01Data We Collect
• Account data: name, email, password (stored as a hash), profile photo and primary sport. • Training data: planned and completed workouts, imported activity files (FIT/TCX/GPX), zones, FTP and thresholds, notes, races and results. • Body data you log: weight and measurements, when you choose to record them. • Uploaded content: photos, videos, and entries from your journal and mental tools. • Location data (GPS): your workout route, collected in the foreground and also in the background with the screen locked, only while a recording you started is running. See the Location Data (GPS) section. • Technical data: device model, operating system, access logs and IP address, for security and diagnostics.
02Location Data (GPS)
What we collect: your device's precise (GPS) and approximate location. When we collect it: • In the foreground — while you have a workout open in the player and chose to train outdoors, to mark the starting point and draw your route. • In the background, with the app closed or the screen locked — only while a workout recording that YOU started is running. This is what lets us keep recording the route of a ride, run or walk without you having to keep the phone awake and in your hand. On Android, a permanent notification stays in the status bar while this happens, telling you the recording is active. Recording stops when you end or save the workout, and collection stops with it. We never collect your location outside a workout being recorded. There is no continuous tracking, in the background or the foreground, when you are not training. What we use it for: drawing the route map of the workout; calculating distance, speed, pace and elevation gain; identifying whether a segment was uphill, flat or downhill, for interval analysis; and recording where a class or workout took place when you check in. Where it goes: when the workout ends, the route is sent to our servers along with the activity, as a standard TCX file, and stays linked to your account and to that workout. We do not build a movement profile, we do not infer your home, your workplace or your routine, and we do not use location for advertising. We never sell this data. Who we share it with: only your coach, if you have one linked — they see the workouts you share with them, including the map; and the integrations YOU connect (for example Strava or Intervals.icu), at the moment the workout is sent to them. No other third party receives your location. How long we keep it: as long as the activity exists in your account. Deleting the workout deletes its route. Deleting your account deletes everything, as described in the Data Retention section. How to turn it off: you can decline the location permission at install time, or revoke it later in your system settings (Android: Settings › Apps › permissions; iPhone: Settings › Privacy › Location Services). The app keeps working without location — you lose the map and the GPS-dependent metrics, and you can still train normally in indoor mode, with data coming from your sensors and trainer.
03Health and Biometric Data — Wearable Integrations
Integrations with Oura, WHOOP, Apple Health, Google Health Connect and Bluetooth heart rate straps are entirely OPTIONAL and are only activated with your explicit consent, given at the moment of connection. • What we collect (read-only): heart rate (HR), heart rate variability (HRV), sleep, SpO2, recovery/readiness metrics and workouts/activities. • How we use it: EXCLUSIVELY to display recovery, readiness and training load insights to you, the athlete, inside the app. • What we NEVER do: sell this data, share it with third parties or use it for advertising. • Security: integration access tokens are encrypted with AES-256. • Revocation: you can disconnect any integration at any time in the app settings and also in the manufacturers' apps or portals (Oura, WHOOP, Apple, Google). When you disconnect, we revoke our access to that integration and stop receiving data; the history already synced stays in your account to preserve your trends and is deleted when you ask (Data Protection Officer and Contact section) or when you delete your account. • Legal basis: specific, highlighted consent for sensitive data, under Article 11 of the LGPD.
04Google Health (Fitbit and Pixel Watch) — Google user data
The Google Health integration is OPTIONAL and only starts when you tap Connect and grant access on Google's consent screen. We request read-only permissions; TrainGO Run never writes, changes or deletes data in your Google account. • Activity and fitness (googlehealth.activity_and_fitness.readonly): your exercise sessions (type, date, duration, distance, heart rate, calories) to log your workouts in your calendar and compute your training load. • Health metrics (googlehealth.health_metrics_and_measurements.readonly): resting heart rate, heart rate variability (HRV), oxygen saturation (SpO2) and respiratory rate, to show your recovery and your trend against your usual values. • Sleep (googlehealth.sleep.readonly): sleep duration and stages, to show how you slept and how it relates to your training. • How we use it: only to show YOU your own data, trends and training guidance inside TrainGO Run, and so the coach YOU linked to your account can follow your training. No other user sees this data. • Artificial intelligence: to generate your recovery reading and your DNA Coach replies, this data is processed by our AI provider (Anthropic) solely to produce the text you yourself see. It is not used to train AI models, ours or anyone else's, and is not used to create or improve generalized models. • What we NEVER do: sell the data, use it for advertising, transfer it to data brokers, or use it for credit decisions or any purpose other than your training. No one on our team reads this data unless you explicitly consent, or when needed for security or required by law. • Storage: access tokens are encrypted (AES-256) and the data is kept in an access-restricted database while your account is active. • Disconnect and delete: in Settings › Integrations › Google Health you can disconnect at any time: we revoke TrainGO Run's access in your Google account and stop fetching new data; the history already received stays in your account. You can also revoke TrainGO Run's access at https://myaccount.google.com/permissions. To delete the data already received from Google, ask through our Data Protection Officer channel (Data Protection Officer and Contact section); we respond within 15 days. When you delete your account, the connection and tokens are erased and your personal data is deleted or anonymized as described in the Data Retention section. TrainGO Run's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.
05Garmin device data and artificial intelligence
Data obtained through the Garmin Connect API (activities, workouts, heart rate, HRV, sleep and other health metrics) is used EXCLUSIVELY to display your calendar, training load and readiness to you and to the coach you linked inside the platform. This data is NOT shared with, processed by, or otherwise made available to any third party — including external artificial intelligence providers (such as Anthropic) or data processing services. Garmin data does not feed the platform's AI features and is not used to train models. We also do not sell, aggregate for third parties, or transfer Garmin data to other platforms. When you disconnect your Garmin account we stop receiving new data, and you can request deletion of the data already received through the DPO channel.
06TrainGO Run Fuel and bike computers
When you enable Fuel, we use power, FTP when provided, workout timing, targets and intake records to plan portions and calculate experimental demand estimates. These estimates do not measure glycogen, absorption or clinical status. Pairing with Garmin Edge or Hammerhead Karoo sends session configuration and validity over HTTPS, using a temporary code and a random installation identifier. This package does not include your name, email, account password or GPS route. The code permits redemption for ten minutes; the window to start the plan is at most 24 hours and may be shorter depending on the access granted. After pairing, the bike computer calculates locally and stores state and intake records on the device. In this version, these records do not sync with the phone or server. Replacing the session or removing the app removes or replaces local state according to device capabilities; deleting your account on the phone does not remotely erase an offline device. In the main app, Fuel records are saved with your activity in your account. When you request AI analysis and have access to this feature, results and their quality may form part of the context sent to the analysis service already described in this policy. Account and activity data follow the retention periods and rights below; session packages associated with the account are removed when the account is deleted.
07Legal Basis for Processing
We process your data under the following LGPD legal bases: • Consent (Art. 11, II, a) — for sensitive health data from wearables and body data you log; • Performance of a contract (Art. 7, V) — for account, training, pack and payment data required to provide the service; • Legitimate interest (Art. 7, IX) — for security, fraud prevention and service improvement, always with safeguards; • Compliance with legal obligations (Art. 7, II) — for tax and payment records. For users in the European Union, the equivalent bases of GDPR Articles 6 and 9 apply.
08How We Use Your Data
We use your data to: operate the app and keep your training, zones and load history; show your progress and statistics; generate personalized insights and content with AI; process plan and pack payments; send relevant notifications (which you can control); provide support; ensure security and prevent fraud. We may use aggregated, anonymized data — which does not identify you — to improve the product and understand usage patterns.
11App usage data
To support you and improve the product, we record how the app and website are used. For this purpose we do not collect workout content, messages, typed text, GPS, IMEI, MAC, serial number or the device name. • What we record: date and method of completed logins (password, passkey or federated login); when you open the app or the signed-in area; a random installation identifier (stored only in hashed form); platform, app and update version, operating system and the model reported by the device; browser family; the IP address always masked (the last digits are discarded); and which features you use (for example, opening the calendar, starting a workout, connecting a device). • Why: to help you in support (understanding the version and the path that led to a problem) and to learn which features are used, to improve the product. We do not use it for advertising and we do not sell it. • Who can see it: only authorized support staff, with access recorded in an audit log. • Retention: login history, 30 days; usage events, 90 days; daily totals, 180 days; installations with no contact for 180 days are removed. Deleting your account erases all of it. • Legal basis: legitimate interest in keeping the service working and secure (Brazilian LGPD art. 7, IX).
12Data Retention
We keep your data while your account is active. When you delete your account, your personal data is deleted or anonymized within 30 days, except for records we must keep due to legal obligations (for example, tax and payment records) for the legally required periods. Backups are purged in regular rotation cycles, within 90 days. When you disconnect a wearable, the health history already synced is kept in your account until you request deletion or delete the account; new data stops arriving.
13Your Rights as a Data Subject
The LGPD grants you, among others, the rights to: access your data; correct incomplete or outdated data; deletion; portability; information about who we share data with; and withdrawal of consent at any time. To exercise any right, write to [email protected]. We respond within the legal timeframe, generally within 15 days. You may also file a complaint with the ANPD (Brazilian National Data Protection Authority).
14Security
We adopt technical and organizational measures to protect your data: encryption in transit (TLS), encryption of sensitive tokens at rest (AES-256), passwords stored as hashes (bcrypt), role-based access control and security monitoring. No system is 100% secure, but in the event of an incident that may create relevant risk, we will notify you and the ANPD as required by the LGPD.
15Children and Teenagers
TrainGO Run is intended for users aged 13 or older. Users under 18 need consent from a parent or legal guardian. We always process teenagers' data in their best interest, as required by Article 14 of the LGPD. Parents and guardians may request access, correction or deletion of a teenager's data via [email protected].
16International Data Transfers
Our servers and some processors (DigitalOcean, Stripe, Anthropic) are located outside Brazil, mainly in the United States. International transfers are carried out with adequate safeguards, such as contractual data protection clauses, in line with Article 33 of the LGPD.
17Changes to this Policy
We may update this policy to reflect changes in the service or in the law. The current version will always be on this page, with the update date at the top. Material changes will be communicated via the app or email. Changes to how we process sensitive health data will require renewed consent.
18Data Protection Officer and Contact
The data controller is RUMPLETISTEKIN CRIACOES LTDA, CNPJ 68.001.451/0001-87. TrainGO Run is operated from Brazil. Our Data Protection Officer (DPO) can be reached at [email protected] — the same channel used for any privacy request. We will do our best to resolve any issue directly with you; you also retain the right to escalate to the ANPD.