Privacy Policy

1. Introduction

TurboGrowth AG ("we", "our", or "us") is committed to protecting and respecting your privacy. This privacy policy explains how we collect, use, and safeguard your personal information when you use our athlete data analytics platform and services. We are the data controller for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Data We Collect

The data we collect includes personal information that you provide directly to us and information that is automatically collected when you use our services. We collect the following types of personal data:

• Contact Information: Name, email address, phone number, postal address
• Account Information: Username, password, profile preferences
• Athletic Data: Performance metrics, training data, biometric information
• Technical Data: IP address, browser type, device information, usage statistics
• Communication Data: Messages, support inquiries, feedback
• Payment Information: Billing details, transaction history (processed securely by third-party providers)

3. How We Use Your Information

We use your personal data for various purposes based on legal grounds including contract performance, legitimate interests, and your consent. How we use your information includes:

• Providing and maintaining our analytics platform and services
• Processing your athletic data to generate performance insights
• Communicating with you about your account and our services
• Improving our platform through data analysis and user feedback
• Ensuring platform security and preventing fraud
• Complying with legal obligations and regulatory requirements
• Marketing our services (with your consent where required)

4. Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please refer to our Cookie Policy.

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following circumstances:

• Service Providers: Trusted third parties who assist in operating our platform
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with mergers, acquisitions, or asset sales
• Consent: When you have given explicit consent for specific sharing

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include encryption, secure servers, access controls, and regular security assessments. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements. Athletic performance data may be retained longer to provide historical analysis and trend insights. When data is no longer needed, we securely delete or anonymise it in accordance with our data retention policies.

8. Your Rights

Under GDPR and other applicable laws, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data in certain circumstances
• Right to Restrict Processing: Request limitation of data processing
• Right to Data Portability: Request transfer of your data
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing

9. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, including adequacy decisions, standard contractual clauses, or other approved transfer mechanisms to protect your data in accordance with GDPR requirements.

10. Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately so we can take appropriate action.

11. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our website and updating the "last updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

12. Contact Information

If you have any questions about this privacy policy, wish to exercise your rights, or need to contact us regarding data protection matters, please reach out to us:

13. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal data unlawfully. In Germany, you can contact the relevant data protection authority in your state or the Federal Commissioner for Data Protection and Freedom of Information (BfDI).