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Privacy Policy

Version 2026.10.24 · Effective October 25, 2026

TRAIN HARD STAY HUMBLE GmbH ("we", "us" or "our") operates the STRENUO website, the web app and the mobile application (the "Platform"). This Privacy Policy explains how personal data is processed, stored and protected in connection with your use of the Platform.

1. Controller and contact

TRAIN HARD STAY HUMBLE GmbH, Tangentenweg 11, 4058 Basel, Switzerland, e-mail: aroldo@thsh.fit. Send privacy requests to this address. We are not required to appoint a data protection officer and have not appointed one.

2. Roles and responsibilities

STRENUO is a coaching platform. There are two roles:

If your coach works in a team, other coaches of that team can access your data within their permissions.

Important: TRAIN HARD STAY HUMBLE GmbH does not provide coaching, medical or nutritional services. All coaching services are delivered directly by the respective coach. TRAIN HARD STAY HUMBLE GmbH is not a party to the relationship between coach and client.

3. Data we collect

3.1 Data you provide

Account information

Health and fitness data

Health-related data (including data you share from Apple Health, Health Connect, Oura or Polar) is provided voluntarily by you and processed on the basis of your separate, explicit consent (Consent to the Processing of Health Data, withdrawable at any time in the settings) and at the direction of your coach for the purpose of delivering personalized coaching services. TRAIN HARD STAY HUMBLE GmbH does not independently determine how this data is used.

Media and communication

Scheduling

Challenges

Payments to your coach

3.2 Data collected automatically

3.3 Data we do not collect

3.4 Public forms, offers and enquiries to a coach

Coaches can offer public forms (e.g. enquiry or questionnaire links) and bookable offers through the Platform. If you fill in such a form or book an offer without already being that coach's client, the coach is the controller for the information you provide (typically name, e-mail, phone number and your answers). The data is stored in that coach's account and may also be processed with AI for the coach; TRAIN HARD STAY HUMBLE GmbH processes it only as a processor. If the coach has added their own consent or information texts to the form and they were shown to you when filling it in, those apply in addition; the exact wording you accepted is stored with your submission. Direct access or erasure requests to the coach; we support them in fulfilling such requests. If no coaching relationship follows, the coach decides on deletion; the technical deletion periods in section 8 apply here as well.

3.5 Calls with your coach

Calls are transmitted encrypted in real time; participants, start time and duration are stored. Your coach can have a conversation recorded to create notes from it. A recording is only made if all participants have agreed.

3.6 Further features of your coach

Coaches can send and receive e-mail through the Platform, run their own website, connect their social media accounts and their ad account, and create success stories from their clients' results. The coach is the controller for the data processed in doing so; we process it on the coach's behalf. If a coach turns on sharing with an advertising network, contact details are only transmitted as a hash; you can object at any time towards the coach.

3.7 Data of coaches and prospective coaches

As controller, we additionally process information you give us in the sign-up flow, in the onboarding assistant, when booking a call with us or in support requests, information on the referral programme and, when you register a domain, the registrant data. We pass the registrant data to the registrar and the responsible registry, which may publish part of it in the public domain directory.

4. Purposes and legal bases

PurposeLegal basis
Providing the Platform, account, login, messages, appointmentsPerformance of a contract (Art. 6(1)(b) GDPR; Art. 31(2)(a) Swiss FADP)
Coaching data and other data on behalf of a coach (sections 3.4 to 3.6)Processing on the coach's instructions; health data on the basis of your explicit consent (Art. 9(2)(a) GDPR; Art. 6(7) FADP); call recordings only with the agreement of all participants
Apple Health, Health Connect, Oura, PolarYour explicit consent (permission or connection, and health data consent)
Security, abuse prevention, bot protectionLegitimate interest (Art. 6(1)(f) GDPR)
Product analytics (coach dashboard)The coach's consent (Art. 6(1)(a) GDPR)
Web analytics on the website and sign-up flowLegitimate interest (Art. 6(1)(f) GDPR); cookies only with your consent (Art. 6(1)(a) GDPR; § 25(1) German TDDDG), for visits from Switzerland with the option to refuse (Art. 45c Swiss Telecommunications Act)
Data of coaches and prospective coaches (section 3.7)Performance of a contract and pre-contractual steps (Art. 6(1)(b) GDPR)
Billing of coaches, invoice archivePerformance of a contract and statutory retention (Art. 6(1)(c) GDPR; Art. 958f Swiss Code of Obligations)
Notifications (e-mail, push)Performance of a contract; can be switched off in the settings
Anonymising the AI memory on deletion and using the anonymised data to improve the PlatformThe coach's instructions; legitimate interest (Art. 6(1)(f) GDPR)

Payments may be processed through external payment providers or directly by the coach. Full card and account numbers are never stored on our systems.

5. Recipients and processors

We do not sell personal data. To operate the Platform we use carefully selected service providers that process data solely on our behalf under data processing agreements:

CategoryProcessing locationPurpose
Hosting infrastructureZurich, SwitzerlandDatabase, login, server logic
File storage and deliveryEUImages, files, voice messages, e-mails; coach websites; abuse protection
Video storage and playbackEU / USAVideos
Video-call transmissionEUReal-time transmission; recording only with the agreement of all participants
E-mail and push deliveryEU / USAInvitations, reminders, notifications, coaches' e-mails
Payment processingEUProcessing of payments (independent controller under its own privacy policy)
Usage analyticsEUPseudonymised analysis of the coach account, only with the coach's opt-in
Web analytics and cookie bannerEUOur own web analytics on the website and sign-up flow
AI processingEU; individual features USAAI features (section 6)
Social media and advertisingEUOnly if a coach connects their accounts (section 3.6)
Domain registrationEUOnly when a domain is registered (section 3.7)
Call booking, help videos, onboarding assistantEU / USAOnly for coaches and prospective coaches (section 3.7)
The coach's calendar providerprovider-dependentCalendar synchronisation, only if your coach connects a calendar (your coach is the controller for this)

The complete, continuously updated list of sub-processors with company names and locations is Annex B of the data processing agreement (DPA) with your coach; you can request it through your coach or by e-mail to aroldo@thsh.fit.

Other recipients: your coach and, where applicable, their team (to deliver the coaching), other participants of a challenge (section 3.1), authorities where legally required, and a successor in the course of a business transfer.

6. AI-assisted processing

The Platform contains AI features that support your coach in their work and can take on tasks for them.

What is processed: Only the data required for the specific task is sent to the AI providers. Contact details from your profile are not sent; your coach can individually exclude first names, free-text notes, health metrics and financial data. If your coach asks the AI about you directly, it uses your name.

Providers used: AI requests are processed predominantly in the EU; technical logging takes place in the EU with automatic deletion after 30 days. Company names and locations are listed in Annex B of the DPA.

Stored AI insights (memory): Insights derived from your data (e.g. trends, preferences, summaries) are stored together with a technical representation (embedding) in our database in Switzerland and used in later requests so that responses and suggestions for you and your coach are personalised. They are not shared with third parties and are visible to your coach. When your data is deleted, these insights are anonymised: everything that could identify you is removed and the link to you and your coach is cut. In this form we use them to improve the Platform.

No training: The AI providers do not use your data to train their models and either do not store it or keep it for at most 30 days for abuse detection.

Degree of automation: Your coach decides which tasks the AI carries out on its own and remains responsible for them.

No automated decision-making with legal effect on you takes place.

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

Objection: You can object to AI processing of your data at any time towards your coach. Your coach then excludes you in the AI settings; from then on no data about you is sent to AI providers. The only exception is what your coach writes or says about you in the AI chat themselves.

7. Cookies and local storage

The Platform uses no advertising cookies. Technically necessary data is stored on your device and, only with your consent, statistics cookies:

The technically necessary storage is required to operate the Platform (Art. 6(1)(b) and (f) GDPR; § 25(2) German TDDDG) and requires no consent; product analytics requires the coach's consent, the statistics cookies your consent (§ 25(1) TDDDG). For visits from Switzerland we set the statistics cookies from the first page view and point this out in the cookie banner; you can refuse them at any time (Art. 45c Swiss Telecommunications Act). You can change your choice via "Cookie settings" in the footer.

8. Retention

Data categoryRetention
Account and profile dataUntil the account is deleted; client accounts are deleted immediately, coach accounts 30 days after the deletion request
Coaching data (training, nutrition, health, check-ins, photos, messages)For as long as you are coached; afterwards your coach decides on deletion. Deleting your account removes it
Apple Health, Health Connect, Oura, PolarAs coaching data; once the permission is revoked or the connection removed, no new data is imported
CallsCall metadata and notes as coaching data; recordings at most 1 day
E-mails, form submissions and booking requestsUntil the coach deletes them
AI memory and other AI dataAs coaching data; the AI memory is anonymised on deletion (section 6)
Data exportsDownload link 72 hours, file at most 4 days
AI logs30 days
Product analytics (coach dashboard)Until the coach withdraws the opt-in, at most 12 months
Web analyticsAt most 2 years
Technical access logsAt most 90 days
Invoices and billing data (coaches)10 years from the invoice date (Art. 958f Swiss Code of Obligations)
Domain registrant dataAs long as the domain is registered through STRENUO

After the retention period, data is erased or anonymised unless a statutory retention obligation applies.

9. Your rights

You have the right of access, rectification, erasure, restriction of processing, data portability, and to object to processing based on legitimate interests. You can withdraw any consent you have given (in particular to the processing of health data) at any time with effect for the future, in the app settings or by e-mail.

Rights concerning coaching data are exercised towards your coach as controller; we forward requests sent to us and support their fulfilment. For data we control ourselves, contact aroldo@thsh.fit directly.

Right to lodge a complaint: You may complain to a supervisory authority. In Switzerland this is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern. In the EU/EEA you may contact the supervisory authority of your place of residence; in Germany the data protection authority of your federal state, in Austria the Datenschutzbehörde, Barichgasse 40-42, 1030 Vienna.

10. Data security

We apply technical and organisational measures to protect personal data, in particular:

As with any digital system, complete security cannot be guaranteed.

11. International data transfers

The database and login are operated in Switzerland, files are stored in the EU. Some providers (section 5) process data in the USA. Switzerland and the EU/EEA mutually recognise an adequate level of data protection. Transfers to the USA rely on the EU Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR) as recognised by the FDPIC and, where the provider is certified, on the EU-U.S. or Swiss-U.S. Data Privacy Framework. A copy of the relevant safeguards is available on request.

12. Children's privacy

Coaches must be adults. Clients under 16 may only use STRENUO if a parent or legal guardian has agreed; the coach obtains this agreement. Without such agreement we do not knowingly collect personal data from anyone under 16.

13. Changes to this Privacy Policy

This Privacy Policy may be updated. Material changes are shown within the Platform and must be accepted again; the current version and its date are visible in the app.

14. Language

The German version of this Privacy Policy is authoritative; translations are provided for convenience.

15. Contact

TRAIN HARD STAY HUMBLE GmbH E-mail: aroldo@thsh.fit Address: Tangentenweg 11, 4058 Basel, Switzerland

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