PRIVACY POLICY

Preamble

What are we talking about?

Personal data refers to any information that can be used to identify you, either directly or indirectly: your contact information (last name, first name, address), as well as your IP address, a photograph, your workout data, etc.

This Policy applies to individuals (hereinafter referred to as “Users” ), whether they are private individuals ( “Athletes” ) or professionals (coaches, club managers, dietitians, etc.), who browse the azeoo.com website or use the free and paid sports training and nutrition features offered by AZEOO via its web and mobile platforms (the “AZEOO Services ”).

It is based primarily on Regulation (EU) 2016/679 of April 27, 2016 ( “GDPR” ) and Law No. 78-17 of January 6, 1978, as amended ( “Data Protection Act ”).

Where can I find information about myself?

• This Privacy Policy: How We Process Your Personal Data;
• The Athlete Terms and Conditions and the Business Terms and Conditions: the terms and conditions governing our offers;
• The Cookie Policy (azeoo.com/cookies): details on the trackers used and how to accept or reject them;
• Legal Notice (azeoo.com/legal-notice): Information about AZEOO.

1. Who is responsible for processing your data?

The data controller is the entity that determines the purposes and means of processing (Articles 4 and 7 of the GDPR). Depending on the processing activities, two situations must be distinguished:

AZEOO is the data controller for the processing activities it decides upon and manages itself: account management, provision and improvement of the Services, billing, security, marketing, and statistics. This Policy describes these processing activities.

AZEOO acts as a data processor when it processes Athletes’ data on behalf of their coach, club, or dietitian (the “Professional”): tracking the programs assigned to you, the history they view, and communications with them. For this data processing, your Professional is the data controller: you can contact them to obtain information about how they use your data and to exercise your rights, while AZEOO assists them in this task in accordance with the data processing agreement entered into with them.

Contact information for the data controller: AZEOO, Simplified Joint-Stock Company (SAS), Lyon Commercial Register No. 813 620 424, 23 rue Crépet, 69007 Lyon, France.

Data Protection Contact: support@azeoo.com, or by mail to the headquarters address listed above.

2. What data do we collect?

Data You Provide to Us

When you create your account and use the Services: last name, first name, gender, email address, username, password (stored in hashed form), profile photo, and any information you voluntarily provide (goals, skill level, content posted on the AZEOO Network, messages).

When certain data is required to access a feature (e.g., recording a performance to track it), this requirement is contractual in nature: without this data, the feature in question may not be available.

Health and Fitness Data

Certain data that you enter or link may reveal information about your health, as defined in Article 9 of the GDPR: physical measurements (weight, height), physical activity and performance data, nutritional data (including any allergies), and sleep data.

• This data is processed only with your explicit consent, which is obtained when you enable the relevant features, and which you may withdraw at any time through your account settings, without affecting the lawfulness of the processing that took place prior to the withdrawal.
• Providing this information is optional and is not required by law, regulation, or contract; failure to provide it will only limit the corresponding tracking features.
• This data is processed solely for the purpose of tracking and personalizing your exercise and nutrition activities (see table, section 3).

Google Fit, Health Connect, and Apple HealthKit

If you choose to connect Google Fit / Health Connect (Android) or HealthKit (Apple), AZEOO may access—with your consent, as expressed in your device’s settings—your weight, height, activities, step count, and sleep data. This connection can be disabled at any time from your device’s or the app’s settings, which will stop the access to this information. The data retrieved is processed under the same conditions as other health data (explicit consent, for monitoring purposes).

Log in via a third-party account (SSO)

If you sign up via Facebook or Apple, we receive from that provider only the information necessary to create your account: name, email address, and, if applicable, a profile photo. We do not control the data processing carried out by these providers on their own behalf; we encourage you to review their privacy policies.

Data Collected Automatically

When using the app and the website: device identifiers and characteristics (model, operating system, app identifiers), IP address, connection and event logs, and usage data for features. This information is used for security, proper operation, troubleshooting, and internal statistics.

The app may request your permission to access certain device features (camera, gallery, storage, Bluetooth) only when the feature you are using requires it (e.g., adding a profile picture). You can change these permissions at any time in your device's settings.

Data Received from Third Parties

When your Professional registers you or links you to their organization, they provide us with the information needed to create your account (name, email address). You will be notified of this no later than when you log in for the first time, in accordance with Article 14 of the GDPR; the source of the data is your Professional.

3. Why, on what basis, and for how long?

The table below summarizes, for each purpose, the legal basis for processing (Article 6 of the GDPR, and Article 9(2)(a) for health data) and the retention period in the active database. At the end of this period, the data is deleted or archived with restricted access for the duration of the statutory retention periods.

Profiling and automated decisions: “Smart Coaching” tailors the content offered (programs, recommendations) based on your goals, your skill level, and your activity data. This profiling does not result in any decisions that have legal effects or significantly affect you within the meaning of Article 22 of the GDPR; you may ignore the recommendations or disable the relevant features at any time.

When processing is based on legitimate interests, you can obtain additional information about the balancing test by contacting us (Section 12).

4. Who receives your data?

Your data is accessible only to those who need it:

• AZEOO’s authorized teams (customer support, technical, sales, and accounting), within the scope of their responsibilities;
• Your professional (coach, club, dietitian), with regard to the data related to the monitoring they provide—they are the data controller for this processing (Section 1);
• Other Users, with regard solely to the content you post on the AZEOO Network: the current settings do not allow you to restrict access to your posts to members of your network; all members have access to them without distinction. Do not post anything you wish to keep private; content that voluntarily discloses health information poses an increased risk to your privacy;
• Our service providers for the following services: web hosting, payment services (Stripe), email marketing and newsletters, customer support and satisfaction tools, accounting and payroll, and web analytics. An up-to-date list of our service providers is available upon request at support@azeoo.com;
• Where applicable, authorities, courts, and judicial officers (attorneys, bailiffs, certified public accountants, and auditors), when required by law or to defend our rights.

AZEOO does not sell your personal data to anyone.

5. Is your data transferred outside the European Union?

Some of our subcontractors are located outside the European Union, primarily in the United States and Canada. In such cases, AZEOO ensures that the transfer is governed by: (i) an adequacy decision by the European Commission (Article 45 of the GDPR), including, for certified U.S. service providers, the “EU-U.S. Data Privacy Framework”; or, failing that, (ii) appropriate safeguards (Article 46 of the GDPR), including the European Commission’s standard contractual clauses, supplemented where necessary by additional technical and organizational measures. Details for each service provider are provided in the list of data processors (Section 4).

6. How is your data secured?

AZEOO implements technical and organizational measures appropriate to the risks, in accordance with Article 32 of the GDPR: encryption of data in transit and at rest, password hashing, access controls and authorizations, logging, regular backups, and staff awareness training. The data is hosted within the European Union by a service provider certified as a “Health Data Host” (HDS). In the event of a data breach that could pose a high risk to your rights and freedoms, you will be notified in accordance with Article 34 of the GDPR.

7. What are your rights?

• Right of access: to obtain confirmation that your data is being processed and to receive a copy of it.
• Right to rectification: to have inaccurate data corrected or supplemented.
• Right to erasure: Have your data deleted, particularly when it is no longer necessary or when you withdraw your consent.
• Right to restriction of processing: to obtain a temporary suspension of processing in the cases provided for in Article 18 of the GDPR.
• Right to object: You may object at any time, for reasons related to your particular situation, to processing based on legitimate interests. For marketing purposes, you may object at any time without having to provide a reason (an unsubscribe link is included in every email, or you may submit a request via Section 12).
• Right to withdraw consent: You may withdraw your consent at any time for processing activities that rely on it (health data, marketing, cookies), without affecting the lawfulness of the processing that took place prior to the withdrawal.
• Right to data portability: to receive the data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Post-mortem directives: Set guidelines regarding the retention, deletion, and disclosure of your data after your death (Article 85 of the French Data Protection Act), and modify them at any time.

You can also correct or delete most of your data yourself directly through the platform. We will respond to your requests within one month, which may be extended by two months for complex requests (in which case you will be notified).

Please note: For matters for which your Professional is responsible (Section 1), you may direct your requests to them directly; if you send them to us, we will forward them to your Professional and assist them in responding.

How to delete your AZEOO account?

Deleting your account affects all AZEOO products (the official app and white-label apps) and results in the permanent deletion of your results and progress; partial deletion is not possible. From the app: Settings → Edit Your Profile → My Account → Delete My Account, then confirm.

Deleting your account does not automatically cancel the renewal of your subscriptions: be sure to cancel your subscription before deleting your account (using the online cancellation feature or, for in-app purchases, through the Apple/Google settings).

How to exercise your rights

By email to support@azeoo.com or by mail: AZEOO – 23 rue Crépet, 69007 Lyon, France. Your request must specify the right(s) you are exercising. If there is reasonable doubt regarding your identity, you may be asked to provide additional information (Article 12(6) of the GDPR); a copy of an ID document will only be requested as a last resort.

Are you entitled to file a claim?

Yes. If you believe your rights have not been respected, you may file a complaint with the National Commission for Information Technology and Civil Liberties (CNIL): www.cnil.fr – 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07. This option does not preclude you from pursuing any other remedies.

8. Minors

AZEOO Services are reserved for adults with full legal capacity. If we discover that an account has been created in violation of this condition, it will be deleted after notifying the account holder.

9. Cookies and Trackers

While you are browsing, cookies and other trackers may be placed on your device by AZEOO or its partners to: ensure the website functions properly (trackers exempt from consent requirements), measure website traffic, personalize content, and, where applicable, display tailored offers.

With the exception of strictly necessary cookies, no cookies are stored without your consent, which is obtained through the banner displayed during your first visit. You can accept, reject, or customize your preferences just as easily in either direction, and change them at any time via the “Manage My Cookies” link on the site. Your browser settings provide an additional way to block cookies.

In accordance with the CNIL’s recommendations, your selection is retained for 6 months, the lifespan of cookies is limited to 13 months, and the information collected through them is not retained for more than 25 months. The site also uses reCAPTCHA (Google) to protect itself from bots: this feature involves cookies that require your consent and a transfer of data to Google.

Details about the cookies used, their purposes, their duration, and the parties responsible can be found in our Cookie Policy: azeoo.com/cookies.

10. Updates to This Policy

AZEOO may update this Policy, in particular to reflect changes in the law or to the Services. In the event of a substantial change (new purpose, new recipients, new transfers), you will be notified individually (via email or an in-app notification) before it takes effect; when new processing is based on your consent, you will be expressly asked for it—simply continuing to use the Services does not constitute consent.

11. Governing Law

This Policy is governed by French law, without prejudice to any mandatory provisions applicable in your country of residence within the European Union. It does not in any way limit your right to file a complaint with the CNIL or to bring a case before the competent courts in accordance with general legal principles.

12. Contact

If you have any questions regarding this Policy or your personal data, please contact us at support@azeoo.com or by mail at AZEOO – 23 rue Crépet, 69007 Lyon, France.