Privacy Notice

Last updated: 2026-04-16

Intro

Training Club ("we") welcomes you. This Privacy Notice ("Privacy Notice") applies to our application available on the App Store and Google Play ("App").

The Privacy Notice describes which of your personal data the App collects, how stores, processes, and uses it, and what happens when you use the App.

Content

• About us
• About you
• Personal data
  • Sources of data
  • Lawful bases for processing
  • Users' data
  • Consumers' data
  • Author's data
  • Data received from third parties
• Data sharing with third parties
• Data protection
• Data subjects rights
  • Residents of Ukraine
  • European Economic Area residents
  • Data sharing outside the European Economic Area
• Privacy Notice updates

About us

We are the controller of your personal data processed through the App. This means that we determine the purposes, scope, and means of personal data processing.

About you

When you visit the App, you become our user ("User").

We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.

Please note! We do not knowingly process the personal data of Users under the age of 18. If you are such a User or the legal representative of such a User, please contact us.

Personal data

Sources of data

We receive your data when you visit the App and interact with it, depending on your actions on the App.

You can change your personal data by exercising your right to rectification or by the App functionality. Please note that the same lawful basis and storage terms apply to the changed data.

We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.

Lawful bases for processing

To process your personal data, we rely on the following lawful bases:

• performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms and Conditions) with you;
• legitimate interest — for the processing necessary for the development of our services, taking into consideration your interests, rights, and expectations;
• legal obligation — for the processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorized public body;
• consent — for additional specific purposes.

If we collect personal data on the basis of legitimate interest or performance of the contract, we can use it for another purpose after checking that the new purpose is compatible with the original purpose.

When your data processing is based on a legal obligation or performance of the contract, you are obliged to provide your personal data. We need this data to comply with legal requirements or to properly provide you with our services. The failure to provide such data may have negative consequences, such as tax liability, inability to enter into a contract or provide services to you, etc.

Users' data

When you visit the App, we collect some data automatically. We collect some technical data about the Users to optimize performance, debug issues, and enhance features while ensuring security and privacy to improve the overall user experience.

Most of the technical data we collect are anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.

Data storage. We store the data for 3 years from its collection to respond to potential disputes and prevent misuse or fraud.

Consumers' data

We collect your personal data when you register and access content within the App.

Data storage. The data is retained for the duration of the Terms and Conditions and for a further three years following their termination.

Author's data

We collect your personal data when you complete the trainer questionnaire and upload content to the App.

Data storage. The data is retained for the duration of the Terms and Conditions and for a further three years following their termination.

Data received from third parties

We may receive some personal data from third parties.

The amount of data collected, the purposes, and the lawful basis for processing are determined by the respective privacy documents of these third parties.

Data sharing with third parties

We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organizational and technical measures to ensure the security of personal data during data transfer to third parties.

To get a detailed list of the third-party recipients of your personal data, contact us.

To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.

Data protection

We apply a variety of security measures appropriate to the possible risks.

Organisational measures

• Action plan in the event of unauthorised access to personal data

Physical measures

• Limited access to premises

Technical measures

• Automatic deletion of data upon expiry of the retention period
• Backups
• Encryption of data

Data subjects rights

You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency. To exercise your rights, contact us.

Residents of Ukraine

Please note! We may ask you to verify your identity before responding to your request. We will process your request and respond to you within 30 days of receiving it.

European Economic Area residents

We will answer your request within one month. If your request is not satisfied, you can submit a complaint to your local Data Protection Authority.

Data sharing outside the European Economic Area

We may share personal data with the recipients of other countries, including non-EEA ones, ensuring that your data is protected and processed in accordance with the General Data Protection Regulation.

To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient.

If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.

You can read more detailed measures to protect your personal data here.

Privacy Notice updates

This Privacy Notice is developed according to the Law of Ukraine "On personal data protection", General Data Protection Regulation, other applicable privacy laws, and best privacy practices.

Existing laws and requirements for processing personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the App.

If there are material changes to the Privacy Notice or the App that affect your data privacy rights, we will notify you by displaying information on the App and, if necessary, ask for your consent.