement)
• Compliance with legal obligations

4. Data Sharing

We do not sell your personal information.

We may share your information in the following circumstances:

• With Your Coach - Your Coach has access to the data you provide through the Platform and is responsible for how that data is used in connection with coaching services.
• With Service Providers - We share data with third-party providers solely to operate the Platform (cloud database, storage, and technical payment facilitation).
• Payment Providers and Invoicing - Payments and invoices may be handled by third-party providers or directly by your Coach. Such providers act under their own privacy policies, and TRAIN HARD STAY HUMBLE LLC does not control or store payment details.
• For Legal Reasons - We may disclose information if required by law or to protect rights and safety.
• Business Transfers - In the event of a merger or acquisition, information may be transferred.

Coaches are independent data controllers and are solely responsible for their compliance with applicable privacy and confidentiality obligations.

5. AI-assisted processing

The platform offers optional AI features (analysis of training and nutrition data, drafting of messages and content for the coach, evaluation of check-ins). These features are only active if your coach has purchased and enabled them.

What is processed: Only the data required for the specific evaluation is sent to the AI providers. Transmission is data-minimised; names and contact details are not transmitted unless required for the evaluation.

Providers used:

- OpenRouter, Inc. (USA) – routing of AI requests to the language-model providers - xAI Corp. (USA) – generative language models for analysis and drafts - Langfuse GmbH (Germany, servers in the EU) – technical logging of AI requests and responses for quality assurance and error analysis; content is deleted automatically after 30 days

No training: The AI providers do not use your data to train their models. Every request is made with a technical restriction to providers that do not store or use the transmitted data for training purposes.

Extent of automation: By default, AI output consists of suggestions and drafts that your coach reviews and approves. Your coach can enable automatic execution for individual types of action (for example message drafts or publishing content). Where they do, these are organisational and content workflows that your coach configured in advance and remains responsible for.

Certain actions are permanently excluded from automation and always require the coach's explicit approval. These include every deleting action and every action relating to payments and billing.

No automated decision about your legal status is made.

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR) on the instruction of the coach as controller, and for special categories of personal data additionally your explicit consent (Art. 9(2)(a) GDPR).

Third-country transfers: OpenRouter and xAI process data in the USA. Transfers are made on the basis of the Standard Contractual Clauses (Art. 46(2)(c) GDPR) and the Swiss recognition of those clauses.

A complete and continuously updated list of all sub-processors is available in the Data Processing Agreement (DPA).

6. Data Retention

We retain personal data for as long as instructed by your Coach or as necessary to provide the Platform.

Upon account deletion or instruction from the Coach, data will be deleted or anonymized within 30 days, unless retention is required by law.

7. Your Rights

Your rights regarding your personal data are primarily exercised with your Coach, who acts as the Data Controller.

If you contact us directly, we will forward your request to your Coach and assist them as required by applicable law.

You may have the following rights:

• Access - Request a copy of your personal data
• Rectification - Request correction of inaccurate data
• Erasure - Request deletion ("right to be forgotten")
• Data Portability - Request data in machine-readable format
• Restriction/Objection - Limit or object to processing
• Withdraw Consent - Where processing is based on consent

To exercise your rights, contact: aroldo@thsh.fit

8. Data Security

We implement appropriate technical and organizational measures:

• Encryption of data in transit (HTTPS/TLS)
• Secure password hashing
• Row Level Security on database tables
• Access controls and session tokens

No method of transmission is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards in accordance with applicable data protection laws.

10. Children's Privacy

STRENUO is not intended for users under 16. We do not knowingly collect data from children under 16.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy within the Platform.

12. Contact Us

TRAIN HARD STAY HUMBLE LLC Email: aroldo@thsh.fit Address: Tangentenweg 11, 4058 Basel, Switzerland