Privacy Policy

1. Introduction

This Privacy Policy explains how PaceAdapt collects, uses, stores, and protects your personal data when you use our adaptive running-training platform. We are committed to being transparent about our data practices and respecting your privacy rights under the General Data Protection Regulation (GDPR) and the UK GDPR.

We have written this policy in plain English so you can understand exactly what happens to your data. If anything is unclear, please contact us using the details at the end of this document.

By using PaceAdapt, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are (Data Controller)

PaceAdapt is operated by an individual based in Ireland, trading as PaceAdapt, who acts as the data controller for the personal data processed through this platform.

Contact details:

Email: hello@paceadapt.com

As the data controller, I am responsible for deciding how and why your personal data is processed, and for ensuring that processing complies with applicable data protection laws.

3. What Data We Collect

We collect and process the following categories of personal data:

Account Information

Email address

Name (as provided via your sign-in method or Intervals.icu)

Intervals.icu user identifier
Account preferences and settings

Training and Activity Data

Running activities and workout history
Heart rate data
Distance and pace information
Activity duration and timestamps
Activity metadata (such as activity type, perceived effort, and notes)
Training load and fitness metrics as calculated by Intervals.icu

Generated Data

AI-generated training insights and recommendations
Personalised training plans created by our platform
Workout schedules synced to your calendar

Technical Data

Device type and browser information
IP address
Usage data (pages visited, features used, session duration)
Push notification tokens (if you enable notifications)

Communication Data

Support enquiries and correspondence
Feedback you provide

Coach Conversations

Messages you send to, and responses you receive from, our in-app AI coach
Feedback you give about your plans, whether through the coach, check-ins, or support

We do not collect sensitive health data beyond the training metrics described above. We do not collect data directly from wearable devices such as COROS or Garmin; all activity data flows through Intervals.icu.

4. How We Collect Your Data

We collect data in three main ways:

Directly from you — when you create an account, set your preferences, complete a check-in, message the coach, or contact support.
From Intervals.icu — when you connect your Intervals.icu account, we retrieve your training activities and related metrics, and we sync planned workouts back to it.
Automatically — when you use the platform, we collect limited technical and usage data to operate, secure, and improve the service.

5. How We Use Data

We use your personal data for the following purposes:

To Provide Our Core Service

Authenticating your account
Retrieving and analysing your training history
Generating personalised training insights and recommendations using AI
Creating and adjusting training plans based on your data
Syncing planned workouts back to your Intervals.icu account
Powering the in-app AI coach and responding to your messages

To Communicate With You

Sending essential service communications (account updates, training reminders, check-ins)
Responding to support enquiries
Notifying you of important changes to our service or this policy
Sending push notifications about your training (if you have opted in)

To Maintain and Improve Our Platform

Monitoring platform performance and fixing technical issues
Understanding how users interact with our features
Improving and developing new features based on aggregated usage patterns
Reviewing coach conversations and feedback to improve the quality of our training plans and coaching. We may review messages you exchange with the coach, and feedback you give about your plans, to identify where our plans or guidance can be improved. Wherever practical we use this in aggregated or de-identified form, and any changes we make to how plans are generated are reviewed and approved by us before they take effect.

To Comply With Legal Obligations

Meeting our legal and regulatory requirements
Responding to lawful requests from authorities

We do not use your data for advertising, and we do not sell or rent your data to third parties.

6. Legal Bases for Processing (GDPR)

Under the GDPR, we must have a valid legal basis for processing your personal data. We rely on the following bases:

Contract Performance Most of our data processing is necessary to perform our contract with you—that is, to provide the PaceAdapt service you have signed up for. This includes retrieving your training data, generating insights, and syncing workouts.

Legitimate Interests We process some data based on our legitimate interests, where those interests are not overridden by your rights. This includes:

Improving and developing our platform including reviewing coach conversations and feedback to improve our plans and coaching
Ensuring the security of our service
Understanding general usage patterns (using aggregated, non-identifying data)

Consent We rely on your consent for:

Sending push notifications (you can opt out at any time)
Any optional data processing beyond what is necessary for the service

Legal Obligation We may process data to comply with legal requirements, such as responding to court orders or regulatory requests.

You have the right to object to processing based on legitimate interests, and to withdraw consent at any time where we rely on it

7. AI & Automated Processing Explanation

PaceAdapt uses artificial intelligence to analyse your training data and generate personalised insights and training plans. Here is how this works:

What the AI Does

Reviews your historical training data (activities, heart rate, distance, pace, and related metrics)
Identifies patterns in your training load, recovery, and progression
Generates weekly insights about your training
Creates and adjusts personalised training plans
Responds to your messages in the in-app coach

How It Works

We use one or more reputable third-party AI providers (large-language-model services) to process your training data and coach messages. The relevant data is sent to these providers' APIs in a structured format, and they return analysis, plans, and coaching responses. These providers act as data processors on our behalf under data-processing agreements, and process your data only to provide these features to us. Some of these providers are located outside the EEA and the UK (see International Transfers). A current list of our key sub-processors is available on request at hello@paceadapt.com.

Important Limitations

AI-generated insights are intended to support your training decisions, not replace them
Our recommendations do not constitute medical, physiological, or professional coaching advice
You should consult qualified professionals (such as a doctor, physiotherapist, or certified coach) for health concerns or personalised medical guidance
The AI may not account for factors it cannot observe, such as illness, life stress, or injuries you have not logged

Your Rights Regarding Automated Decisions Under GDPR Article 22, you have rights related to automated decision-making.

Our AI provides recommendations and coaching, but final decisions about your training remain with you, and changes to how our plans are generated are reviewed and approved by a person before they take effect.

8. Data Sharing & Third Parties

We share your data only where necessary to provide our service or meet legal requirements. We do not sell your data or share it for advertising purposes.

We use a small number of trusted third-party providers ("sub-processors") who process data on our behalf, by category:

Training data source — Intervals.icu, for authentication and training-data synchronisation (retrieving your activities and syncing planned workouts back to your account).
AI providers — third-party large-language-model services that analyse your training data and power the coach, as described in AI & Automated Processing.
Hosting, storage & infrastructure — providers that host our website and app, store your account and training data, and run our backend processing. Some are located in the United States.
Payments — payment processing is handled by our payment provider; we do not receive or store your full payment card details.
Push notifications (if enabled) — if you opt in to push notifications, our notification provider stores your device token and notification preferences to deliver them.

We only share data that is necessary for each provider's specific purpose, each provider is bound by a data-processing agreement, and we do not share your data with marketing platforms or advertisers. A current list of our key sub-processors is available on request at hello@paceadapt.com.

Legal Disclosures — We may disclose your data if required by law, court order, or regulatory authority, or to protect our legal rights or the safety of others.

9. Data Retention

We retain your data only for as long as necessary to provide our service and meet our legal obligations.

Active Accounts While your account is active, we retain your data to provide the service. This includes your training history, coach conversations, and generated insights.

Account Deletion When you delete your account or request data deletion:

We will delete or anonymise your personal data within 30 days
Some data may be retained longer if required for legal, accounting, or security purposes, but this will be the minimum necessary
Backup systems may retain data for a limited period before automatic deletion

Intervals.icu Data Deleting your PaceAdapt account does not delete data stored in Intervals.icu. You must manage that data directly through Intervals.icu.

Communication Records We may retain support correspondence for up to 2 years to maintain service quality and resolve disputes.

10. User Rights (GDPR)

Under the GDPR, you have the following rights regarding your personal data:

Right of Access You can request a copy of the personal data we hold about you.

Right to Rectification You can ask us to correct inaccurate or incomplete data.

Right to Erasure (Right to Be Forgotten) You can ask us to delete your personal data in certain circumstances.

Right to Restrict Processing You can ask us to temporarily limit how we use your data while we address a concern.

Right to Data Portability You can request your data in a structured, commonly used format to transfer to another service.

Right to Object You can object to processing based on legitimate interests. We will stop unless we have compelling legitimate grounds.

Right to Withdraw Consent Where we process data based on consent, you can withdraw it at any time.

Right to Lodge a Complaint You have the right to complain to a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO). In Ireland, it is the Data Protection Commission (DPC). In other EU countries, contact your local data protection authority.

How to Exercise Your Rights To exercise any of these rights, please contact us at hello@paceadapt.com. We will respond within one month, as required by law. We may ask you to verify your identity before processing your request.

11. Data Security

We take reasonable and appropriate measures to protect your personal data from unauthorised access, loss, misuse, or alteration.

Our Security Measures Include:

Secure data transmission using HTTPS/TLS encryption

Authentication via OAuth and trusted identity providers your Intervals.icu or third-party sign-in passwords

Access controls limiting who can access personal data within our organisation
Regular review of our security practices
Use of reputable third-party providers with their own security measures

Our Limitations While we work to protect your data, no system is completely secure. We cannot guarantee absolute security of data transmitted over the internet or stored electronically. If we become aware of a security breach affecting your data, we will notify you and relevant authorities as required by law.

12. International Transfers

Where Data May Be Transferred

Your data may be transferred to and processed in countries outside the European Economic Area (EEA) and the UK, including the United States, where some of our AI, hosting, and infrastructure providers operate.

How We Protect International Transfers Where data is transferred outside the EEA/UK, we ensure appropriate safeguards are in place, such as:

Standard Contractual Clauses (SCCs) approved by the European Commission
Transfers to countries with an adequacy decision from the European Commission
Other legally recognised transfer mechanisms

If you have questions about international transfers, please contact us.

13. Cookies & Analytics

PaceAdapt uses cookies and similar technologies to operate our platform.

What Are Cookies? Cookies are small text files stored on your device when you visit a website. They help the site function and can remember your preferences.

Cookies We Use

Our website and app use cookies for:

Essential functionality (keeping you logged in, security)
Basic analytics (understanding how users interact with our site)

We aim to keep cookie use minimal. We do not use advertising cookies or tracking pixels from marketing platforms.

Managing Cookies You can control cookies through your browser settings. Disabling essential cookies may affect your ability to use PaceAdapt.

Push Notifications If you enable push notifications via our app, a device token is stored to deliver notifications. You can disable notifications through your device settings at any time.

14. Children's Data

PaceAdapt is not intended for use by anyone under the age of 16.

We do not knowingly collect personal data from children under 16. If we become aware that we have collected data from a child under 16, we will delete it promptly.

If you believe a child under 16 has provided us with personal data, please contact us at hello@paceadapt.com.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

How We Will Notify You

We will post the updated policy on our website with a new "Last Updated" date
For significant changes, we will notify you by email or through a notice on our platform before the changes take effect

Your Continued Use Your continued use of PaceAdapt after changes take effect constitutes acceptance of the updated policy. If you do not agree with changes, you may delete your account.

We encourage you to review this policy periodically.

16. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us via hello@paceadapt.com.

We aim to respond to all enquiries within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority:

UK: Information Commissioner's Office (ICO) — ico.org.uk
Ireland: Data Protection Commission (DPC) — dataprotection.ie
Other EU countries: Contact your national data protection authority