Privacy policy (draft)

Trilogy Sport Training Platform Privacy Policy

Version 2.0 — Draft for legal review
Effective date: 1 November 2026

1. Data Controller and Service

The data controller is SPORTCLUB LLC (ООО «СПОРТКЛУБ»), a company registered in the Russian Federation.

Russian Tax ID (INN): 9704030872
Tax Registration Reason Code (KPP): 770401001
Registration Number (OGRN): 1207700338779
Website: https://trilogy-sport.ru
Privacy contact: support@trainingplatform.ai
Registered address: Room 201, Floor 1, Building 4, 24 Luzhniki Street, Moscow, 119048, Russian Federation

Trilogy Sport Training Platform (the “Platform”) enables athletes to access and analyze their own training activity data through compatible applications, including ChatGPT.

The Platform is not intended to provide medical diagnosis or treatment.

2. Information We Process

Depending on the services used, we may process:

Account information: email address, user-selected display name or pseudonym, internal account identifier and authentication information.

Subscription information: subscription plan, billing period, payment status, transaction references and information required for accounting and legal compliance.

Training information: activity dates, duration, distance, speed, pace, heart rate, power, cadence, elevation, intervals and other permitted training metrics.

Connection information: technical Garmin Connect and MCP connection identifiers, authorization permissions and access tokens.

Technical information: IP addresses, session details, security events and diagnostic logs.

Users may use pseudonyms. A legal first and last name is not required for training analysis unless separately required by law or another applicable obligation.

Information linked to an identified or identifiable individual may constitute personal data even when the individual uses a pseudonym.

3. Purposes and Legal Grounds

We process information to register users, administer subscriptions, provide access to training activities, perform requested analyses, maintain security, deliver support and comply with legal obligations.

Processing is based on applicable legal grounds, including contractual necessity, legal obligations and user consent where required.

Where physiological or other information qualifies as a special category of personal data under applicable law, we process it only when an appropriate legal basis exists.

4. Garmin Connect Integration

Users initiate the connection to Garmin Connect and grant the required permissions.

The Platform accesses only information permitted by the applicable integration and necessary for its enabled functions.

We do not sell users' training data or use it for advertising profiling.

Users may disconnect Garmin Connect. Following disconnection, new data retrieval through that connection stops. Previously obtained data is handled under applicable retention rules and legal obligations.

5. Data Minimization and ChatGPT

The Platform is designed to provide compatible MCP clients with the minimum information necessary to fulfill a user's request.

For ordinary training analysis, the intended output includes training metrics and calculated results without legal names, email addresses, profile photographs, persistent Garmin user identifiers or precise GPS coordinates.

Detailed route information may be provided separately when specifically requested and appropriately authorized.

Raw Garmin API responses and complete FIT files are not intended to be transferred to ChatGPT by default.

Minimized training metrics may still constitute personal data where they can be linked to an identifiable individual.

When users connect the Platform to ChatGPT, information transmitted to ChatGPT may be processed by OpenAI under its applicable terms and privacy policy.

Transfers to external services are permitted only after the relevant legal requirements have been satisfied, including any applicable requirements for international personal data transfers.

6. Storage and Security

We implement organizational and technical safeguards, including user access separation, protected transmission channels and restricted access to authorization credentials.

Information is retained only for as long as necessary for the relevant purposes or as required by law.

Specific retention periods for account data, training records, credentials, logs and backups are determined by the controller's approved retention schedule.

Where applicable, we comply with Russian personal data localization requirements.

7. Third-Party Service Providers

We may engage hosting providers, payment processors, technical support providers and compatible application providers where necessary to operate the Platform.

Any sharing is limited to appropriate purposes and lawful grounds.

We do not sell users' personal data.

8. User Rights

Subject to applicable law, users may request information about processing, correction or deletion of their personal data, withdraw consent, disconnect integrations and submit complaints.

Requests should be sent to: support@trainingplatform.ai.

Requests are handled within the periods required by applicable law.

Disconnecting ChatGPT does not necessarily delete information previously processed by an independent third-party platform. Separate requests to that provider may be necessary.

9. Cookies and Technical Data

The Platform may use essential cookies for authentication, security and session management.

Optional analytics and advertising technologies are used only where the necessary legal grounds exist.

10. Policy Changes

We may update this Policy when our services, processing activities or legal obligations change.

The current version will be published on our website with its effective date. Where separate consent is required, it will be obtained before the relevant processing.

11. Contact

SPORTCLUB LLC (ООО «СПОРТКЛУБ»)
INN: 9704030872
KPP: 770401001
OGRN: 1207700338779
Website: https://trilogy-sport.ru
Privacy email: support@trainingplatform.ai