axl Privacy Policy

PRIVACY POLICY

Last updated: 11.10.2026

This Privacy Policy explains how AxlBrains OÜ (“Company”, “we”, “us”, or “our”) collects, uses, and protects personal data when you access or use the Axl platform, including the Axl app for athletes (iPhone, Apple Watch and Android), Axl Studio for coaches, and related websites and services (collectively, the “Services”).

This Privacy Policy applies to all users of the Services worldwide and should be read together with our Terms of Use.

1. WHO WE ARE

Controller:

AxlBrains OÜ
Akadeemia tee 15A, 12618 Tallinn, Estonia
info@axlbrains.com

We act as a data controller for personal data processed to operate and improve the Services.

In the app, athletes are coached by Axl, an AI coach. Axl follows a training method written by a coach in Axl Studio or by our own team. Coaches are independent providers and may act as separate controllers for their own coaching-related decisions and materials. What a coach can see about you is described in section 9.

2. PERSONAL DATA WE COLLECT

We collect only the data necessary to operate the Services.

a) Account Information

Athletes: email address; name; date of birth; sex; height; units of measurement; time zone; app language; a profile photo if you add one; the consents you gave and when. If you sign in with Apple or Google, we receive the account identifier, email address and name they give us. For Sign in with Apple we also keep an encrypted token, so that we can revoke the sign-in when you delete your account.
Coaches: name, email address, username, gender, country and language; the profile you publish (photo, bio and links to your website and social accounts); your interview recordings and, if you provide one, a reference video of your face; the videos, documents and audio you upload to your library, which we index with our AI provider; voice samples, if you create a synthetic voice; if you sign in with Google, your Google email address and name, and only the Google Drive files you pick to import (we keep no access to your Drive); your Stripe account identifiers, if you sell subscriptions. A sign-in email shows the country of the request, which we look up from its IP address on our own servers, and the type of device.

b) Communication Data

Your conversations with Axl: text messages, voice messages and their transcriptions, photos and documents you send, Axl's replies (written, and as audio when Axl speaks them), and an English translation of each message (Axl works in English and translates to and from your language).
Your reactions to replies (thumbs up or down) and any comment you add.
Reminders and messages you ask Axl to schedule.

Voice messages are transcribed and stored as part of the conversation history until deleted by the user. Voice messages recorded on the Apple Watch reach us through your iPhone in the same way.

Photos can carry hidden metadata, such as where they were taken. We remove it from the photos you send and the profile photos you add.

c) Training Profile and What Axl Remembers

What you tell Axl to set up your coaching: your sports and level, goals and race dates, how many days and how much time you have, your equipment, and things you cannot or should not do (without the reason).
Facts Axl records from your conversations so that it still knows them later, in your words and with your numbers, for example a test result, a day you never train, or a past injury.
Your training record: the sessions Axl prescribed, what you did and what you said about it, and how Axl adjusted your plan.
What you ask Axl to log: body weight, mood notes, and meal photos with the nutrition estimate Axl makes from them.
The city you train in, as you tell Axl or as Axl infers from your time zone. Axl uses it to check the weather. We send only the city name to our weather provider (Open-Meteo), with nothing that identifies you.
Your choice of Axl's face, voice, way of speaking and language; how Axl may contact you (push notification or email) and your quiet hours.

d) Health and Fitness Data

Data read from Apple Health, Health Connect, or a wearable service you connect (only if you connect a source, see section 3)
Health information you tell Axl in a conversation, and the safety holds it leads to (see section 3(f))

e) Calendar (only if you turn it on)

If you turn on “Use my calendar” and allow calendar access on your phone, the app reads your phone's calendars and sends us only when you are busy over the next 7 days: the start and end of each busy period and whether it lasts all day. What an event is, who is in it, where it is and any notes never leave your phone. We keep only the latest sync and replace it every time the app syncs. We delete it when you turn the setting off, when you reset or delete your account, and the next time the app opens after you take calendar access away in your phone's settings. Axl uses it only to propose training at times you are free.

f) Payment Information

If you subscribe, you pay on a Stripe page. We never receive your card number. We keep your subscription status, plan, price, billing period, and Stripe's identifiers for you and your subscription.

g) Usage and Technical Data

Device and log data: IP address, device and app type, the time and address of each request to our servers; your device's push notification token and whether it is an iPhone or an Android phone; when you were last active.
Crash reports from the app (see section 6).

We do not collect advertising data, and the app does not collect usage analytics.

3. HEALTH AND FITNESS DATA

Health data is optional. If you connect a health source, we read health and fitness data from it. This is special category data, and we process it only on the basis of your explicit consent. We ask for that consent separately from the Terms of Use (“Axl may read my health data”), and the app does not let you link a source before you give it. You can withdraw your consent at any time by turning it off in Account → Consents or by disconnecting the source. We then stop reading the source, and Axl stops using the health data read from it.

a) Sources

Apple Health on iPhone;
Health Connect on Android;
wearable services you choose to connect: currently Oura, Polar, Strava and Hevy. For Hevy you paste a personal API key, which is used only to read your workouts.

Data from all of these sources reaches us through Open Wearables, open-source software that we run ourselves on Google Cloud in the European Union. From there it is delivered to our servers directly and through Svix, a data delivery service (see section 7).

b) What we read

Health Connect on Android (read access only; we do not write to Health Connect):

workouts (exercise sessions), distance, speed, power, cycling pedaling cadence, steps, active calories and total calories burned;
heart rate, resting heart rate, heart rate variability;
sleep;
VO2 max, weight, height.

Apple Health on iPhone: the same types, except that we read resting energy instead of total calories burned, which Apple Health does not record. You choose them on Apple's permission screen and can change your choice at any time in the Health app. That screen also asks for permission to write body weight. We ask for it only because the software we use to connect to Apple Health needs it to show that screen, and Axl never writes to Apple Health.

Wearable services: the same types, as far as the service records them. Where a service measures them, we also read respiratory rate, oxygen saturation, daily readiness, stress, body temperature, blood glucose and body composition (body fat, muscle mass, BMI).

Height and weight you can also tell us in a conversation.

c) What we use it for

We use this data to coach your training: to see what your sessions did (distance, pace and speed, power, cadence and energy spent) and adjust the next one, to judge how recovered you are before prescribing a session, to set training zones, and to scale training load and energy estimates. When you connect Apple Health or Health Connect, we read the last 30 days and then new data as it arrives. When you connect a wearable service, we read the history it provides for up to the last 400 days and then new data as it arrives. On iPhone and from wearable services, a workout is synced after you record it, without you opening the app, so Axl's answer is ready when you next look. With Health Connect on Android, new data may wait until you next open the app.

d) Sharing

We never sell health data and we never use it for advertising or marketing. Health data is processed by our AI provider (Google, in the European Union, see section 5) only to generate Axl's responses and the short profile summary your coach reads, and extracts of it can reach the AI tool our team uses to check Axl's coaching (section 5). Svix carries data from your sources to our servers (section 3(a)). Because Axl's replies can mention your health data, the services that deliver those replies carry it too: the voice provider that reads a reply aloud (section 5), and Firebase Cloud Messaging and Apple's push service when the start of a reply appears in a notification (section 7). The coach whose method you follow can read your conversations and your profile summary, which includes your latest weight, and sees your maximum heart rate with each reaction you leave (section 9). Our use and transfer of information received from Health Connect will adhere to Google Play's User Data Policy, including the Limited Use requirements. We do not store data from Apple Health in iCloud.

e) How long we keep it and how to delete it

Health data is kept for as long as your account exists. You can stop new data from being read at any time by disconnecting the source in the app, by turning off the health data consent in Account → Consents, or by removing Axl's access in Apple Health or Health Connect settings. When you delete your account, your health data is deleted with it and we revoke our connection to the source, as described in section 8.

f) Health information you share in conversations

The Services are not medical services: they do not diagnose or treat any condition. You may tell Axl about your health in a conversation, for example an injury, an illness, a symptom, a pregnancy, how you eat, or a lab or performance test report you share. This is special category data. We process it on the basis of your explicit consent, which we ask for separately from the Terms of Use. Axl uses it to keep your training safe and appropriate. It is processed by our AI provider to generate Axl's responses (section 5) and stored with your conversation and, where it matters for later sessions, among the facts and restrictions Axl remembers.

Safety holds. Every message you send is checked, by fixed rules and by our AI provider, for signs of three things: symptoms that need a doctor before training continues (for example chest pain, fainting or a head injury), a pregnancy or recent birth, and signs of disordered eating. When it finds one, Axl places a safety hold. For symptoms or pregnancy, training stops. For disordered eating, only the work around weight and diet stops. The hold stays until you tell Axl that a clinician has cleared you. Axl does not verify a clearance; it records what you told it. A hold can also be placed from your data or by our team. We store the kind of hold, when it was placed, the words of your message that placed it (up to 500 characters), and, when it is lifted, your words saying you were cleared. Safety holds are kept until you reset or delete your account.

Messages our safety check declines to answer (for example about self-harm, a medical emergency or substances) are stored as written, so that our team can check how the safety check performs. They are kept until you delete your account.

A safety hold diagnoses nothing and has no legal effect on you; it changes only what Axl prescribes.

Apart from the health data described in this section, we do not request or require the submission of special category data.

4. HOW WE USE PERSONAL DATA

We use personal data to:

provide and operate the Services: your account, your conversations with Axl, your plan and training record, reminders and notifications (to perform our contract with you, Art. 6(1)(b) GDPR);
process health data from your sources and your conversations, and place safety holds (your explicit consent, Art. 9(2)(a) GDPR);
use your phone's calendar (your consent, Art. 6(1)(a) GDPR), which you can turn off at any time;
maintain safety, integrity, and performance: security, preventing abuse, fixing errors, server logs and crash reports (our legitimate interests, Art. 6(1)(f) GDPR);
improve Axl and its methods: our team and the coach whose method you follow review conversations and the reactions you leave, and we test changes on a copy of our data kept in the same EU location, with email addresses, phone numbers, sign-in and payment details removed (our legitimate interests);
send essential service communications (e.g. sign-in codes, account, security or payment messages) (contract);
take payments and keep the records accounting law requires (contract; legal obligation, Art. 6(1)(c) GDPR).

We do not use personal data for advertising or marketing. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects; safety holds are explained in section 3(f).

5. AI PROCESSING AND THIRD-PARTY PROVIDERS

a) AI Processing

Messages and inputs are processed by AI systems to generate Axl's responses. This includes writing replies; transcribing voice messages; translating between your language and English; reading photos and documents you send; checking messages and replies for safety; titling and summarising conversations and indexing the summaries so that Axl can recall them; writing the profile summary your coach reads; and recording facts, restrictions and safety holds.

b) Third-Party AI Providers

Google Gemini, through Google Cloud Vertex AI, in Google Cloud's EU regions (Frankfurt, Germany, and Belgium). Google processes this content as our processor under the Google Cloud data processing terms and does not use it to train its models.
Voice messages are turned into text on your iPhone, by its speech recognition, where your iPhone can recognise your language on the device; the recording does not leave the phone for this. Otherwise, on Android, and when the text is missing or in the wrong language, Google Gemini transcribes the recording on our servers.
fish.audio, a text-to-speech provider, turns Axl's replies into speech when Axl answers a voice message or you ask for a reply to be read aloud. It receives only the text to be spoken and returns audio. For coaches who create a synthetic voice in Axl Studio, fish.audio also receives the voice samples they upload; that voice is deleted from fish.audio 30 days after the coach's account is deleted.
Anthropic's Claude, which our team uses as a tool to check the quality of Axl's coaching and to investigate problems. It can receive extracts of an athlete's data, such as a training session Axl prescribed. Anthropic processes this as our processor and does not use it to train its models.

We use no other AI providers, and we do not run AI models of our own on your data.

We:

opt out of model training where supported by providers;
do not intentionally authorize third-party AI providers to train their models on personal data processed via the Services.

However, we cannot fully control how third-party providers process data beyond contractual and technical safeguards.

6. ANALYTICS

The app contains no analytics or advertising SDK. It sends crash reports to Firebase Crashlytics (Google). When the app crashes or hits an error, the report contains the device model, operating system and app version, a random installation identifier and technical details of the error. We do not add your name or email address to it, but a report about a voice or video message that failed to load includes the file's web address, which contains your account identifier. Crashlytics keeps crash reports for 90 days.

Our websites (axl.coach and Axl Studio) use Google Analytics to count visits and clicks, such as on the App Store and Google Play buttons. Google Analytics sets cookies, and we use it only if you accept them in the cookie banner. You can change your choice at any time with “Cookie settings” at the bottom of axl.coach. Analytics data is used in a pseudonymized and aggregated manner.

We do not use cookies or SDKs for advertising or tracking across apps or websites.

7. DATA STORAGE AND LOCATION

Our servers, database, file storage and application logs run on Google Cloud in the European Union (Belgium), and the AI processing described in section 5 runs in Google Cloud's EU regions. Platform audit records of administrative actions are kept by Google Cloud under its own terms. Open Wearables, which receives the data from your health sources, runs in the same Google Cloud location. Svix delivers that data to our servers from its EU region; Svix itself is a United States company.

Some service providers process personal data outside the European Economic Area:

Postmark (ActiveCampaign, United States) sends our emails: sign-in codes, account and payment messages, and reports to our support mailbox;
Firebase Cloud Messaging (Google) and the Apple Push Notification service deliver push notifications, which can include the first 200 characters of Axl's reply (you can hide previews in your phone's notification settings);
Firebase Crashlytics (Google, United States) receives crash reports;
Google Analytics (Google, United States) counts visits to our websites, if you agree to it;
fish.audio turns Axl's replies into speech;
Anthropic (United States) provides the AI tool our team uses (section 5);
Stripe (Stripe Payments Europe, Ireland, and Stripe, Inc., United States) processes payments;
Google Workspace hosts our support mailbox.

Where personal data is transferred outside the European Economic Area, we rely on an adequacy decision of the European Commission (including the EU-U.S. Data Privacy Framework, for certified providers) or on the European Commission's Standard Contractual Clauses. You can ask us for a copy of these safeguards at support@axl.coach.

When you connect a wearable service or sign in with Apple or Google, that company handles your data under its own privacy policy.

8. DATA RETENTION AND DELETION

We keep personal data for as long as your account exists, unless this section says otherwise.

Sign-in codes expire after 10 minutes. A sign-in on a device expires after 30 days without use.
Server logs are kept for 24 hours and crash reports for 90 days. Our email provider keeps copies of emails for up to 45 days. Reports in our support mailbox are deleted after 12 months.
Calendar data: only the latest sync, see section 2(e).
When you delete a conversation, it disappears from the app at once and is permanently erased, with its voice messages, photos and Axl's spoken replies, within 30 days. Facts Axl recorded from it remain part of your profile until you reset or delete your account.
Resetting your account (Account → Reset account) starts your coaching over. It deletes your plan, training record, sports and levels, goals, availability and equipment, restrictions, the facts Axl remembers, safety holds, reactions and calendar data, and it deletes your conversations and the documents you sent as described above. These stay: your account and profile details, consents, language, your choices for Axl, your connected sources and the data read from them, the body weight, mood notes and meals you logged, reminders you asked Axl to schedule, your city, your maximum heart rate and the baselines measured from your data, a short summary of your earlier coaching history, goals and plans saved by earlier versions of the app, and messages our safety check declined (section 3(f)).

You may delete your account and associated data at any time in the app (Account → Delete account).

Upon deletion:

at once: you are signed out on every device; your email address, phone number, push tokens and calendar data are deleted; and nobody, including coaches, can see your profile or conversations any longer;
shortly after: we disconnect your wearable services and delete the data Open Wearables holds for you, including your email address there; we revoke Sign in with Apple and remove your Apple and Google sign-in details; and we cancel your subscription at Stripe;
within 30 days: everything else is permanently deleted from our database and file storage, including your name, profile, conversations, voice messages, photos, documents, Axl's spoken replies, health and training data, the facts Axl remembers, safety holds, reactions and messages our safety check declined. If you deleted your account by mistake, contact us within that time;
copies can remain for a limited time in backups, logs and our providers' systems: database backups and deleted files are kept for 7 days after permanent deletion, server logs for 24 hours, crash reports for 90 days, emails at our email provider for up to 45 days, and reports in our support mailbox for 12 months. Other technical records, such as request traces and records of data deliveries, are kept for no more than 90 days. The copy of our data we test on (section 4) is refreshed from live data, and a deleted account leaves it within 30 days.

Payment records are kept for as long as accounting law requires (seven years in Estonia). For the same reason, Stripe keeps your customer record and payment history after your subscription is cancelled.

We may retain aggregated and anonymized data that cannot reasonably be linked back to an individual, including for system improvement and safety purposes.

9. DATA SHARING

We do not sell personal data.

We share data:

with the coach who wrote the method Axl follows for you. The coach can read the conversations their method produced, including the voice messages, photos and documents in them, together with your name, your profile photo and a short profile summary that our AI writes for them from your goal, your latest weight, your last mood note, how often you trained in the past week and your last workout. For each reaction you leave, they see the reaction, your comment, Axl's reply, the message of yours that came before it, and a snapshot of what Axl knew about you at the time: your age, sex, height, units, time zone and languages; your sports and levels, goals, availability and equipment; your maximum heart rate and where it came from; your restrictions and recorded facts; which wearable services you connected; and how many workouts and days of wearable data we had from the previous two weeks. They do not see your email address or date of birth. Coaches may use this access only to improve their method. On request we tell you which coach wrote your method. Methods written by our own team are seen only by our team;
with authorised members of our team, who can read accounts, conversations and reactions to provide support, keep the Services safe and improve them. When you react to a reply, an email with your account and conversation identifiers, your reaction, your comment and the name of the method is sent to our support mailbox. Copies of the payment and account emails we send also go to that mailbox; sign-in emails are not copied;
with service providers acting on our behalf, named in sections 3 to 7 (cloud hosting, AI, text-to-speech, email, push notifications, crash reports, health data delivery, website analytics, payments);
with a wearable service, Apple or Google only as needed to connect it or sign you in, at your request;
where required by law or valid legal process;
to protect the rights, safety, or integrity of the Services.

We send no personal data to the weather service or to YouTube: only a city name, or a short search phrase when you ask Axl for a YouTube video.

All service providers are required to implement appropriate security measures.

10. USER RIGHTS (GDPR)

Depending on your location, you may have the right to:

access your personal data;
correct inaccurate data;
delete your data;
restrict or object to certain processing;
receive a copy of your data in a portable format;
withdraw a consent at any time, without affecting processing before the withdrawal (health data in Account → Consents; calendar in the app or your phone's settings).

Requests can be made by contacting us at support@axl.coach. We answer within one month.

You also have the right to lodge a complaint with a supervisory authority: in Estonia, the Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee), or the authority where you live or work.

11. SECURITY

We implement reasonable technical and organizational measures to protect personal data. Data is encrypted in transit and at rest; the files in conversations and in coaches' libraries, including Axl's spoken replies, are kept in private storage and opened only through links that expire; sign-ins can be revoked; and only team members who need access have it.

No system is completely secure. You use the Services at your own risk.

12. CHILDREN

The Services are not intended for users under 16 years of age. The app asks for your date of birth and does not let anyone under 16 sign up.

We do not knowingly collect personal data from individuals under 16. If we learn that an account belongs to someone under 16, we delete it.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

If changes are material, we will provide notice through the Services or other appropriate means.

14. CONTACT

If you have questions about this Privacy Policy or our data practices, contact us at: support@axl.coach