FitLoad Privacy Policy

Effective date: October 28, 2026 · Version 2.0

Find out how your privacy is protected and used within FitLoad.

Capitalized terms not defined here have the meanings given to them in our Terms of Service.

This Privacy Policy (“Policy”) of fitload.ai, app.fitload.ai, its downloadable software applications, and all related content, materials and services (collectively, the “Site”) is hereby made effective as of October 28, 2026, by Scaling Reason LLC, a Delaware limited liability company (“FitLoad” or “we” or “us” or “our”), and, without waiving or otherwise releasing any right or obligation under any prior privacy policy or similar document or agreement of FitLoad, including without limitation any prior privacy policy or similar document or agreement set forth on the Site, hereby amends and restates any such prior privacy policy.

By using or accessing the Site, you (“you” or “your” or “user” or “member”) (i) agree and acknowledge that you have read and understood this Policy, and (ii) acknowledge and consent to the learning, collection and use of your Personal Information (as hereinafter defined), other than consumer health data, as described in this Policy. Using or accessing the Site is not consent to the collection or sharing of consumer health data. Where this Policy or applicable law requires your consent, including for consumer health data, FitLoad will ask for it separately, and you give it only by an affirmative act, such as ticking a box. If you do not agree with any part of this Policy, you are prohibited from using or accessing the Site.

For individuals in the United States, please also consult the Consumer Health Data Policy and our Notice For Individuals Residing In Certain US States below.

This policy was last modified on October 28, 2026

General

When you register for a membership on the Site and when you complete a user profile and use the Site, you will provide certain data and information to FitLoad and, during your use of the Site, FitLoad will learn, collect and use certain additional data and information about you for various purposes, as more fully described in this Policy. This data and information includes, without limitation, name, age, gender, physical address or location, electronic mail address, telephone number, cellular number, billing information, demographic information, internet protocol address, browser types, domain name, mobile device identifier, wireless carrier, fitness and physical characteristics, health information, sport preferences, your Intervals.icu athlete identifier and the API key or access token you provide to us, and any other data or information that you upload or provide to the Site or which is collected through your use of the Site and which may be reasonably associated with, connected to you, or used to identify you, or which would allow you to be personally identified or contacted (all such personal data and information is collectively referred to herein as, “Personal Information”).

In addition to Personal Information, when you register for a membership on the Site and when you complete a user profile and use the Site, you will provide certain other data and information to FitLoad and, during your use of the Site, FitLoad will learn, collect and use certain other additional data and information which cannot be used to identify you, or which would not allow you to be personally identified or contacted, including, without limitation, statistical data and information (“Non-Personal Information”). Performance, exercise, training and fitness data, training plan use, and training logs are Personal Information, and are not Non-Personal Information.

Even though FitLoad will learn, collect and use information about you, FitLoad will not lease, sell, share or otherwise provide your Personal Information to any third party without your consent, except as provided herein.

Activity Data: We collect Activity Data directly or through third-party integrations you configure. “Activity Data” is information about the activities and workouts you record or upload to FitLoad, such as date, time, distance, speed, pace, cadence, calories, perceived exertion, power, and geolocation information. Activity Data can also include health data, such as heart rate, if you choose to provide it.

Wellness and Training Settings: We collect wellness data such as body weight, resting heart rate, heart-rate variability and sleep, where a Connected Service holds it; your training settings (such as FTP, threshold heart rate and maximum heart rate) and fitness estimates; and profile details such as sex, date of birth and weight.

Profile Information: We collect information you provide about yourself, such as your profile photo, fitness goals, and level of experience, and your races and race results, training plans, daily check-ins (readiness, tiredness, illness, pain level and where it hurts, weekly stress), injuries, reasons for missed sessions, height, notes, units and other settings.

Content You Share: We collect content you share through the Services, such as photos, posts, comments, and messages, including your messages to the AI coach, its replies, and files you attach (images, PDFs, text, Word and Excel files). Workout files you upload (.fit, .tcx, .gpx) are read to create an activity and are not kept.

Payment Information: If you make a payment on FitLoad, we collect information about your purchase. We do not collect your payment card information. Instead, we use Payment Card Industry compliant third-party payment services.

Health Information: Much of the foregoing, such as heart rate, heart-rate variability, resting heart rate, weight, sleep, pain, illness and injury reports, and estimates derived from them, is health information. FitLoad treats all such information as sensitive Personal Information, and none of it is Non-Personal Information. FitLoad never uses consumer health data for advertising, marketing or sale, and never provides it, even in de-identified or aggregated form, to advertisers or in reporting to investors.

What We Learn, Collect and Use

Starting when you register on the Site, FitLoad will learn, collect and use certain personal data and information about you and, as you use the Site, will continue to learn, collect and use additional Personal Information.

Registration. To become a registered user of the Site, you must provide us with Personal Information. You cannot create an account and/or become a registered user of the Site without providing Personal Information. Upon registration or when you choose to use certain services available or offered on the Site, FitLoad may collect certain other information, including without limitation, Personal Information, from you including, without limitation, demographic information, such as location, age or gender. During any registration process, FitLoad may request or collect Personal Information from you which FitLoad may use to provide or improve the Site or may use as is otherwise provided herein. FitLoad may store Personal Information, and it may be included in databases owned and maintained by FitLoad’s agents or service providers.

Using the Site. When you use and interact with the Site, FitLoad also receives and stores additional Personal Information, and such information may or may not be personally identifying information. This information includes, without limitation, your internet protocol address, browser types, domain name, and other statistical data relating to your use of the Site and/or our services. This information is collected passively by means of various technologies or may be provided by you through communications with the Site or FitLoad.

Because of the way the internet operates, when you visit the Site we automatically receive the uniform resource locator of the webpage you were on before and of the webpage you go to after the Site. FitLoad also receives your computer’s internet protocol address, the type of operating system and web browser you are using, your location, the date and time of your access, pages viewed on the Site and other information relating to your visit to the Site.

When you interact with the Site’s or FitLoad’s customer service, FitLoad may also collect information in order to assist you and to improve the operation of the Site.

Performance Metrics: We generate metrics from your information to help you analyze your performance, such as training load, fatigue, fitness and readiness estimates, heart-rate and pace zones and race-time predictions.

Information From Other Sources

Connected Devices and Apps: We collect information (including Activity Data) from devices and apps you choose to connect to FitLoad, such as Intervals.icu, which may hold data from your Garmin or other devices, and, once our mobile apps are available, Apple Health or Google Health Connect. If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.

Third-Party Accounts: You can sign up and log in to the Services using accounts with other businesses, such as Intervals.icu (“Third-Party Accounts”). We will collect information such as your name, email address, profile information, and preferences if you access the Services through Third-Party Accounts. To control the information we receive from Third-Party Accounts, you must use the privacy controls in your Third-Party Account.

Service Providers: We may collect information through our service providers, such as when we collect your feedback through surveys and questionnaires or when Stripe or Apple tells us about a purchase.

Other Users’ Information: We may collect information about you from other FitLoad users.

FitLoad uses “cookies.” A cookie is a piece of information that the Site provides to your computer when you access the Site. FitLoad uses cookies to track your usage of the Site, trends in the usage of the Site and to improve the Site and analyze and assess changes to, successes and failures of the Site and portions thereof. Members who do not want cookies placed on their computers should set their browsers to block cookies. If the ability to accept cookies is disabled, some features of the Site may not function properly. We also use other programs, software and/or applications to analyze typical user behavior.

FitLoad may also collect information through other commonly used techniques, including without limitation, (i) through your browser, computer, mobile device, or tablet to ensure Site functionality, (ii) though pixel tags, web beacons, or clear GIFs; or (iii) through your IP Address. Some or all of the features of the Site may not function properly if you disable our ability to collect or obtain information through any of the above-referenced means. To ensure the availability of the Site and for security purposes, FitLoad may also use programs, software and/or applications to monitor network traffic, to identify unauthorized attempts to upload or change information, or otherwise cause damage to the Site or FitLoad.

FitLoad does not permit third-party advertising cookies, pixels, web beacons or other tracking technologies on app.fitload.ai, in our mobile apps, or on any page of the Site that displays health information.

How We Use Your Personal Information

FitLoad uses your Personal Information in connection with the operation, development and improvement of the Site and other products and services offered by FitLoad, the operation and billing of your account and/or membership, and for other uses consistent with this Policy. FitLoad may use your Personal Information for the following purposes, subject to the limits on health information in this Policy:

to respond to your inquiries and fulfill your requests;
to notify you of important information regarding the Site, products or services for which you subscribe or may be interested in subscribing for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information;
to administer your account and for other membership, subscription and billing purposes;
to permit outside vendors to perform services that the Site requires;
to deliver marketing communications from FitLoad about the Services that we believe may be of interest to you, without using health information;
to personalize your experience on the Site
to provide the Services, including the AI coach;
to verify your identity and/or location so as to allow access to your accounts, and to maintain measures aimed at preventing fraud and protecting the security of account and Personal Information;
for security purposes, risk control, fraud detection and prevention;
to let you participate in surveys and other forms of market research, sweepstakes, contests and similar promotions and to administer these activities (some of these activities may have additional rules, which may contain further information about how Personal Information is used and shared);
to comply with laws, rules or regulations, or with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures or law enforcement process;
to enforce FitLoad’s rights under this Policy, the Terms and Conditions of fitload.ai (the “Terms and Conditions”), or any other agreement, document or policy; or
for general FitLoad business purposes, including, without limitation, data analysis, audits, developing and improving existing and new products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns, and to otherwise manage and operate the Site, develop new services and products and conduct the business and operations of FitLoad.

FitLoad personnel may review your data, including coach conversations, to operate, support, secure and improve the Services.

YOU SHOULD NOT PROVIDE ANY PERSONAL INFORMATION UNLESS YOU CONSENT TO THAT INFORMATION TO BE USED IN ACCORDANCE WITH THIS POLICY.

Provide AI Features: We use and develop machine learning (“ML”) or artificial intelligence (including large language models) (“AI”) to provide features that are designed to improve the Services and enhance your training (“AI Features”). Our AI Features include, for example, protecting the integrity and security of our Services and users and providing personalized training insights. Depending on your sharing permissions and privacy controls, we may also use personal information such as Activity Data for AI Features, for example, to provide training analysis and recommendations to you.

AI Coach Providers: The AI coach is provided by means of large language models of third-party AI providers, such as Anthropic (Claude), OpenAI or Google. When you use the AI coach, we disclose to our AI provider(s) your messages, files you attach and the Personal Information, including health information, that the AI coach requires. The AI providers we use are listed in our list of subprocessors.

Automated Decision-Making: As described above, we sometimes use AI features and automated decision-making to analyze your personal information. However, we do not use these technologies for decisions that have legal or similarly significant effects on you.

You can choose to share your information and content with third-party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with FitLoad to offer an integrated feature, such as a tracking device. Information you provide to these third parties is subject to their terms and policies.

Disconnecting: If you disconnect a Connected Service, information we already imported may remain in your FitLoad account.

Please note that you are responsible for paying any fees or costs you incur in connection with receiving communications from FitLoad, including data, internet, cellular carrier or other similar fees.

Apple Health (iPhone app): We collect information (including Activity Data) from devices and apps you choose to connect to FitLoad, such as the Apple Health app. This could include, for example, workouts, sleep information, heart rate, HRV, or resting heart rate. If we collect health information from Apple Health, we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.

FitLoad recognizes the importance of the privacy of its users and does not lease, sell, share or otherwise provide Personal Information to third parties, except as provided herein. FitLoad will not provide or disclose your Personal Information to any third party except:

as otherwise set out in this Policy, including, without limitation, the internal purposes described above;
to allow a third party to perform services for FitLoad related to the operation, development and improvement of the Site and other products and services offered by FitLoad, and the operation and billing of your account and/or membership, under a contract that requires it to protect your Personal Information at least as well as this Policy requires;
as otherwise required by laws, rules or regulations, or to comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures or law enforcement process;
as reasonably necessary to respond to claims that the rights of third parties have been violated, whether or not the third party is a user, individual, entity or government agency;
as reasonably necessary to enforce FitLoad’s rights under this Policy, the Terms and Conditions, or any other agreement, document or policy;
as reasonably necessary to prevent death or imminent bodily harm and to detect, prevent and address fraud and other illegal activity; or
as reasonably necessary to protect the property and rights of FitLoad or its officers, directors, shareholders, employees or agents.

In connection with the marketing and promotion of the Site, FitLoad may post and use any testimonials that you have provided about the Site. Testimonials and other marketing, promotions and advertisements may contain obfuscated Personal Information that you have provided to FitLoad (such as first name and general location).

FitLoad may also disclose your Personal Information to a third party as part of a sale of the equity interests or assets of FitLoad, as the result of a proposed or actual change in control of the company, or in connection with any financing of or investment in FitLoad by a third party, except that FitLoad discloses consumer health data only as part of an actual sale of FitLoad or its assets or change in control, and not to prospective investors or financing sources. Any successor or assign of FitLoad, including, without limitation, any third party to which FitLoad transfers or sells FitLoad’s assets or to which the owners of FitLoad transfer their equity interests, by any means, will have the right to continue to use your Personal Information as set forth herein.

When you register, use or interact with the Site, FitLoad may also learn, collect and use certain Non-Personal Information. This Non-Personal Information may include, without limitation, demographic information, or data, information and other metrics concerning access to and use of the Site. FitLoad does not provide Personal Information or Non-Personal Information to advertisers.

We never use consumer health data for advertising, marketing or sale. We may create de-identified data from Your Data to develop and improve our models. We will (a) take reasonable measures to prevent it from being linked to you or your device, (b) publicly commit not to attempt re-identification, and (c) contractually require recipients to do the same. Data from Apple Health is used only for the health-management purposes described in this Policy. We don't share identifiable data with third parties to train their models.

Your Privacy Rights and Choices

Access to and Protection of Your Personal Information. You have a right to access, modify, correct and request that FitLoad internally delete any of your Personal Information obtained by or provided to the Site or FitLoad. To the extent that such Personal Information cannot be modified or corrected in your user profile by logging into your account and going to Settings, any other request for access, modification, correction or deletion of your Personal Information, or a part thereof, should be addressed to legal@fitload.ai. If you update, modify or correct any such Personal Information, we may retain copies of your Personal Information from before such update, modification or correction for uses provided for in this Policy. You may request internal deletion of your Personal Information at any time by contacting FitLoad in the manner set forth below, provided that FitLoad may retain, use and disclose your Personal Information as set forth in this Policy. FitLoad will endeavor to respond to your request in a timely fashion. You recognize, acknowledge and agree that the Site and certain FitLoad products and services require Personal Information as a condition to their availability to you, or as part of their functionality, and that to the extent you withhold or delete Personal Information, the Site and other products and services may be unavailable to you or their functionality may be limited.

You may withdraw your consent at any time by contacting FitLoad at legal@fitload.ai.

Additionally, California residents may request and obtain from FitLoad a list of what Personal Information (if any) of such user we disclosed to third parties for that third-party’s direct marketing purposes in the preceding calendar year and the names and addresses of those third parties by making such request to FitLoad at legal@fitload.ai. Requests may be made only once a year and are free of charge. California residents may opt-out of the disclosure of Personal Information to third parties for use by such third party in direct marketing by making such request to FitLoad at legal@fitload.ai. Please note that this opt-out does not prohibit disclosures made for non-marketing purposes, for purposes of assisting us with our own marketing, or for any other purpose permitted by this Policy.

Australian residents may request access to or correction of Personal Information. To access your Personal Information, please get in touch with FitLoad at support@fitload.ai. We may charge for this service and will respond to reasonable requests as soon as practicable and, in any event, within the time limits that the law prescribes. If you have any complaints about how FitLoad handles your Personal Information, please contact FitLoad at support@fitload.ai with a detailed description of the complaint. FitLoad responds to complaints as soon as practicable and, in any event, within the time limits that the law prescribes.

Notice For Individuals Residing In Certain US States

Residents of particular US states, such as California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, and other states to the extent they enact similar privacy laws, may have additional rights under your corresponding state laws (collectively, “US State Privacy Laws”).

Categories of Personal Information Shared and the Categories of Third Parties to Whom it was Shared: Our Policy explains how we collect, use, and disclose your personal information.

The table below describes the categories of information we have disclosed to third parties for business purposes in the last twelve months, and the categories of those third parties.

Category of Personal Information	Service providers	Other parties*
Identifiers, such as your name, email address, IP address, and other similar identifiers	Yes	Yes
Personal information categories listed in the California Consumer Records statute, such as name.	Yes	Yes
Protected characteristics under California or federal law, such as age and gender	Yes	Yes
Sensitive personal information, such as precise geolocation and health information	Yes	Yes
Commercial information, such as subscription history or status	Yes	Yes
Internet or similar network activity	Yes	Yes
Geolocation information	Yes	Yes
Audio, electronic, visual, or similar information, for example photos	Yes	Yes
Inferences drawn from any of the above-listed categories of information, such as commercial behavior	Yes	Yes

Other parties means parties with whom you direct us to share information, government entities or law enforcement or other third parties if we believe doing so is necessary to comply with a legal obligation or prevent harm.

Categories of Personal Information Shared and the Categories of Third Parties to Whom it was Shared: We do not sell personal information for monetary value. We do not “sell” or “share” the personal information of users we know are under 16 years old.

Data Subject Rights: Only you, or someone legally authorized to act on your behalf, may make a request relating to your personal information. Please see Your Privacy Rights and Choices for a list of the rights we provide to you and for how to exercise them. Below, we describe additional rights that may be available to you under US State Privacy Laws.

Opt Out of Sharing for Targeted Advertising: You have the right to opt out of sharing your personal information for targeted advertising. FitLoad does not sell your personal information or share it for targeted advertising. You can broadcast an Opt-Out Preference Signal, such as the Global Privacy Control. Note that Do Not Track (DNT) is a privacy preference that you can set in browsers, but we do not currently process DNT signals.
Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information for purposes other than with your consent to provide the Services, or as otherwise permitted by law.
Non-Discrimination: We will not discriminate against you because you exercise any of your US State Privacy Law rights.
Appeal: You may have the right to appeal our decision on a request relating to your privacy rights.

Authorized Agents: You may appoint an authorized agent to exercise, on your behalf, any of your privacy rights. To verify that your authorized agent is acting on your behalf, we will ask your agent for proof and may require that you also verify your identity.

Any Personal Information you provide to FitLoad will be protected in a manner that is commercially reasonable. Although we will take these measures to protect your Personal Information, “perfect security” does not exist, and we cannot guarantee that your Personal Information will be secure in all situations. FitLoad recommends that you take additional measures to protect yourself and your information, such as installing anti-virus software, closing browsers after use, keeping your log-in credentials and passwords confidential, and making sure that you regularly update software and apps you have downloaded so that you have enabled the latest security features on your devices.

Retention of Information

Subject to our legal obligations, we retain information for as long as needed to provide the Services. We generally retain information associated with your account until you delete it or we no longer need the information to provide the Services. When making these determinations, we consider the amount, nature, and sensitivity of the personal information, the purposes for which we process it, whether we can achieve those purposes through other means, and applicable legal requirements.

Do Not Track

We do not track our members over time and across third party websites to provide targeted advertising, and we therefore do not respond to Do Not Track (DNT) signals.

Links to Other Websites

We are not responsible for the practices used by websites linked to or from the Site, nor the information or content contained therein. Please remember that this Policy is no longer in effect when you use a link to go from the Site to another website. Your browsing and interaction on any other website, including websites that have a link on the Site, are subject to that website’s own rules, terms and conditions, and/or policies.

Children

The Site is not directed at individuals under the age of 13. FitLoad does not intentionally collect any information on the Site from those we actually know to be under 13; in fact, registration for and use of the Site by persons under the age of 18 is expressly prohibited. If we learn that we have collected any information, including without limitation Personal Information, from a person under age 13, we will take steps to remove that information.

Miscellaneous

FitLoad reserves the right to revise this Policy at any time without prior notice to you. By using the Site, you agree to be bound by the then-current version of this Policy, and your continued use of the Site reaffirms your agreement to the then-current Policy. You agree to regularly consult the Site for up-to-date information about this Policy. Without limiting the foregoing, FitLoad will post any revisions of this Policy on the Site and notify you that a revised Policy has been posted through your electronic mail address contained in your user account. It is solely your responsibility to ensure that this address is a current address and that you monitor this address for communications from FitLoad. Any revisions to the Policy will be effective five (5) business days from posting of such revisions to the Site for existing users, and shall be effective immediately for new users.

This policy also applies, in addition to the Site, to any FitLoad mobile applications and any Personal Information or other information that we may collect through such applications.

This Policy is incorporated into and part of the Terms and Conditions. To review the full Terms and Conditions for the Site, please visit https://fitload.ai/terms . If the terms of this Policy conflict with or are inconsistent with any provision of the Terms and Conditions, the Terms and Conditions shall govern.

If any provision of this Policy is found by a court of competent jurisdiction or arbitrator to be illegal, void, or unenforceable, the unenforceable provision will be modified so as to render it enforceable and effective to the maximum extent possible in order to effect the intention of the provision; and if a court or arbitrator finds the modified provision invalid, illegal, void or unenforceable, the validity, legality and enforceability of the remaining provisions of this Policy will not be affected in any way

IF YOU DO NOT AGREE WITH ANY TERM OR PROVISION OF THIS POLICY, PLEASE EXIT THE SITE IMMEDIATELY. PLEASE BE ADVISED THAT YOUR CONTINUED USE OF THIS SITE OR THE PRODUCTS OR INFORMATION PROVIDED THEREBY SHALL INDICATE YOUR CONSENT AND AGREEMENT TO THIS POLICY.

Any claim under this Policy or otherwise related to the Site or FitLoad shall be governed by the laws of the State of Delaware without regard to its conflict of law provisions, and, subject to the Dispute Resolution section of our Terms, shall be exclusively resolved by a state or federal court located in the State of Delaware. You agree to submit to the personal jurisdiction of the courts located within the State of Delaware, for the purpose of litigating all such claims. Notwithstanding the above, you agree that FitLoad shall still be allowed to apply for injunctive remedies (or an equivalent type of urgent legal relief) in any jurisdiction, and shall be entitled to enforce a judgment against you in any jurisdiction.

The Site, and FitLoad’s other products and services, are directed solely to individuals residing in the United States. We don't currently offer the Services to people in the UK or EEA. Those who choose to access and use the Site, and FitLoad’s other products and services, from other locations do so at their own risk, and are responsible for complying with all laws, rules and regulations applicable thereto. FitLoad reserves the right to limit the availability of the Site, and any other products or services of FitLoad, to any person, geographic area, or jurisdiction, in any manner and at any time, in its sole discretion.

Questions about this Policy should be addressed to legal@fitload.ai. If you would like a physical or electronic copy of this Policy, please address the request to legal@fitload.ai. If we need, or are required, to contact you about any event that involves any of your Personal Information that we collect, use, or share, we may do so by electronic mail, telephone, or mail using the number or address we have on file for you.

GDPR Supplement

This GDPR Supplement to the Privacy Policy (the “GDPR Supplement”) of fitload.ai (the “Site”), is hereby made effective as of October 28, 2026, by Scaling Reason LLC, a Delaware limited liability company (“FitLoad” or “we” or “us” or “our”), and supplements that certain Privacy Policy of FitLoad (the “Privacy Policy”), for the citizens of the European Union (the “EU”) described below. We don't currently offer the Services in the UK or EEA, but if you use them from there, this section applies to you.

This GDPR Supplement is intended to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of Such Data, and Repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR”).

This GDPR Supplement applies only to, and is directed to, citizens of the European Union, to whom FitLoad offers goods or services, or who access the Site and may be subject to monitoring or the collection of personal data by FitLoad (“you” or “your” or “EU User” or “EU Member”), as when you browse the Site, register for a membership, or use our goods or services or other materials available on or through the Site, you will be providing certain information to us that could be used to identify you, and we will learn, collect, use and share certain information about you for various purposes, as more fully set forth in the Privacy Policy and this GDPR Supplement.

1. Contact Information

If you have questions regarding the Privacy Policy or this GDPR Supplement, then you should contact FitLoad at legal@fitload.ai.

Likewise, if you desire to exercise a right described Paragraphs 2 through 9, below, and your exercise of that right requires you to contact FitLoad, then you should contact FitLoad at legal@fitload.ai.

2. Right to Access

You have a right to confirmation by FitLoad as to whether FitLoad is processing your personal data and, if that is the case, you have a right to access the following information:

the purpose of the processing;
the categories of personal data concerned;
the recipients, or categories of recipients, to whom your personal data have been or will be disclosed;
the envisaged period for which your personal data will be stored or the criteria used to determine that period;
the existence of your right to rectification (described below);
the existence of your right to erasure (described below);
the existence of your right to restrict processing (described below);
the existence of your right to object to processing (described below);
the existence of your right to lodge a complaint with a supervisory authority (described below);
whether FitLoad uses your personal data for automated decision-making and, where that is the case, the logic involved and the significance and envisaged consequences to you;
where FitLoad does not collect your personal data directly from you, the existence of your right to information about FitLoad’s source of your personal data; and
where FitLoad intends to transfer your personal data to a third country or international organization, the existence of your right to be informed of the appropriate safeguards used in connection with the transfer.

Your right to access includes the right to obtain a copy of the personal data that FitLoad is processing. In compliance with the GDPR, FitLoad will provide one such copy free of charge, but FitLoad may charge a reasonable fee for any further copies.

3. Right to Rectification

You have a right to obtain from FitLoad the rectification of inaccurate personal data relating to you. In addition, taking into account the purposes for which FitLoad is processing your personal data, you have a right to obtain from FitLoad the completion of incomplete personal data relating to you.

4. Right of Erasure

A. General Rule

You have a right of erasure to obtain from FitLoad the erasure of your personal data on any of the following grounds:

your personal data is no longer necessary in relation to the purposes for which FitLoad collected or otherwise processed your personal data (subject to the exceptions described in Paragraph 4(B), below);
FitLoad collected or otherwise processed your personal data on the basis of your consent and you have since withdrawn your consent (subject to the exceptions described in Paragraph 4(B), below);
you have exercised your right to object to processing (described below) and there are no overriding legitimate grounds for FitLoad to continue processing your personal data;
FitLoad has unlawfully processed your personal data;
compliance with a legal obligation imposed by the EU or the law of any “member state” of the EU (a “Member State”), to which FitLoad is subject, requires the erasure of your personal data; or
FitLoad has collected your personal data in relation to the offer of information society services, i.e., an offer for a service normally provided for remuneration, at a distance (the parties are not simultaneously present), by electronic means, and at the individual request of the recipient of the service.

B. Exceptions

Your right to erasure described in Paragraph 4(A), above, does not apply if FitLoad’s processing of your personal data is necessary for:

exercising the right of freedom of expression and information;
complying with a legal obligation imposed by the EU or any Member State to which FitLoad is subject or for carrying out a task in the public interest; or
establishing, exercising, or defending legal claims.

5. Right to Restrict Processing

You have a right to restrict FitLoad’s processing of your personal data where any of the following applies:

you contest the accuracy of your personal data that FitLoad is processing, (for a period sufficient to allow FitLoad to verify its accuracy);
FitLoad’s processing of your personal data is unlawful but you object to the erasure of your personal data;
your personal data is no longer necessary in relation to the purposes for which FitLoad collected or otherwise processed your personal data, but you require your personal data for the establishment, exercise, or defense of legal claims; or
you have exercised your right to object to processing (described below), (pending verification that FitLoad has overriding legitimate grounds to process your personal data).

If you exercise your right to restrict processing, and if your exercise of said right is valid, then FitLoad can store your personal data but cannot otherwise process your personal data without your consent, unless otherwise processing your personal data is necessary for the establishment, exercise, or defense of legal claims, the protection of the rights of another natural or legal person, or for reasons of important public interest of the EU or a Member State.

6. Right to Object to Processing

A. Right to Object to Processing on the Basis of Your Particular Situation

Where FitLoad’s processing of your personal information is necessary for the performance of a task carried out in the public interest or for legitimate interests pursued by FitLoad, you still have a right to object, on grounds relating to your particular situation, to FitLoad’s processing of your personal information. If you exercise your right to object to processing described in this Paragraph 6(A), FitLoad cannot process your personal data unless FitLoad demonstrates that it has overriding legitimate grounds to process your personal data.

B. Right to Object to Processing for Direct Marketing Purposes

You have a right to object to the processing by FitLoad of your personal information for direct marketing purposes. If you exercise the right to object to processing described in this Paragraph 6(B), FitLoad cannot process your personal information for purposes of direct marketing.

7. Right to Data Portability

Where FitLoad’s processing of your personal data is based on your consent or is necessary for the performance of a contract to which you are a party or is necessary to take steps at your request prior to entering into a contract, and where FitLoad’s processing of your personal data is carried out by automated means, you have a right to data portability. This means you have a right to receive from FitLoad a copy of the personal data you provided to FitLoad in a structured, commonly used, and machine-readable format. Additionally, this means that you have a right to require FitLoad to transmit directly to a third party the personal data you provided to FitLoad, provided that such transmission is technically feasible and provided further that such third party is a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing personal data.

8. Right to Withdraw Consent to Processing

You have a right to withdraw consent where FitLoad’s processing of your personal data is based on your consent. However, your withdrawal of consent will not affect the lawfulness of FitLoad’s processing of your personal data prior to your withdrawal of consent.

9. Right to Lodge a Complaint with a Supervisory Authority

If you believe that FitLoad’s processing of your personal data is unlawful or otherwise improper, you have a right to lodge a complaint with a Supervisory Authority. A “Supervisory Authority” is an independent public authority established by a Member State pursuant to Article 51 of the GDPR. You should contact the Supervisory Authority that was established by the Member State of which you are a citizen. If you are unable to identify that Supervisory Authority, then you may contact FitLoad using the contact information provided in Paragraph 1, above. FitLoad will use its best efforts to help you identify that Supervisory Authority.

10. Intention to Transmit Your Data to a Third Country

The personal data FitLoad collects is transmitted over the internet. FitLoad uses several safeguards to protect the transmission of your personal data. These safeguards include the encryption of certain data and other commercially reasonable practices and measures. If you would like more information about these safeguards, then you should contact FitLoad using the contact information provided in Paragraph 1.

Notice to Individuals in the EEA, UK, Switzerland, Brazil and Other Regions

The following is additional information in accordance with data protection laws in the European Economic Area (“EEA”), the United Kingdom (“UK”), Switzerland, Brazil, and other relevant jurisdictions.

Legal Bases: Under certain data protection laws, we must identify a valid legal reason (called a “legal basis”) before we collect, use, share or otherwise process your personal information. Common legal bases include:

Contract: When processing personal information is necessary to perform our contract with you (our Terms) or to take steps at your request prior to entering into a contract.
Consent: When you’ve given us permission to use your information for a specific reason. You have the right to withdraw your consent at any time.
Legitimate interests: When we use your information in ways that are expected and that do not unfairly impact your rights.
Legal obligation: When we’re required by law to process your information.

The table below summarizes the legal basis on which FitLoad processes data for certain purposes. The specific data that is processed will depend on how you use FitLoad, your devices, your account settings, and your device settings.

Why and how we process data

What data is processed

Legal basis

To provide FitLoad’s Services.

Examples of processing activities:

Create and update your account
Process your subscription
Generate your training plan
Record your training activities
Analyze your performance
Manage your training
Enable GPS-based activities
Visualize your activities
Personalize your experience
Provide personalized training insights using AI and ML
Assist you with a request
Contact you about the Services
Account Information
Profile Information
Support Information
Content You Share
Activity Data
Location Information
Usage Information
Performance Metrics
Device Information
Payment Information
Third-Party Accounts Information
Other Users’ Information