Privacy policy

Last updated: 17 August 2026

trAIn processes data about your health and your training. This page explains exactly which data, what for, who it is shared with and what you can do about it. It is written to be read, not to cover ourselves.

1. Who is responsible

Data controller: Santiago Acero Marchesotti
Spanish tax ID (NIF): 02577340Y
Address: Calle Arroyofresno 25, Escalera A, 1.º izquierda, 28035 Madrid
Contact: santiago.acero@yourtrainapp.com

The company behind trAIn is Fergasan Acero, S.L. (Spanish company tax ID B86266756), owner of the domain yourtrainapp.com and the entity that will operate the app. While the closed beta lasts, the person identified above is the one who decides what happens with your data and is answerable for it, not the company. That responsibility will pass to Fergasan Acero, S.L. when the app is published, and you will be told before it happens.

2. What data we process

What you give us when you sign up

Data	What for
Sign in with Apple identifier	To identify your account. We do not receive your name or your email if you choose to hide them
Date of birth	To verify the minimum age and to calculate physiological references. It cannot be changed afterwards
Goal, availability and self-reported level	To build your plan

What we read from the Health app, with your permission

This is health data and therefore special category data. We only read it if you give us permission, and each block is asked for separately:

Block	What it includes
Training	Workouts, duration, distance, pace, heart rate, cadence, power and the second-by-second series where they exist
Recovery	Sleep, heart rate variability, resting heart rate, respiratory rate, wrist temperature, oxygen saturation and VO₂max
Body composition (optional)	Weight, body fat percentage and lean mass
Location (optional)	The GPS route of your workouts and your city, for the map and the weather. The app works fully without this

What you generate by using the app

Your check-in answers: how you feel, perceived effort and discomfort.
Your conversations with the coach.
Notes you write about injuries, restrictions or preferences.
Basic app usage (which screens are opened), with no health data and no content from your messages.

3. On what legal basis

Processing	Basis
Providing you the service: account, plan, adaptations	Performance of the contract — GDPR Article 6(1)(b)
All health data	Your explicit consent — GDPR Article 9(2)(a)
Location, body composition and usage analytics	Your consent, given separately for each one — Article 6(1)(a)
Security and error detection	Legitimate interest in keeping the service working — Article 6(1)(f)

You can withdraw any consent whenever you want from within the app. Withdrawing it does not affect what was done before, and the app keeps working with whatever remains.

4. Who else sees it

Who	What for	Where
Hetzner Online GmbH	The servers the app runs on	Germany (EU)
Anthropic	Generating the coach's explanations and replies	United States
Apple	Sign-in and notifications	Per their terms
Functional Software (Sentry)	Technical error reports	European Union

What NEVER leaves our servers towards third parties: your health values and the content of your conversations are not sent to the error-reporting or analytics systems. That is filtered in the code, not entrusted to an internal policy. And we do not sell your data and we do not use it for advertising.

Transfers outside the European Union

To generate the coach's replies, the necessary context about your training is sent to Anthropic, in the United States. That transfer relies on the European Commission's Standard Contractual Clauses, incorporated into Anthropic's data processing agreement through its Commercial Terms.

If you would rather this did not happen, you can simply not use the chat: the plan and its adaptations are calculated on our own servers, in the EU, with no external model involved.

5. For how long

For as long as your account is open.
When you delete it, your data is erased within 7 days.
We only keep what the law requires us to keep, and only for as long as it requires.

6. Your rights

You can exercise all of them by writing to santiago.acero@yourtrainapp.com. Two of them are also available inside the app:

Access and portability: export everything we hold about you as a file, from Profile.
Erasure: delete your account and all its content, from Profile.
Rectification, restriction and objection.
Withdrawing your consent at any time.

And you can lodge a complaint with the Spanish Data Protection Agency if you believe we are not doing this well.

7. Minors

trAIn is not directed at anyone under 16. Age is checked before the account is created and, below that threshold, the account is never created.

8. This website

It uses no cookies, no analytics and no third-party resources. Visiting it leaves no trace of you with anyone.