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Nevada Consumer Health Data Privacy Policy

Effective: 2026-07-26

This policy applies to consumers in the State of Nevada and is provided under NRS 603A.495. It is separate from, and additional to, our Privacy Policy. Washington consumers should read the Washington Consumer Health Data Privacy Policy.

Controller: DEL PORTAL TECHNOLOGIES S.A.C., Lima, Peru.

Categories of consumer health data collected

Heart-rate and cardiovascular fitness measurements; physical activity and workout information; body measurements; sleep-derived recovery information; fitness and nutrition records; reproductive-cycle information processed locally when the optional Cycle feature is enabled; and fitness-related inferences or derived indicators generated from those data.

Purposes for which the data is used

To provide the features the consumer requests: personalizing training load, recovery and nutrition targets; displaying the consumer's own history and progress; and computing descriptive fitness indicators from the consumer's own information. The data is not used for advertising, marketing or behavioral profiling, and is not used to make any medical determination.

Categories of sources

Information entered directly by the consumer; Apple Health when the consumer grants access; compatible Bluetooth devices; device location and sensors when the consumer starts an outdoor activity; and indicators derived by TrainO from the consumer's own information.

How consumer health data is processed

TrainO processes consumer health data through deterministic software functions used to provide fitness, recovery, nutrition and progress features requested by the consumer. Health information stored on TrainO servers is associated with the consumer's account and processed only for the purposes disclosed in this policy. Optional menstrual-cycle information is processed locally within the App and is not transmitted by TrainO to its backend systems.

Categories shared, and with whom

TrainO does not sell consumer health data and does not share it with third parties or affiliates for their own purposes. Service providers acting as processors may process it on TrainO's behalf where necessary to provide the requested service: Supabase (database, authentication and file hosting) and Sentry (crash and performance diagnostics; a truncated, non-identifying user reference may be attached for debugging only).

Cross-service collection

TrainO does not permit a third party to collect consumer health data through TrainO over time and across unrelated websites or online services for advertising, marketing or profiling purposes.

Exercising rights, review and correction

A Nevada consumer may confirm whether TrainO is collecting or sharing their consumer health data, access it, request its deletion, and withdraw consent to future collection or sharing where processing is based on consent.

To review and correct the data: profile and body measurements can be edited directly in the App under Profile; nutrition and training records can be edited or removed in their respective screens. For anything that cannot be corrected in the App, or to submit any of the requests above, write to privacy@delportaltechnologies.com. TrainO may take reasonable steps to authenticate the consumer before completing a request, and will respond within the timeframe required by Nevada law. If a request is refused, the consumer may appeal by replying to the decision.

Material changes

If TrainO makes a material change to the categories of consumer health data it collects, the purposes for which the data is processed, or the categories of entities with whom it is shared, TrainO will provide notice through the App and, where required, obtain affirmative voluntary consent before applying the new processing to consumer health data.