AG+

AG+ Privacy Policy

Version 2026-10-20-draft · draft, not yet in force

Draft for legal review, not yet in force. Written from what the AG+ app and the Mental Performance Coach actually process today. Before publishing, a lawyer must confirm the lawful bases and consent wording, the retention periods and the transfer safeguards, and a DPIA must be completed (UK GDPR / EU GDPR Art. 35). Text in [square brackets] is a placeholder AG+ must fill in.

Who we are

Anders Örbom ("AnotherGear", "AG+", "we") is the controller of the personal data described here. Address: [address, country]. A company is being formed to run AG+; once it exists, this section will name it with its registered office and company number.

What this policy covers

This policy covers the AnotherGear (AG+) mobile app, the AG+ Mental Performance Coach inside it (text, voice and coaching stories) and [anothergear.app]. It does not cover third-party services you choose to connect, such as Apple Health, which have their own policies.

Our internal admin console is used only by AG+ staff and is covered by our staff privacy notice.

Information we collect

We collect what you give us, what the app records while you use it, and what you choose to connect. We do not buy data about you.

Category Examples Where it comes from
Account Email, name, sign-in identifier You, when you register (via our sign-in provider)
Profile and goals Sport, experience, your "Why", goals, time zone, country You, in onboarding and your profile
Training plan and events Planned sessions, key sessions, your selected race, completed sessions You, and the plan you build in the app
Workouts (optional) Completed workouts read from Apple Health; we never write to Apple Health Apple Health, only if you allow it
Location (optional) Your approximate location, used once to suggest nearby races Your device, only if you allow it; you can pick a country instead
Mental performance assessments Your answers and scores (for example the ACSI-28 questionnaire) You
Check-ins, practices and reflections Mood and energy ratings, completed practices, whether a practice helped You
Coach conversations What you type or dictate to the coach, the coach's replies, the sources it used You and the AI coach
Coach memory Short notes the coach keeps about you (for example an upcoming race, a worry, a cue that helps), each marked confirmed, unconfirmed or temporary Drawn from your conversations, check-ins and plan; you can see and correct them
Voice Short recordings for voice-to-text, and live voice audio Your microphone, only when you use voice
Coaching stories Personal stories the coach writes for you, and their audio narration Generated from your confirmed information
Race reports and files Files you upload, such as a race report You
Subscriptions and usage Your plan (Free, Plus), purchase status from the App Store or Google Play, how much coach time you have used App stores; our servers
Device and notifications Device type, app version, push notification token, notification settings Your device
Emails we send you Delivery of service emails (for example "your data export is ready") Our email provider
Sharing and referrals Share links you create, referral codes You
Technical and security logs Request identifiers, timestamps, errors, IP address Our servers; these logs never contain the text of your messages

Sensitive information about your wellbeing

What you tell the coach about nerves, stress, confidence or how you feel may be health data, a special category of personal data (Article 9 GDPR). We process it only with your explicit consent, which we ask for before your first coach conversation.

[Legal review: confirm explicit consent as the Art. 9(2)(a) condition and the consent wording shown in the app.]

How we use information and why we're allowed to

We use your information only for the purposes below. We never use coach conversations for advertising, never sell personal data, and never share conversations with clubs, coaches or sponsors.

Purpose Information used Lawful basis [to confirm]
Provide your account, plan, practices and progress Account, profile, plan, check-ins, assessments Contract
Mental performance coaching (text, voice, stories) Coach conversations, coach memory, profile, plan, voice Contract; explicit consent for wellbeing data
Remember what matters to you between conversations Coach memory Explicit consent
Adapt your mental-training plan when you confirm a lasting change Confirmed coach memory, plan Explicit consent; changes are only made after you confirm them
Proactive coach messages (for example before a key session) Plan, events, check-ins, notification settings Legitimate interests; you can turn them off
Service emails (account, data export, deletion, policy changes) Email address, the event the email is about Contract; legal obligation
Subscriptions and coach-time allowances Purchase status, usage records Contract; legal obligation for financial records
Safety support when you may be at risk The message that triggered it Explicit consent / vital interests [to confirm]
Security, fraud and abuse prevention, service quality Technical logs, usage records Legitimate interests
Answer support requests and exercise your rights Account, the data your request concerns Legal obligation; contract
Improve the service using aggregated statistics (no message content) Usage and cost totals Legitimate interests

How the AI coach works

The coach's replies and stories are written by an AI model, not by a person. To answer you, it uses only a limited, labelled set of information: your profile, your upcoming plan and selected race, recent check-ins, the most relevant notes from your coach memory, and excerpts from AG+'s approved knowledge library.

Voice

Voice is optional and uses your microphone only while you are dictating or in a live voice session.

Who we share information with

We share personal data only with service providers that process it on our instructions under a data processing agreement, and only what each needs. We do not sell personal data.

Provider What they do for us Data involved Location
Amazon Web Services Hosting, databases, file storage, encryption keys, document text recognition All app and coach data UK (London region) [confirm backup region: EU]
OpenAI AI coach replies, memory notes and coaching stories; search indexing of coach memory and the knowledge library; [voice-to-text and live transcription, if chosen as provider] Your messages and the coach's replies, short memory notes, and voice audio as needed for each request United States [confirm EU data residency / zero data retention]
ElevenLabs Synthetic coach voice for live voice, previews and story narration Coach reply and story text (not your recordings) [confirm]
Loops Sending service emails Your email address, first name and the details of that email (never your conversations or coach memory) United States [confirm]
Supabase Sign-in and app progress backups Account, app progress [confirm region]
Apple App Store, Google Play Payments and subscription status Purchase records Per the store's policy
[Push provider: Apple Push Notification service / Firebase Cloud Messaging] Delivering notifications Push token, notification text (never your conversation) United States

We may also disclose information if required by law, to protect someone's life or safety, or as part of a sale or reorganisation of our business (with notice to you).

International transfers

Our main systems run in the UK (AWS London). Some providers process data in the United States. Where data leaves the UK or EEA, we rely on an adequacy decision (for example the UK-US Data Bridge or the EU-US Data Privacy Framework, where the provider is certified) or on Standard Contractual Clauses / the UK International Data Transfer Addendum, plus a transfer risk assessment. You can ask us for a copy of the safeguards. [Legal review: list the mechanism per provider.]

How long we keep information

We keep information only as long as needed for the purpose it was collected for. These are our defaults [to be confirmed in the DPIA]:

Information How long
Voice-to-text recordings Deleted immediately after transcription
Live voice audio Not recorded
Coach conversations 12 months after your last activity
Temporary coach notes (e.g. "legs heavy this week") Expire after about 7 days; deleted 30 days after expiry
Other coach memory and coaching stories Until you delete them or your account
Account, profile, plan and progress Until you delete your account
Data export files you request 24 hours
Records of which policy versions you accepted, and consent given or withdrawn For as long as we may need to show we had your consent, then deleted [confirm]
Purchase and billing records [As required by tax law, e.g. 7 years], with no conversation content
Security logs [90 days]
Backups Overwritten within 35 days

When you delete your account, we erase your data within 30 days. Usage and audit records are kept only in anonymised form.

How we protect information

No system is perfectly secure. If a breach affects you, we will tell you and the regulator as the law requires.

Your rights

You can use these rights in the app or by emailing [privacy@anothergear.app]. We reply within one month.

Right How
See your data and get a copy (access, portability) [Settings › Privacy › Export my data]: a download of your data in a machine-readable format
Correct it Edit your profile; correct or mark wrong any coach note in [What the coach knows]
Delete it Delete single coach notes, or delete your account in [Settings › Privacy] (erased within 30 days)
Withdraw consent Turn off the coach or voice, or withdraw wellbeing-data consent, in [Settings › Privacy]
Object or restrict Turn off proactive messages; email us to object to other processing
See staff access [Settings › Data access log]
Complain Contact us first if you can. You may also complain to your data protection authority: in the UK the Information Commissioner's Office (ico.org.uk), in Sweden Integritetsskyddsmyndigheten (imy.se), or the authority where you live

Proactive messages and notifications

If you allow notifications, the coach may send short messages, for example a few hours before a key session, in the days before your race, after a session, or when a coaching story is ready. They respect quiet hours in your time zone and a weekly limit, and pause if a recent conversation needed safety support. You can turn them off, or set your own quiet hours, in [Settings › Notifications]. Notification text never includes what you said to the coach.

Children

AG+ is for people aged [18] and over. We don't knowingly collect data from younger users; if you think a child has an account, tell us and we will delete it. [Open decision: if under-18s will be allowed, add age checks, guardian consent and stricter messaging rules first.]

Changes and contact

We will update this policy when what we do changes, and tell you in the app before material changes take effect. The version and date above show the latest version.

Questions or requests: [privacy@anothergear.app] · Anders Örbom, [address].