Effective date: July 1, 2018
Thank you for entrusting Trayn with your training data, plans, and your personal information. In this document, we describe how we handle your private information. We’ve tried our best to explain things in a simple and clear way and also maintain a separate FAQ section with simple answers to questions that may arise.
Short version: We use these terms throughout this document, and they have specific meanings.
Refers to Trayn’s website located at trayn.com, and all content, services and products provided by Trayn at or through the Website. It also refers to Trayn-owned subdomains of trayn.com, such as blog.trayn.com, journal.trayn.com, or docs.trayn.com. Occasionally, websites owned by Trayn may provide different or additional terms of service. If those additional terms conflict with this Agreement, the more specific terms apply to the relevant page or service.
- "User Personal Information"
Any information about one of our users which could, alone or together with other information, personally identify them. Information such as an email address, an IP address, a real name, and a photograph are examples for such information.
2. What information Trayn collects and why
Short version: We distinguish between visitors to our Website and users with accounts actually using the service. For visitors to our website, we collect information to better understand how visitors use the Website. For users with accounts, we collect and process data to be able to provide our services and to understand how to improve our services.
2.1. Information from website browsers
If you are browsing the Website, we collect the same basic information that most websites collect: We use common technologies, such as cookies and web server logs. We collect this information from all visitors, whether they have an account or not.
The information we collect about all visitors to our Website includes the visitor’s browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. We also collect potentially personally-identifying information like IP addresses.
We collect this information to better understand how our Website visitors use Trayn, and to monitor and protect the security of the Website.
2.2. Information from users with accounts
If you create an account, we require some basic information at the time of account creation. Name, password, and email address are required. You have the options to add more information, which may include User Personal Information. The Services allow for the storage and processing of data concerning health. You will have to make sure your users have given explicit consent to the processing of those personal data for the purposes of providing the Services.
The information on individual users may be entered by a person with administrative responsibilities. As account owner providing information about someone else, you have to make sure you have the appropriate consent from this person.
User Personal Information does not include aggregated, non-personally identifying information. We may use aggregated, non-personally identifying information to operate, improve, and optimize our website and service.
We need your User Personal Information to create your account, and to provide the services you request, including identifying you when using the Service, or to respond to support requests.
We will use your email address to communicate with you, if you’ve said that’s okay, and only for the reasons you’ve said that’s okay. Please see our section on communication for more information.
We use your User Personal Information for internal purposes, such as to maintain logs for security reasons, for training purposes, and for legal documentation.
We limit our use of your User Personal Information to the purposes listed in this Privacy Statement. If we need to use your User Personal Information for other purposes, we will ask your permission first.
Under certain international laws (including GDPR), Trayn is required to notify you about the legal basis on which we process User Personal Information. Trayn processes User Personal Information on the following legal bases:
When you create a Trayn account, you provide your name and an email address. We require those data elements for you to enter into the Terms of Service agreement with us, and we process those elements on the basis of performing that contract. Trayn does not collect or process a credit card number, but our third-party payment processor, who acts as a controller regarding credit card numbers, does.
When you fill out the information in your user profile, you have the option to provide User Personal Information such as your full name, an avatar which may include a photograph, and additional information. We process this information on the basis of consent. All of this information is entirely optional, and you have the ability to access, modify, and delete it at any time. Even, if this information has been entered by an administrative person in your organization, data relevant to you is under your control.
Generally, the remainder of the processing of personal information we perform is necessary for the purposes of fulfilling our services and our legitimate interests. Examples:
If you want to see a workout individualization using your base heart rate, you will have to enter this information and we can then use this for workout individualization
For security purposes, we must keep logs of IP addresses that access Trayn.
If you would like to request erasure of data we process on the basis of consent or object to our processing of personal information, please contact firstname.lastname@example.org.
2.3. What information Trayn does not collect
We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, or religious information. Although Trayn does not request or intentionally collect any sensitive personal information, we realize that you might store this kind of information in your account. If you store any sensitive personal information on our servers, we store and process your data for the purposes communicated to you when you insert such data. However, you are responsible for complying with any regulatory controls regarding that data.
Trayn is neither intended nor directed to children under 14. Please do not hesitate to contact us if you have knowledge of a minor child that has submitted personal information without the applicable consent of the parent or guardian of such minor child.
3. How you can control sharing of your content
When you use our Service as a registered user to store and manage data such as, but not limited to training, performance, tests, schedules, and other pieces of information, this information is stored in a way so that other members of your sports organization may access it. This information is not automatically shared publicly and not indexed by search engines. You as a registered user can export and delete Reusable Content for which you have appropriate permissions based on the ownership and permission model. The ownership and permission model regulates how you and other users in your organization can use, modify, copy, or export your Reusable Content.
If you as a registered user want to make the information stored in the Service available publicly, you will have to explicitly indicate and give your respective consent. Only then will this information be available to entities outside of your sports organization and may be indexed by search engines. After making information publicly available, it may not be possible to remove all copies of that information, but only such copies of that information which are still stored under our control.
The selection of permission and ownership models may change and changes to these models are communicated to you as a user, if you are affected by these changes. If you do not agree to these changes, you may terminate the service during this period without further incurring charges.
4. How you can access and control the information we collect
As user of Trayn, you may access update, alter, or delete your personal information by editing your user profile, or contacting email@example.com.
4.1. Data portability
As a user of Trayn you can request an export of your data. You will receive a full export and may require some technical skills to be able to import information from Trayn into a different system. You may also have your personal data transmitted directly from Trayn to another controller, where this is technically feasible. Please contact firstname.lastname@example.org with such an export request.
4.2. Data retention and deletion of data
In general, Trayn retain User Personal Information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete data associated with your account within 90 days.
As a paying customer, we will retain your data for at least 6 months after termination. If you decide to "come back" you can continue where you have left off. However, you can always contact email@example.com to request the immediate erasure of the data we have stored.
If requested by your organization, its authorized representatives, or individual coaches and athletes, we will delete the data of individual users, such as a coach or an athlete, as applicable, if such coach or athlete switches organizations or is traded/transfered to another organization.
5. Cookies and Tracking
We provide a web page on cookies and tracking that describes the cookies we set, the needs we have for those cookies, and the types of cookies they are (temporary or permanent). It also lists our third party analytics and service providers and details exactly which parts of our website we permit them to track.
5.2. Tracking and analytics
We use a number of third party analytics and service providers to help us evaluate our users' use of Trayn; compile statistical reports on activity; and improve our content and website performance. We only use these third party analytics providers on certain areas of our website, and all of them have signed data protection agreements with us that limit the type of personal information they can collect and the purpose for which they can process the information. You can request copies of these data protection agreements via email to firstname.lastname@example.org.
In addition, we use our own internal analytics software to provide features and improve our content and performance.
We do not currently respond to your browser’s Do Not Track signal, and we do not permit third parties other than our analytics and service providers to track Trayn users' activity over time on Trayn. We do not track your online browsing activity on other online services over time.
6. How we store and protect your information
Trayn takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information. Your information may be stored and processed in the United States or the European Union.
Transmission of data on Trayn is encrypted using SSH, HTTPS, and SSL/TLS. Trayn enforces a security information program, which
aligns with industry recognized frameworks;
includes security safeguards reasonably designed to protect the confidentiality, integrity, availability, and resilience of our users' data;
is appropriate to the nature, size, and complexity of Trayn’s business operations;
includes incident response and data breach notification processes; and
complies with applicable information security related laws and regulations in the geographic regions where Trayn does business.
In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected users and/or the competent data protection authorities without undue delay. Please help us help you by maintaining the secrecy of your unique password and account log-in information, and for controlling access to email accounts and devices associated with your Trayn account.
7. Privacy practices
We provide the same standard of privacy protection — as described in this Privacy Statement — to all our users around the world, regardless of their country of origin or location. If our vendors or affiliates have access to User Personal Information, they must sign agreements that require them to comply with our privacy policies and with applicable data privacy laws.
We provides clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data using consent as a basis.
We collect only the minimum amount of personal data necessary for our purposes, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
We offer you simple methods of accessing, correcting, or deleting the User Personal Information we have collected. Both as an administrative user, or the owner of the User Personal Information
We provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.
7.1. Compelled disclosure
Trayn may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our legitimate interests, or those of third parties, or the public at large.
In complying with court orders and similar legal processes, Trayn strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
7.2. Resolving complaints
If you have concerns about the way Trayn is handling your User Personal Information, please let us know immediately. We want to help. You may contact us by filling out the Privacy contact form. You may also email us directly at email@example.com.
We will use your email address to communicate with you, if you’ve said that’s okay, and only for the reasons you’ve said that’s okay. For example, if you contact our support with a request, we will respond to you directly through the Service, but follow-up via email, if we cannot respond immediately. We do so for answering your request in order to take steps at your request prior to entering into a contract or fulfilling our contractual obligations.
Depending on your notification settings, Trayn may send you an email for new messages in conversations you are participating in. You may manage your communication preferences in your profile. Please note that you can not opt out of receiving important communications from us, such as mails from our support team or system emails.
Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. Example: If you haven’t replied to a conversation, but we may see that our last message has been read we may not need to follow up.
9. Legal Basis
We have to provide relevant references to the legal basis. This section contains references to the EU General Data Protection Regulation (GDPR).
9.1. General References
We process your data for the performance of our contractual obligations as described in Article 6 (1) lit b of the GDPR. If not for the performance of our contractual obligations, we process your data on another legal basis, such with your consent based on Article 6 (1) lit a of the GDPR. If we process your personal data solely on the basis of your consent, you may withdraw your consent at any time by sending us an email to firstname.lastname@example.org.
Your withdrawal shall have no effects on the legality of our data processing up until the point of our receipt of your withdrawal (see Article 7 (3) of the GDPR), or fulfil our legal obligations (Article 6 (1) lit c of the GDPR) in particular.
User Personal Information includes Personal Data as defined in Article 4 fig 1. of the GDPR.
Data concerning health is used in this document as defined in Article 9 of the GDPR.
9.2. Legal Rights
Under the GDPR, you have the following (additional) legal rights, as a data subject:
Every data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data (copy of the personal data which are the subject of the processing) and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source;(h) the existence of automated decision-making, including profiling. The controller shall provide a copy of the personal data undergoing processing. For all further copies which the data subject requests, the controller may request a reasonable fee on the basis of administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) the data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing; (c) the data subject objects to the processing (see below); (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in the EU or member state law to which the controller is subject;(f) the personal data have been collected in relation to the offer of information society services (consent of a child).The right to erasure does not apply to the extent that processing is necessary for compliance with a legal obligation of the controller, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, and/or for the establishment, exercise or defence of legal claims.
The data subject has the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or (d) the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject. Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. A data subject who has obtained restriction of processing shall be informed by the controller before the restriction of processing is lifted. Right to Data Portability, details in Article 20 GDPR (also see 4.1, below, in this respect): Insofar as the processing is based on consent or a contract and the processing is carried out by automated means, the data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or the purposes of the legitimate interests pursued by the controller or by a third party. The controller shall then no longer process the personal data, except where he proves compelling legitimate grounds for the processing, which override the interests or fundamental rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. If the data subject objects to the processing for the purposes of direct marketing, the personal data shall no longer be processed for this purpose.
Every data subject has the right to file a complaint with a supervisory authority without prejudice to other administrative or judicial legal remedies, in particular in the member state of their residence, their workplace or the place the alleged offense occurred, if the data subject is of the view that the processing of personal data concerning him or her breaches these legal provisions.