Privacy Policy

1. Data Controller & Scope

Szymon Traczyk Running Coach
ID: 7282909155
Contact: contact@strunning.coach.

This Policy applies to coaching services provided by Szymon Traczyk and integration with the TrainingPeaks ecosystem.

2. Detailed Data Processing Activities

2.1. Identity & Contact

• Data Scope: Name, email, TrainingPeaks ID

• Legal Basis (GDPR): Art. 6(1)(b) (Contract fulfillment)

• Sensitive Data (CCPA): No

• Retention Period: Duration of contract + 3 years (statute of limitations for claims)

2.2. Health Data

• Data Scope: Heart Rate (HR), HRV, weight, injuries, perceived exertion

• Legal Basis (GDPR): Art. 9(2)(a) (Explicit Consent)

• Sensitive Data (CCPA): Yes

• Retention Period: Until consent is withdrawn or end of coaching + 1 year

2.3. Precise Geolocation

• Data Scope: GPS logs, route maps, elevation data

• Legal Basis (GDPR): Art. 9(2)(a) (Explicit Consent)

• Sensitive Data (CCPA): Yes

• Retention Period: Same as Health Data

2.4. Financial Data

• Data Scope: Payment history, billing address, tax info

• Legal Basis (GDPR): Art. 6(1)(c) (Legal Obligation)

• Sensitive Data (CCPA): No

• Retention Period: 5 years from the end of the fiscal year

2.5. Marketing & Analytics

• Data Scope: IP address, cookies, website usage patterns

• Legal Basis (GDPR): Art. 6(1)(f) (Legitimate Interest)

• Sensitive Data (CCPA): No

• Retention Period: Up to 24 months

3. Sources of Data

I process data provided directly by you and data imported from third-party wearable devices (e.g., Garmin, Polar, Suunto, Apple Watch) via your TrainingPeaks account. By syncing these devices, you authorize the transfer of this data to the Coach for analysis.

4. International Transfers & Sub-processors

I utilize specialized SaaS providers located in the USA:

• Peaksware LLC (TrainingPeaks): Core performance platform.

• Stripe, Inc.: Payment processing.

• Google Workspace: Communication and cloud storage.

Safeguards: Transfers are based on the EU-U.S. Data Privacy Framework. Where the framework does not apply, I implement Standard Contractual Clauses (SCCs) and have performed a Transfer Impact Assessment (TIA) to ensure a level of protection equivalent to the GDPR.

5. Your Rights & The Right to Object

Under GDPR/UK GDPR, you have the right to access, rectify, and erase your data.

NOTICE ON THE RIGHT TO OBJECT: You have the absolute right to object at any time to the processing of your personal data based on Art. 6(1)(f) (Legitimate Interest).

To exercise your rights or withdraw consent for health/GPS data processing, contact: contact@strunning.coach. Note: Withdrawal of consent for health data results in the inability to provide personalized coaching plans.

6. California Privacy Rights (CCPA/CPRA)

• Right to Limit: You may limit the use of your SPI to what is necessary to perform coaching services.

• No Sale/Sharing: I do not sell your personal information or share it for cross-context behavioral advertising.

• Right to Know/Delete: California residents may request a report on data categories collected in the last 12 months.

7. Automated Analysis vs. Human Coaching

My methodology utilizes TrainingPeaks metrics (TSS®, CTL, TSB). These are mathematical calculations of physiological load. However, no automated decision-making occurs. All training adjustments, periodization, and recovery protocols are manually reviewed and implemented by the Coach.

8. Cookies

I use "Essential" cookies (session management) and "Analytical" cookies (Google Analytics 4). You may opt-out via your browser or the cookie banner on strunning.coach.