← Trainbay

Privacy Policy

Last updated: September 26, 2026

1. Data Controller

ZX Consulting LLC, EIN 37-2131941, registered address at 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110 (USA), operates Trainbay (the "Platform") under that trade name. Contact for data protection matters: contact@trainbay.app.

Who is responsible for which data depends on whose data it is:

  • For the trainer's own account and business data (section 2), and for the Platform's own technical data, Trainbay is the data controller.
  • For the data of each trainer's contacts and clients (name, conversations, training profile, health and progress data, payments), the data controller is the trainer: it is their business relationship, and they decide what that data is used for. Trainbay acts as data processor, processing it only on the trainer's instructions and in accordance with the Data Processing Addendum that each trainer accepts when signing up.

2. What Data We Process

From the trainer (Platform user):

  • Account data: name, email, password (encrypted).
  • Business data they configure: business name, pricing, schedule, assistant tone.

From the trainer's contacts and clients:

  • Contact data: name, phone number, email, source channel.
  • Conversations with the assistant and with the trainer.
  • Training profile: goal, level, type of training, restrictions or injuries reported.
  • Health and progress data: height, weight, BMI, progress photos, meal log. This is special category data and is processed only with the client's explicit consent.
  • Payment data: agreed fee and billing history (card details are processed by Stripe, Trainbay never stores them).

3. Purposes and Legal Basis

  • Providing the service (lead and client management, routines, diets, follow-up, billing): performance of a contract.
  • Health data and progress photos: the client's explicit consent, revocable at any time.
  • AI assistant: to capture and qualify leads and to answer nutrition questions. The assistant always identifies itself as AI (Art. 50 of the EU AI Act).
  • Legal obligations (invoicing, tax): where applicable. This includes keeping proof that a client expressly requested that the service start before the end of the withdrawal period (date and time, the text accepted, IP address and browser), recorded when they subscribe.

4. Processors and Third Parties

The following providers are used, under a data processing agreement:

  • Supabase — database, authentication, and file storage (hosted in the EU).
  • Anthropic — the AI model that generates the assistant's replies. It receives the conversation messages and, if the client attaches one, a photo of a menu; this data is not used to train its models.
  • Stripe — payment and subscription processing.
  • Vercel — application hosting.
  • Resend — sending invoice and account emails.
  • Google Cloud — Gemini AI models, used through Google Cloud's Agent Platform with processing located in the European Union, to generate some of the assistant's replies and to transcribe voice notes. Under Google Cloud's terms, this data is not used to train its models.
  • Google — Google Calendar, only for trainers who choose to connect it (see section 4quater).

Data is never sold or shared with third parties for advertising purposes.

4bis. International Transfers

Trainbay is operated by a US entity, and some of the providers listed above (such as Anthropic) process data outside the European Economic Area. Where this happens, it is covered by the Standard Contractual Clauses approved by the European Commission (Implementing Decision (EU) 2021/914) or another transfer mechanism recognized under the GDPR, incorporated by reference into the Data Processing Addendum.

4ter. Meta Platforms (WhatsApp and Instagram)

Trainbay integrates with products of Meta Platforms, Inc. — the WhatsApp Business Cloud API, the Instagram API with Instagram Login (Graph API), and Facebook Login for Business — so that a trainer can receive and reply to leads that message them on WhatsApp or Instagram (direct messages, story replies, or comments) directly inside Trainbay. On Instagram, this uses the permissions instagram_business_basic, instagram_business_manage_messages, and instagram_business_manage_comments — Trainbay does not request public_profile, email, pages_show_list, business_management, or ads_management, and has no consumer "Login with Facebook" flow.

Through these integrations we receive: the sender's phone number (WhatsApp) or Instagram user ID and username (Instagram), their profile name where available, and the content of the messages they send. This data is stored as part of that person's contact record and conversation history in Trainbay, exactly like any other channel described in section 2 — it is used only to let the trainer (and, on their behalf, the AI assistant described in section 3) see and reply to that conversation. It is never used for advertising, never sold, and never shared with Meta beyond what is technically required to send and receive messages through their API.

A trainer can disconnect their WhatsApp or Instagram account from Trainbay at any time from Meta Business Suite or their Instagram account settings; Trainbay receives an automated notification from Meta when this happens (our deauthorize callback). See our Data Deletion Instructions for how to request deletion of data obtained this way.

4quater. Google Calendar

A trainer can optionally connect their Google Calendar so that busy times already in their calendar block availability on their Trainbay booking page, and so that each new booking is added to their calendar. For this, Trainbay requests only two permissions: calendar.freebusy (to know which time ranges are busy, without reading event titles, descriptions, or attendees) and calendar.events (to create the event for a booking made on Trainbay).

The data received from Google is used only to provide that feature to the trainer who connected their calendar. It is not used for advertising, not sold, not used to train AI models, and not shared with anyone except as needed to provide the feature or as required by law. Trainbay's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

The trainer can disconnect their calendar at any time from Bookings → Public page in Trainbay, or revoke access from their Google Account (Security → Third-party apps). The stored access credentials are then deleted.

5. Retention

Data is retained for as long as the relationship with the trainer or client lasts, and afterward for as long as needed to meet legal obligations. Progress photos and the meal log are deleted when the client's account is closed, or at their request.

6. Your Rights

Anyone can exercise their rights of access, rectification, erasure, objection, restriction, and portability by writing to contact@trainbay.app. For a client's data, the request should first be directed to their trainer (who is the controller of that data, see section 1); Trainbay cooperates with them to handle it. Clients can also request deletion of their account from within the app ("My account" section). If you believe your rights have not been addressed, you can lodge a complaint with the data protection authority in your EU country of residence.

7. Security

Access to data is restricted at the database level (each trainer only sees their own data; each client only sees their own data). Photos are stored in private storage with temporary, signed links. Passwords are stored encrypted.

8. Cookies and Local Storage

Trainbay does not use tracking or advertising cookies. It only stores, in the browser, the session token needed to keep you signed in.

Privacy Policy · Terms of Use · Data Processing Addendum