AxlCoach Privacy Policy
PRIVACY POLICY
Last updated: 06.02.2026
This Privacy Policy explains how AxlBrains OÜ (“Company”, “we”, “us”, or “our”) collects, uses, and protects personal data when you access or use the AxlCoach platform, including the Coach App, Athlete App, 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
Mooni tn 18-60, Tallinn, 10613 Estonia
info@axlbrains.com
We act as a data controller for personal data processed to operate and improve the Services.
Coaches are independent providers and may act as separate controllers for their own coaching-related decisions and materials.
2. PERSONAL DATA WE COLLECT
We collect only the data necessary to operate the Services.
a) Account Information
- Coach profile information (e.g. name, email)
- Athlete profile information (e.g. name, email)
b) Communication Data
- Chat messages between Athletes and AI Twins
- Voice messages and their transcriptions
Voice messages are transcribed and stored as part of the conversation history until deleted by the user.
c) Usage and Technical Data
- App usage analytics (e.g. feature usage, performance metrics)
- Device and log data (e.g. IP address, timestamps)
We do not collect advertising data.
3. HEALTH AND SENSITIVE DATA
The Services are not designed to collect health or medical data.
However, Athletes may voluntarily include health-related or fitness-related information in their messages. If they do so:
- that information is processed solely to provide the requested AI Twin responses;
- it is not required to use the Services; and
- it is handled in accordance with this Privacy Policy.
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;
- enable communication with AI Twins;
- maintain safety, integrity, and performance;
- analyze usage and improve functionality using aggregated insights;
- send essential service communications (e.g. account or security messages).
We do not use personal data for advertising or marketing.
5. AI PROCESSING AND THIRD-PARTY PROVIDERS
a) AI Processing
Messages and inputs may be processed by AI systems to generate responses from AI Twins.
b) Third-Party AI Providers
We use third-party AI providers, including OpenAI and Google, in addition to our own models. This may involve transmitting message content to those providers for inference.
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
We use Firebase analytics to understand how the Services are used and to improve performance and reliability.
Analytics data is used in a pseudonymized and aggregated manner.
We do not currently use cookies or SDKs for advertising or tracking across apps or websites.
7. DATA STORAGE AND LOCATION
All personal data is hosted and processed within the European Union using cloud service providers.
We do not intentionally transfer personal data outside the EU.
8. DATA RETENTION AND DELETION
You may delete your account and associated data at any time through the Services.
Upon deletion:
- personal data is removed from active systems; and
- residual data may remain temporarily in backups or logs until overwritten in the normal course of operations.
We may retain aggregated and anonymized data that cannot reasonably be linked back to an individual, including for system improvement and safety purposes.
We do not commit to fixed retention periods.
9. DATA SHARING
We do not sell personal data.
We may share data:
- with service providers acting on our behalf (e.g. cloud hosting, analytics, AI providers);
- where required by law or valid legal process;
- to protect the rights, safety, or integrity of the Services.
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.
Requests can be made by contacting us at support@axl.coach.
11. SECURITY
We implement reasonable technical and organizational measures to protect personal data.
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.
We do not knowingly collect personal data from individuals under 16.
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