Privacy Policy

We collect Personal Data about you from:

• You, when you provide such information directly to us, such as when completing your profile, responding to a questionnaire, or communicating with us directly through customer support;
• Wearable integrations, which you may connect to your Trainable account to share fitness and health data collected by your wearable device;
• When you interact with and receive responses from another member;
• Automatic data collection, such as cookies, local storage objects, web beacons, and other similar technologies in connection with your use of the Services;
• Customers and partners, such as employers, insurance companies, trainers, teams, or other organisations that engage with our Services;
• Marketing and advertising partners, such as companies that have entered into joint marketing relationships with us or assist us with marketing or promotional services, which may provide us with data related to how you interact with our Services, advertisements, or communications;
• Social media, other third-party platforms, and linked accounts, devices, or features, if you interact with our pages on social media sites, post content to their sites using the Services, sign into the Services through a third-party site or service, or otherwise link accounts, devices, or features to your Trainable account; and
• Data providers, such as information services and data licensors, when we supplement your data.

We may collect the following types of Personal Data:

• Contact details, such as your first and last name, email and mailing address, and phone number;
• Profile data, such as username and password that you may establish to create a Trainable account, as well as any photographs or information you choose to include in your Trainable profile;
• Communications that we exchange with you, including when you contact us via email, web app, or mobile app with questions, feedback, or reviews;
• Wellness data, including the type of physical activity you engage in and the duration of your activity; your physiological profile, including birthday, gender identity, weight, height, fitness/athlete level (e.g., professional or recreational); and details you choose to submit about your habits, diet, medications, and female health tracking. We may use some of this information to customise your experience with us as part of our Services;
• Conversations that you participate in with the Platform;
• Payment and transactional data needed to complete your orders on the website or through the Services (including name, email address, payment card information, bank account number, billing information) and your transaction history, although Trainable does not have access to payment card numbers. Our payment processors will collect the financial information necessary to process your payments in accordance with the payment processor’s respective services agreement and privacy policy. Paid subscriptions are billed through the applicable app store (such as the Apple App Store or Google Play), and your subscription payment information is collected and processed by that app store under its own terms and privacy policy, not by Trainable;
• Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them (e.g., the marketing emails that you open and the links within them that you click);
• Device data, such as your computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP Address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area;
• Geolocation data, such as GPS (precise geolocation), IP Address, and movement on certain exercise types if you give permission for Trainable to do so; and
• Online activity data, such as pages or screens you view, how long you spent on a page or screen, the website you visited before visiting our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Trainable uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognise your web browser and tell us how and when you visit and use our Services, as well as to analyse trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data included on the Services (such as on a website or in an email) or placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). We will obtain your (opt-in) consent prior to deploying any cookies other than cookies which are regarded as being “strictly necessary” (i.e., Essential Cookies, as described below).

Cookie usage and type

• Essential Cookies: required for providing you with features or Services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and Services unavailable.
• Functionality Cookies: used to record your choices and settings regarding our Services, maintain your preferences over time, and recognise you when you return to our Services. These Cookies help us to personalise our content for you, greet you by name, and remember your preferences (e.g., your region).
• Performance/Analytical Cookies: allow us to understand how users use our Services by collecting information on how often a user engages with a particular feature of the Services. We use these aggregated statistics internally to improve the Services. They also help us measure the performance of our advertising campaigns.
• Marketing Cookies: collect data about your online activity and identify your interests so that we and our advertising partners can provide marketing that we believe is relevant to you. For more information, please see the section below titled “Interest-based advertising.”

Online tracking opt-outs

There are a number of ways you can opt out of certain interest-based advertising and other online tracking activities, which we have summarised below.

• Blocking Cookies in your browser. Most browsers let you remove or reject Cookies, including Cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept Cookies by default until you change your settings. For more information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Blocking advertising ID use in your mobile device settings. Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of your advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting Cookies used for interest-based ads by using a browser with privacy features, and configuring them to block third party Cookies/trackers.

Please note that some opt-out features are Cookie-based, meaning that when you use these opt-out features, an “opt-out” Cookie will be placed on your computer or other device indicating that you do not want to receive interest-based advertising from certain companies. If you delete your Cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.

Opting out of interest-based advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Services.

We process and use Personal Data for the following purposes:

Service delivery, including to:

• Provide, operate, improve, develop, understand, and personalise the Services and our business, including testing, research, analysis, and product development;
• Satisfy the reason you provided the information to us, including for delivery of the Services and responding to and fulfilling requests;
• Communicate with you about the Services, including Service announcements, updates, or offers;
• Provide support and assistance for the Services;
• Create and manage your account or other user profiles;
• Customise website content and communications based on your preferences; and
• Process orders, memberships, or other transactions.

Research and development

We may create and use aggregated data or de-identified data from Personal Data we collect, for business improvement purposes, including to analyse the effectiveness of the Services, to improve and add features to the Services, and to analyse the general behaviour and characteristics of users of the Services. We also use de-identified wellness data for research purposes to help us and our research partners answer important questions about human performance and create an even better experience for our members by identifying cutting-edge insights and providing new content and product features.

Direct marketing and advertising

We may use data from the Personal Data we collect and certain data collected when you browse our website, to send you direct offers or other marketing messages or to advertise the Services or other Trainable product offerings.

Interest-based advertising

We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use Cookies and similar technologies to collect information about your interaction over time across the web, our communications, and other online services, and may use that information to serve online ads.

Compliance and protection, including to:

• Protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services;
• Comply with or enforce our legal or contractual obligations, resolve disputes, and enforce our Terms of Use;
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); and
• Respond to law enforcement requests and as required or permitted by applicable law, court order, or governmental regulations.

Lawful bases for processing

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, but will depend on the type of Personal Data and the specific context in which we process it. The legal bases we typically rely on for each category of processing activity are set out below.

We may use your Personal Data for reasons not described in this Policy where permitted by law and where the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Solely automated decision-making

We do not make decisions based solely on automated processing involving personal data, including profiling, which produce legal effects or similarly significantly affect you, including in connection with the personal data processing activities described under “Trainable Services and third-party AI technology” below.

Data subject rights

You have certain rights with respect to your Personal Data, including:

• Access. You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification. If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account.
• Erasure. You can request that we erase your Personal Data from our systems.
• Withdrawal of consent. If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilise some or all of our Services.
• Portability. You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection. You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of processing. You can ask us to restrict further processing of your Personal Data.
• Right to file a complaint. You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority in the relevant jurisdiction where you reside.
• Automated decision-making. You have the right to request not to be subject to solely automated decision-making, and the right to obtain human intervention or to contest such decisions.
• Transfer of data. Obtain a copy of any Standard Contractual Clauses or other international data transfer agreement we may use to transfer your personal data.

We may share your Personal Data with:

• Service providers, such as payment processors, vendors who advertise our Services or other Trainable products, security and fraud prevention consultants, hosting and other technology and communications providers, Anthropic (the provider of Claude AI, which powers our in-app AI chat assistant), analytics providers, and staff augmentation and contract personnel, that provide services to us or on our behalf;
• Advertising partners that may collect information on our website through Cookies and other automated technologies, including for the interest-based advertising purposes described above;
• Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us;
• Authorities and others, including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process;
• Business transferees, such as acquirers and other relevant participants in business transactions (or diligence or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganisation, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Trainable or our affiliates (including in connection with a bankruptcy or similar proceedings);
• Distributors and retailers of our Services or other Trainable products; and
• Affiliates of Trainable; and
• Venues and trainers, when you book a session through the Platform, who receive the booking information (such as your name, contact details, and booking time) necessary to deliver that session. We require these partners to protect your data under a data processing agreement consistent with this Policy and the UAE Personal Data Protection Law. While we do not control a partner’s internal systems, we hold them contractually accountable for how they handle your data, including through audit rights and liability for non-compliance.

Depending on how you use the Services, you may share Personal Data with:

• Other users of the Services or the general public, which allow you to choose to share information and content with other users of the Services, and users are by default searchable by other users. When you make Personal Data visible to other users of the Services, it may become publicly available and can be collected, viewed, and used by anyone;
• Third-party social media platforms, or linked accounts, devices, or features, when you choose to connect your account on those services with your Trainable account or post content to social media;
• Managing entities. If your use of the Services is on behalf of or managed by a managing entity, such as a trainer, team, organising body, or other entity with which you are affiliated, your account information and Personal Data may be shared with the managing entity subject to your consent, and you hereby consent to that managing entity allowing that information to be publicly shared, subject to any features of the Services that expressly override that control. The managing entity will determine how the relevant information and content is shared; and
• Corporate wellness programmes. If you use the Services in connection with an employer or organisational corporate wellness programme, we may share your information with that organisation subject to your consent. Typically, we will share only aggregated data with these organisations.

Trainable will use generative AI features that are intended to help you set and make progress toward your goals, understand Trainable concepts, provide educational guidance, and integrate with the rest of your Trainable experience. Trainable creates a training experience by combining your Trainable metrics to help you optimise your health, fitness and performance.

Third-party AI processing. Our app includes an AI-powered chat assistant that provides fitness and exercise guidance. When you use this feature, your chat messages (the text you type) are sent to Anthropic, the provider of Claude AI, for the purpose of generating responses. Anthropic processes this data in accordance with their own privacy and data protection standards. We do not send any other personal information (such as your name, phone number, or booking history) to this third-party service unless explicitly included in your message.

Please note that Trainable employees will only access your Personal Data when required to provide services and support. This may include collecting information about your experience with Trainable to assess the performance of and improve Trainable and other product offerings. In the case that Trainable suggests connecting to Membership Services, you can opt in to have your support request automatically filed with our team. In this case, our support team will only have access to that specific conversation to provide you with the best support.

Access, update, correct, opt-out, or delete. When you log in to your account, you may access, and in some cases edit or delete, certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting dpo@trainableai.io. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as aggregated or de-identified data derived from or incorporating your Personal Data that does not identify you after you update or delete it.

Privacy settings. You can change certain privacy settings, such as whether you are searchable on Trainable, within the Platform settings.

Personalisation settings. You can control how your health data is used to personalise your Trainable experience in the Platform settings. Depending on your location, we may ask for your permission before using certain types of data for personalisation. You can update your preference at any time. If you turn this setting off, we will no longer use your health data to personalise recommendations, offers, or similar features within Trainable, which may affect certain features of the Services.

Push notifications and device permissions. You can change your settings related to push notifications and device permissions through the settings on your mobile device.

Geolocation data. You may allow or disallow Trainable to collect geolocation data by enabling or disabling location services on your mobile device. If you decline to grant Trainable access to this data, we will not be able to provide certain Services, capabilities, or features to you.

Wellness data. You can disable collection of certain wellness data by disconnecting your connected wearable integration from your Trainable account. If you disconnect a wearable integration, we will not be able to provide certain Services, capabilities, or features to you.

Trainable bookings. If you have connected with another member of Trainable (such as a user making a booking with a trainer) you may stop the sharing of your Personal Data with such other member at any time within the Platform.

Marketing communications. You can opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions contained in the marketing-related message. You cannot opt out of receiving certain non-marketing emails regarding the Services (examples include booking confirmations, payment receipts and account security alerts).

Online tracking opt-outs. There are a number of ways you can opt out of certain interest-based advertising and other online tracking activities, which we summarise in the “Online tracking opt-outs” section above.

The Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control mobile applications, websites, or online services offered or operated by third parties, and we are not responsible for their actions. You can learn about and control how these third parties use and share Personal Data, including with Trainable, by reviewing their privacy policies and exercising the privacy choices the third party may offer.

We employ a number of technical, organisational and physical safeguards designed to protect the Personal Data we collect. While we endeavour to protect the privacy of your account and other Personal Data we hold in our records, no security measures are failsafe, and we cannot guarantee the security of your Personal Data.

We retain Personal Data for as long as reasonably necessary for the purposes described in this Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

Where we process your data; international transfers. We store and process your Personal Data in the United Arab Emirates (UAE). Some of our service providers — for example, cloud hosting, payment providers, the app stores, and analytics and messaging tools — may process your Personal Data outside the UAE. The Services are intended for use within the UAE; if you access the Services from, or are located, outside the UAE (for example, if you travel), your Personal Data will still be transferred to and processed in the UAE and in the countries where those providers operate, which may have data-protection laws different from those where you are located. Where we transfer Personal Data outside the UAE, we do so on a lawful basis under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021): to a country with an adequate level of protection, under contractual safeguards that require a level of protection consistent with that law, with your explicit consent, or where the transfer is necessary to provide the Services to you. By using the Services, you acknowledge this processing and transfer.

Retention if you stop using the Services. If you close your account, it becomes inactive, or you leave the UAE, we retain your Personal Data only for as long as described above and then delete or anonymise it. You may ask us to delete your Personal Data at any time, and exercise your other rights (including access, correction, portability, restriction and objection) regardless of where you are located, by contacting us as described in “Contact us” below.

The Platform is not directed at, and Trainable does not knowingly collect Personal Data from, individuals under the age of 18. If you are under the age to consent to data sharing, as applicable based on your jurisdiction, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under the age to consent to data sharing, as applicable based on jurisdiction, we will delete that information as quickly as practicable.

We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. We will alert you to material changes by placing a notice on the Trainable website, by in-app notification, by sending you an email, and/or by some other means.

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to dpo@trainableai.io or at the mailing address below.