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Privacy Policy

Last Updated: March 17, 2026

1. Introduction

Sprout Media Limited (registered in Ireland) develops and operates Finzy Swimlog (the mobile app for swimmers) and the Finzy Coach Platform (the web dashboard for coaches). Together, these are referred to as "Finzy" or "the Services" in this policy.

Sprout Media Limited is the data controller for any personal data processed through the Services. This Privacy Policy explains how we collect, use, store, and protect your data across both the swimmer app and the coach platform. Our contact details are provided in Section 16 below.

2. Data Collection & Usage

2.1 Swimmers — Using the App Without a Squad

If you use Finzy Swimlog without joining a coach's squad, the app runs entirely on your device. All data is stored locally and Sprout Media Limited does not have access to it. The AI processes data you input temporarily to generate training insights and reports; this data is not stored permanently by Sprout Media Limited or any external service.

2.2 Swimmers — Joining a Squad

To join a coach's squad, you must create an account. Once you are part of a squad, the following data is stored in our database:

  • Your user ID and email address, for account verification and identification
  • Logged session data (distance, metrics, and other training details you record)
  • Meet and meet entry data, including both meets you create and meets created by your coach
  • Inputs you provide for coach-created metrics where your coach has enabled swimmer input
  • Mood data you optionally provide (selected from preset options)

This data is stored solely to enable the squad functionality. Your coach can view the training data you log while you are a member of their squad. Your training data is also always stored locally on your device, so if you leave a squad you retain a full copy of your data on your device. However, you will lose access to the app unless you join another squad or pay for a subscription.

2.3 Swimmers — Individual Subscription Users

This section applies to swimmers who pay for an individual subscription rather than joining a coach's squad. If you purchase an individual subscription through the App Store or Google Play, the following applies:

  • Apple or Google processes your payment. We do not receive or store your payment card details.
  • RevenueCat, our subscription management provider, collects limited data such as your subscription status and a unique user identifier for subscription management and fraud prevention. This data is not linked to your personally identifiable information.
  • Your training data is stored locally on your device. If you do not create an account, Sprout Media Limited does not store any of your personal data in our database.

2.4 Coaches — The Finzy Coach Platform

When you create a coach account on the Finzy Coach Platform, the following data is stored in our database:

  • Your name and email address, for account creation and communication
  • Your country, used to determine applicable age thresholds for swimmer consent (see Section 12)
  • Squad configuration data, including squad names, squad codes, and settings you create
  • Workout plans, session templates, metrics, and any other content you create within the dashboard
  • Data you input about swimmers, including age declarations (over or under 16) and parent/guardian email addresses for swimmers you identify as under 16
  • Your subscription and billing data (see Section 2.5 below)

All data you input in the coach dashboard is stored securely in our database and is used solely to provide the Finzy Coach Platform functionality.

2.5 Coaches — Subscription & Payment

This section applies to coaches who subscribe to the Finzy Coach Platform. Payment for the coach platform is processed by Stripe. When you subscribe:

  • Stripe collects and processes your payment information (such as card details and billing address) directly. Sprout Media Limited does not receive or store your full payment card details. We receive confirmation of your subscription status, payment history, and a Stripe customer identifier.
  • Your subscription status is used to manage your access to the coach platform.
  • Stripe may process data outside the European Economic Area (EEA). Where this occurs, appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

For more information on how Stripe handles your data, see Stripe's privacy policy at stripe.com/privacy.

2.6 Data Export and Device Transfer

If you wish to transfer your data to a new device, some account-related and squad data will be available when you sign in with your account. To transfer your full training history and locally stored data, you can use the data export and import feature within the Finzy Swimlog app.

2.7 Analytics & Tracking

Finzy does not use any analytics, advertising, or tracking services across either the swimmer app or the coach platform. We do not collect usage statistics, crash reports, or behavioural data.

3. Legal Basis for Processing

Where we process personal data, we rely on the following legal bases under the General Data Protection Regulation (GDPR):

  • Performance of a contract: Processing your account data, squad data, and coach platform data is necessary to provide the services you have signed up for.
  • Legitimate interest: Processing limited data through RevenueCat (swimmer subscriptions) and Stripe (coach subscriptions) for fraud prevention and subscription management.
  • Consent: For swimmers under 16 years of age, we process personal data on the basis of verifiable parental or guardian consent. See Section 12 for details.

4. Data Processors & International Transfers

Squad-related data and coach platform data is stored using Supabase, our cloud database provider, hosted in the EU (Ireland).

The following third-party data processors may process data outside the European Economic Area (EEA):

  • Stripe (coach subscription payments)
  • RevenueCat (swimmer subscription management)
  • Apple / Google (swimmer in-app subscription payments)

Where data is transferred outside the EEA, appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

5. Your Rights

Under the GDPR and applicable data protection laws, you have the following rights:

  • Right of access: Without a squad, all swimmer data is stored locally on your device and fully under your control. As a squad member or coach, you may request a copy of the personal data we hold about you.
  • Right to erasure: Local data can be deleted by uninstalling the app. You may request deletion of any data held in our database, including squad-related data and coach platform data.
  • Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
  • Right to data portability: Swimmers can transfer their data by using the in-app export and import feature located in the settings modal.
  • Right to withdraw consent: Where processing is based on consent (including parental consent for under-16s), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact us at privacy@finzy.app. We will respond within 30 days.

Parents and guardians may exercise any of the above rights on behalf of their child at any time by contacting privacy@finzy.app. See Section 12 for further details.

6. Required Permissions

Microphone (Finzy Swimlog app only): Finzy Swimlog requires access to your device's microphone for voice-to-text transcription, allowing you to log training sessions hands-free.

7. Data Retention

Swimmer data: Local app data remains on your device until you uninstall the app. Your training data is always stored locally, regardless of whether you are part of a squad. Squad-related data stored in our database is retained for as long as your account exists. If you leave a squad, your data remains in our database in case you rejoin or join another squad. If you wish to have your squad data deleted, you can request this by contacting us at privacy@finzy.app, or by using the account deletion feature described in Section 8.

Coach data: Coach platform data (including squad configuration, workout plans, and any content you have created) is retained for as long as your coach account exists. If you cancel your subscription, your data is retained for 90 days in case you resubscribe, after which it is permanently deleted. You may request earlier deletion by contacting us at privacy@finzy.app.

Minors' data: If parental consent for a swimmer under 16 is withdrawn or declined, all squad-related data for that swimmer is deleted from our database promptly. See Section 12 for details.

8. Account Deletion

Swimmers: You can request full deletion of your account and all associated data stored in our database by visiting finzy.app/delete-account or by contacting us at privacy@finzy.app. Upon deletion, all squad-related data tied to your account will be permanently removed from our systems. Local data on your device is not affected and can be removed by uninstalling the app.

Coaches: You can request full deletion of your coach account and all associated data (including squad configurations and any content you have created) by contacting us at privacy@finzy.app. Upon deletion, swimmers in your squad(s) will be notified that the squad has been dissolved. Swimmer data that was logged by individual swimmers remains in their local app storage.

9. Security

Swimmers not in a squad: Data is stored on your device only and there are no security risks on our end.

Squad members and coaches: All data stored in our database is handled securely. Data is encrypted in transit between your device and our servers. Our database is hosted in the EU (Ireland) by Supabase, which maintains industry-standard security practices. Payment data is handled entirely by Stripe (coaches) and Apple/Google (swimmers) — we never receive or store full payment card details.

Users should ensure their device is secure and avoid entering unnecessary personal information in the app or coach platform.

10. Changes to the Policy

This Privacy Policy may be updated from time to time. Users will be notified of material changes through the app or coach platform. Continued use of the Services after changes constitutes acceptance of the updated policy. Where we process data on the basis of consent (including parental consent for minors), we will seek fresh consent where a change materially affects how that data is processed.

11. Data Processing Agreement — Coaches

By using the Finzy Coach Platform, coaches acknowledge that they act as a point of contact between Sprout Media Limited and the swimmers in their squad. Coaches agree to:

  • Accurately declare whether a swimmer joining their squad is under 16 years of age
  • Provide a valid parent or guardian email address for any swimmer they identify as under 16
  • Not use the Finzy Coach Platform to collect or store data about swimmers beyond what is necessary for training and squad management purposes

Sprout Media Limited acts as the data controller for all personal data processed through the Services. Coaches do not become independent data controllers by using the coach platform.

12. Children's Privacy

Finzy Swimlog is used by competitive swimmers, many of whom are under 16 years of age. We take the protection of children's personal data seriously and have implemented the following safeguards.

Age Threshold

We apply a universal age threshold of 16 years. Swimmers under 16 require verifiable parental or guardian consent before any of their personal data is stored in our database. This threshold meets or exceeds the requirements of the GDPR (Article 8), Ireland's Data Protection Act 2018, the UK GDPR, and the US Children's Online Privacy Protection Act (COPPA).

How Consent Works

When a swimmer requests to join a coach's squad, the coach reviews the request and declares whether the swimmer is 16 or over, or under 16.

  • Swimmers aged 16 and over are approved by the coach and can use the app immediately.
  • Swimmers under 16 require parental consent before they can access the app. The coach provides the parent or guardian's email address. We then send a consent notification to the parent or guardian that clearly explains:
    • What data is collected (training sessions, distances, metrics, mood selections, email address, and user ID)
    • Who can see the data (the coach of the squad the swimmer is joining)
    • How the data is used (to provide training insights and squad functionality)
    • How to withdraw consent at any time

The parent or guardian must actively confirm consent before the swimmer is granted access. No personal data beyond the swimmer's name (as provided by the coach) and the parent's email address is stored until consent is granted. If consent is not granted within 14 days, the request expires and any data associated with it is deleted.

What Data Is Collected From Minors

We collect the same categories of data from minor squad members as from adult squad members, as described in Section 2.2. We do not collect any additional data from minors. We do not use any minor's data for advertising, profiling, or any purpose other than providing the squad and training functionality.

Parental Rights

Parents and guardians of swimmers under 16 have the right to:

  • Review the personal data we hold about their child by contacting privacy@finzy.app
  • Request deletion of their child's data at any time by contacting privacy@finzy.app
  • Withdraw consent at any time by contacting privacy@finzy.app. Upon withdrawal, the swimmer will be removed from their squad and all associated squad data will be deleted from our database promptly. The swimmer retains any locally stored data on their device.

We will action any parental request within a reasonable timeframe, and in any event within 30 days.

Data Minimisation

We collect only the data necessary to provide the training logging and squad functionality. We do not collect precise geolocation data, photographs, video, or biometric data from any user, including minors.

13. Additional Google Play Disclosures

Notification Permission

Finzy Swimlog requests permission to send push notifications. These notifications are used solely to remind users to log training. You can allow or deny notification access when prompted and can disable notifications at any time in your device's settings. No personal data is collected or transmitted through notifications.

In-App Access to Privacy Policy

This Privacy Policy is accessible at any time from within the Finzy Swimlog app under the Settings section.

Google Play Data Safety

For non-squad users, we do not collect or share any personally identifiable data. For squad members, certain account, training, and meet data is collected as described in Section 2.2. Limited data processed by RevenueCat for subscription management and fraud prevention is encrypted in transit.

14. Additional US Disclosures (COPPA)

Finzy complies with the Children's Online Privacy Protection Act (COPPA) for users in the United States. We apply our universal under-16 parental consent requirement to all users, which exceeds COPPA's under-13 threshold. We do not condition a child's participation on the collection of more personal information than is reasonably necessary to provide the squad and training functionality. Parents may contact us at privacy@finzy.app to review, request deletion of, or withdraw consent for their child's data.

15. Additional Apple App Store Disclosures

Finzy Swimlog uses a squad-code-based access model. Swimmers can access the app for free when they join a coach's squad using a code provided by their coach. Alternatively, swimmers may purchase an individual subscription through the App Store. The app does not use any third-party advertising or tracking frameworks.

16. Contact Us

If you have any concerns or questions about your privacy, or to exercise any of your rights (including parental rights regarding children's data), contact:

Contact Information

Data Controller: Sprout Media Limited

Address:
Suite 16, The Mall
Beacon Court, Sandyford
DUBLIN 18
Ireland

Phone: +353 89 222 7759

Email: hello@finzy.app

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