Privacy Policy
Last updated: October 18, 2026
1. Who we are
CoNudge is a service of P2P Concepts, trading as CoNudge, KVK 56042442, Oranjestraat 26, 2013VG Haarlem, the Netherlands. P2P Concepts is the data controller under the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679).
Contact: privacy@conudge.com.
2. Scope and roles
CoNudge has two kinds of customers. Personal trainers (PTs) use CoNudge as a business tool; their clients use CoNudge via an invitation from their PT. Athletes can also take CoNudge directly as consumers (D2C), with their own account and subscription.
CoNudge as data controller: for the client's own account — sign-up, consent, data export and deletion — CoNudge remains responsible. This continues if the client switches PT or the PT stops: coaching then continues through the AI coach.
CoNudge as processor: for the content of the coaching — instructions to the AI coach and reviewing training programs before the client sees them — CoNudge carries out what the PT instructs. There, CoNudge is a processor within the meaning of Art. 28 GDPR, and the PT is an independent data controller for their own client relationship.
3. What data we collect
3.1 Account data
- Email address (for authentication and communication)
- Name (optional, for display in the app)
- Date of birth, height (optional, for program personalization)
3.2 Training data
- Training programs (blocks, workouts, exercises, sets, reps, weights, RPE)
- Logged workouts and sets
- Coach memory (structured JSON profile of your training status)
- PT notes on exercises or programs
3.3 Health data (special category, Art. 9 GDPR)
- Body measurements: weight, waist, chest, hips, arms, legs, body fat percentage
- Injury information (free text during intake)
- Training load (RPE, volume, adherence)
3.4 Chat history
- All messages between you and the AI coach
- Messages from your PT via the platform
4. Purposes and legal basis
| Purpose | Legal basis |
|---|---|
| Account creation and management | Performance of contract (Art. 6(1)(b) GDPR) |
| Generating and adjusting training programs | Performance of contract (Art. 6(1)(b) GDPR) |
| Tracking progress and evaluations | Performance of contract (Art. 6(1)(b) GDPR) |
| Processing health data (measurements, injuries) | Explicit consent (Art. 9(2)(a) GDPR) |
| Service notifications (account changes, policy changes) | Legitimate interest (Art. 6(1)(f) GDPR) |
Health data: we process this exclusively based on your explicit consent (Article 9(2)(a) GDPR). You provide this consent separately when you first use the app. You can withdraw this consent at any time through your account settings — as easily as you gave it. Upon withdrawal, your body measurements are immediately deleted and health data in your coach memory is anonymized.
5. Processors and international data transfers
We share your data with the following processors. Appropriate safeguards for transfers outside the EEA have been implemented with each processor, in accordance with Chapter V GDPR.
| Processor | Purpose | Location | Safeguard |
|---|---|---|---|
| Supabase Inc. | Database, authentication | EU (Ireland) | Data stays in the EU; SCCs only for remote support |
| Vercel Inc. | Hosting, edge computing | Execution in the EU (Ireland); ingress via a global network | Every request, including those carrying health data, enters through Vercel's global edge network (TLS, routing, security, cache). The routing layer, which checks your session and applies security rules, runs in the Vercel region closest to you; outside the EU that can be a region outside the EU. The application itself and the processing of your data then run in Dublin, next to the database. EU SCCs cover that global ingress and routing and the logs |
| Anthropic PBC | AI processing (training program generation) | US | EU SCCs |
| OpenAI (only if you connect ChatGPT) | Independent recipient through the connection in 6b, not a processor for CoNudge; legal basis Art. 6(1)(b), health data only with your explicit consent (Art. 9(2)(a)) | US | OpenAI's own terms; you choose the connection |
| Resend Inc. | Transactional email | US | EU SCCs |
| Sentry (Functional Software Inc.) | Error monitoring | EU | EU processing |
| Upstash Inc. | Rate limiting and spend gates | US | EU SCCs |
| Stripe Payments Europe, Ltd. | Payments and invoicing (once checkout opens): email address, name, payment status. Card and bank details only reach Stripe, never our servers. | Ireland (EU) | EU processing; Stripe Inc. (US) as sub-processor under SCCs |
Standard Contractual Clauses (SCCs) are model contract terms approved by the European Commission (Implementing Decision (EU) 2021/914) that provide an appropriate level of protection for personal data transferred outside the EEA.
We do not sell personal data. We do not display advertisements. We do not share data with anyone beyond the processors and recipients listed above (see 6b for the connection with your own assistant).
6. AI processing and Anthropic
Your chat messages, training data, and coach memory are processed via Anthropic's Claude API to generate training programs, perform evaluations, and adjust your program.
What is shared with Anthropic: your chat messages, training profile (sport, goal, level, injuries), coach memory (structured training history), and your PT's instructions. Anthropic processes this data via their API and does not retain it for model training. See Anthropic's privacy policy for details about their processing.
Anthropic retains API input for a maximum of 30 days for abuse detection and does not use it to train models. After deletion of your CoNudge account, previously processed data at Anthropic is deleted within this period; we do not have a separate "zero-retention" agreement.
6b. Connecting your own assistant
You can connect CoNudge to your own AI assistant (Claude by Anthropic or ChatGPT by OpenAI) to look up your own training data there. This only happens on your own initiative, after explicit consent on our consent page (/oauth/consent). The provider of the assistant you choose then receives your data as an independent recipient on your own initiative, not as a processor for CoNudge. What that provider does with your data is set out in its own privacy policy: OpenAI and Anthropic.
Only the data you ask for there flows to your assistant: your active program, your workout history, your progress and your limitations. A proposal your assistant makes (a new block, a profile change) only counts after you approve it in the app. Only the providers named here can connect.
You can withdraw the connection at any time under Settings, block "Connected assistants". From that moment the assistant receives nothing more. Also remove the connection inside the assistant itself, so no old data lingers there. If that fails, email support@conudge.com.
6c. If you have a trainer: they can view your data through their own assistant — only with your separate consent
Separately from your own connection above, your trainer can connect their own AI assistant (for example Claude or ChatGPT) to look up your data. This only works if you give separate consent for it in your account settings ("my trainer may view my data through an AI assistant", off by default) — the consent you gave earlier for health data does not automatically cover this. Once that consent is given, your trainer's assistant can: look up your name in order to select you; read your full active training block (exercises, sets, reps, weights, RPE); and, only when your trainer explicitly asks, look up your limitation categories (for example "lower back" or "shoulder") and your most recent body measurements — never your date of birth, never the free text of your injury, never your trainer's coaching notes. Based on that, the assistant can draft a proposal for a new or revised training block; that only becomes a real block once your trainer reviews and approves it themselves — the assistant never writes directly into your schedule. The provider of your trainer's assistant is then an independent recipient on your trainer's initiative, not a processor for CoNudge. This connection exists technically in CoNudge, but is switched off until CoNudge publishes it to an assistant directory.
7. AI transparency (EU AI Act)
Pursuant to Article 52 of Regulation (EU) 2024/1689 (AI Act), we inform you as follows:
- You are communicating with an AI system (the "Coach"), not a human, unless your PT sends you a direct message.
- The AI generates training programs based on your profile, goals, and training history.
- In B2B mode, your PT reviews and approves each program before you see it. The PT remains responsible for the training content.
- AI output is not medical advice. CoNudge is not a medical device within the meaning of Regulation (EU) 2017/745 (MDR).
- Your PT is not a BIG-registered healthcare provider (unless they are also a physiotherapist). Advice from CoNudge and your PT does not replace medical advice.
8. Automated decision-making
The AI coach generates training programs. This does not constitute automated decision-making under Article 22 GDPR, because:
- The programs have no legal effects and do not significantly affect you.
- You always decide whether to accept or reject a program.
- In B2B mode, your PT reviews the program before it is presented to you.
9. Cookies
CoNudge uses only functional cookies for authentication via Supabase. These cookies are strictly necessary for the service to function and do not require consent under the ePrivacy Directive (2002/58/EC).
We do not place tracking cookies, analytics cookies, or third-party cookies. No cookie banner is displayed because there are no non-essential cookies.
10. Data retention
| Category | Retention period |
|---|---|
| Account data (email, name) | As long as the account is active |
| Training programs and logged sets | As long as the account is active |
| Chat history | As long as the account is active |
| Coach memory | As long as the account is active |
| Body measurements (health data) | As long as health data consent is active; immediately deleted upon withdrawal |
| After account deletion | Erased immediately from our systems; backups within our hosting subscription's retention period |
For Anthropic, the retention period from section 6 applies.
11. Your rights under the GDPR
You have the following rights regarding your personal data:
- Right to information (Art. 13-14): you have the right to be informed about the processing of your data. This privacy policy fulfills that right.
- Right of access (Art. 15): you may request what data we hold about you.
- Right to rectification (Art. 16): you may have inaccurate data corrected.
- Right to erasure (Art. 17): you may request deletion of all your data. This can be done via your account settings or by email.
- Right to restriction (Art. 18): you may request limitation of processing.
- Right to data portability (Art. 20): you may request your data in a structured, commonly used, and machine-readable format.
- Right to object (Art. 21): you may object to processing based on legitimate interest.
- Right regarding automated decision-making (Art. 22): see section 8 — no automated decision-making within the meaning of Art. 22 GDPR takes place.
- Withdraw consent: you can withdraw your consent for health data processing at any time through your account settings. Withdrawal is as easy as giving consent and does not affect the lawfulness of prior processing.
Email privacy@conudge.com to exercise any of these rights. We will respond within 30 days.
12. Complaints
You have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) (Bezuidenhoutseweg 30, 2594 AV The Hague, the Netherlands).
If you reside outside the Netherlands within the EU/EEA, you may also file a complaint with the supervisory authority in your own member state.
13. Security
We take appropriate technical and organizational measures to protect your data, including:
- Encrypted connections (HTTPS/TLS) for all data transfers
- Row Level Security (RLS) in the database — you can only see your own data
- Content Security Policy (CSP) headers to prevent cross-site scripting
- Cookie-based authentication without tracking
- Rate limiting on all API endpoints
- Input validation on both frontend and backend
14. Geographic scope
CoNudge primarily targets the Benelux region. The service is available in Dutch and English. This privacy policy is drafted in accordance with the GDPR.
15. United Kingdom
CoNudge does not actively target users in the United Kingdom. If you use CoNudge from the UK, the UK GDPR (Data Protection Act 2018) may apply in addition to this policy. For complaints, you may contact the Information Commissioner's Office (ICO). CoNudge has not appointed a representative in the UK.
15b. Minors
CoNudge is intended for people aged 18 and over. We ask for your date of birth before you consent to the processing of health data, and we do not create an account holding health data for anyone younger. The reason is both legal and substantive: a child's consent to the processing of health data is not valid without a parent or guardian, and a training plan for a growing body should come from a professional. Under 18? Talk it over with a parent or guardian and ask a sports doctor, physiotherapist or coach near you for guidance. Think we hold a minor's data anyway? Email us and we will delete it.
16. No medical advice
The AI coach generates training programs based on information you provide. AI output is not medical advice and does not replace the judgment of a physician, physiotherapist, or other registered healthcare provider. In case of pain, injuries, or medical complaints, we always refer you to a professional. CoNudge is not a medical device within the meaning of Regulation (EU) 2017/745.
17. Changes
For material changes to this policy, we will notify you at least 14 days in advance by email. If the change concerns the processing of health data, we will request your explicit consent again. Non-material changes (such as typos or clarifications) may be made without notice.
18. Terms of Service
Please also read our Terms of Service.