PACEWISE

Draft. This page is under review and is not final.

Privacy Notice

This page has two parts. Part 1 applies now, to this website. Part 2 describes how the Pacewise service will handle personal data once it opens; no user data is processed by the product today.

Part 1 — Pre-launch website (applies now)

Last updated: [PUBLICATION DATE]

This notice explains how personal data is handled on pacewise.io while Pacewise is in development. Pacewise is a wellness project, not a medical device.

Who is responsible

The data controller is the individual in Spain who is developing Pacewise. Pacewise is not an incorporated company.

Contact: privacy@pacewise.io (data protection) or hello@pacewise.io (general).

What this website does — and does not do

  • It is a static information page. It has no forms, no accounts, no sign-ups and no newsletter.
  • This website uses no analytics, advertising or tracking cookies or similar technologies.
  • To deliver the page and protect it from abuse, our hosting and network provider processes technical data that every browser sends, such as your IP address and browser type, in server logs [to confirm: provider Cloudflare, Inc. (hosting/DNS); which logs exist and how long they are kept].

If you email us

The only way to contact us through this website is by email (the "mailto" link opens your own email program). If you write to us, we receive:

  • your email address and name (as shown by your email program);
  • the content of your message and any attachments;
  • technical email headers (e.g. date, sending server).

Why and on what basis: to read and answer your message and keep a record of the conversation.

  • The legal basis is our legitimate interest in answering people who contact us (GDPR Art. 6(1)(f)).
  • If your message is about a possible future agreement with us (for example, a partnership), it is the steps you asked us to take before entering into a contract (Art. 6(1)(b)).

You are not required to email us; if you do, we need your email address to reply.

Please do not send health information or other sensitive data by email.

Who handles it for us:

  • Our email provider, Zoho Corporation B.V. (the Netherlands), receives and stores emails sent to @pacewise.io addresses and sends our replies, as our processor. It keeps them in its EU data centres (the Netherlands and Ireland).
  • Staff of Zoho group companies outside the European Economic Area may occasionally access this data remotely to provide technical support: in India and, for Spanish-language support, in Mexico and Colombia. The European Commission has not adopted an adequacy decision for these countries, so this access is covered by the European Commission's Standard Contractual Clauses. You can ask us for a copy at privacy@pacewise.io.

We do not sell your data, use it for advertising, or add you to any mailing list. We will not send you marketing emails unless you have asked for them.

How long:

  • We keep correspondence for [PROPOSED: 12 months after the last message], unless it is needed longer to handle a request or a legal claim.
  • If you ask us to delete it sooner, we will, unless we must keep it.

Your rights

You can ask for access to, correction, deletion or restriction of your data, object to our processing, or ask for portability, by writing to privacy@pacewise.io. You can also complain to the Spanish Data Protection Agency (AEPD), www.aepd.es.

Changes

Before Pacewise opens any sign-up, waitlist, beta or app, this page will be replaced by a full privacy policy, and nothing in Part 2 will apply to you until you sign up and give the consents described there.

Part 2 — Product privacy and AI Transparency Statement

Applies once the Pacewise service opens. No user data is processed by the product today. This part is published in advance so that you can see how the service will handle your data. The retention and deletion rules below are the policy the service will apply from the day it opens; items marked planned are not in place yet and may change. All of it will be confirmed, and completed with the full details required by law, in the privacy policy you will be shown before you sign up. If anything here changes, this part will be updated first.

Pacewise is a wellness and fitness coaching service. It is not a medical device and does not provide medical advice, diagnosis or treatment. The controller will be the same person as in Part 1.

AI Transparency Statement

  • Optional and separate consent. Pacewise is designed to use an AI system to write coaching reports only if you give a separate, explicit consent ("AI coaching"), off by default and separate from your other consents (GDPR Art. 9(2)(a)). You will be able to withdraw it at any time in the app's privacy settings, as easily as you gave it (Art. 7(3)). If you do not give it, the rest of the service works without AI reports.
  • Nature and purpose. The AI turns wellness metrics into plain-language training and recovery commentary. It is instructed not to give medical diagnoses, prescriptions or clinical recommendations, and to suggest seeing a qualified professional where the data may indicate a health concern. AI output is informational only: no decision with legal or similarly significant effect is made about you by automated means.
  • What the AI receives — derived metrics only. Before any AI processing, your wearable data is reduced to a small set of derived scores and trends (for example a recovery score, a training-load estimate and sleep-regularity patterns), with the date range they cover and your preferred units. The AI does not receive your raw wearable records, your name, your email address or your account ID. This summary is still your personal data, and is treated as health data: it is not anonymous.
  • Who provides the AI — planned. Amazon Web Services (Amazon Bedrock) [to confirm contracting entity: Amazon Web Services EMEA SARL], as our processor, only in its EU data centres (Frankfurt, Stockholm, Milan, Spain, Ireland or Paris), under the AWS Data Processing Addendum, which includes the EU Standard Contractual Clauses for any transfer outside the EEA. [Not yet live: applies once the switch is complete.]
  • Transfers — planned. We do not plan to transfer this data outside the European Economic Area. Our AI provider belongs to a group headquartered in the United States, so authorities outside the EU could ask it for data; it has committed by contract to try to redirect any such request to us. [Lawyer to confirm wording.]
  • What the AI provider keeps — planned. We intend to set up the service so that our AI provider does not keep this data after the report is written. Whether the provider's terms still allow it to keep the data for a time, for example for abuse detection, and for how long, is still to be verified [to confirm against the provider's terms for the model used].
  • Training — planned. Our AI provider states that data sent to its AI service is not used to train or improve AI models [to confirm against the provider's terms for the model used].
  • When we withdraw or change this. If the AI provider, the place of processing, the data sent to it or the purpose changes, this statement will be updated and, where required, your consent asked for again before the change applies.

Wearable data — as designed

  • You will be able to connect a supported wearable provider only after giving a separate, explicit consent for wearable data processing (GDPR Art. 9(2)(a)).
  • Pacewise is designed to keep only what its calculations need, as simple daily records (activities, sleep and heart-rate summaries). Device identifiers and location are removed, and times are reduced to calendar dates.
  • Raw provider data. Raw data received from a wearable provider is processed in memory, reduced to the daily records above, and not stored as retained application data.
  • Provider notifications — planned. Where a provider notifies us that new data is available, the notification is designed to be held only in an internal processing queue, hosted in the EU, until it is reduced to the daily records above, and then removed from the queue [to confirm: queue retention and persistence settings].
  • Pacewise does not send data back to wearable providers and does not sell your data.

Retention [lawyer to confirm]

These retention periods apply once the service opens. Data can be deleted sooner: see the next section.

DataRetention
Daily wearable records and wellness metricsRolling 90 days, unless deleted sooner
AI reports, with the summary of derived metrics each was written from365 days (about 12 months), unless deleted sooner
Server logs and error reports30 days [to confirm: hosting log and error-report retention]
Database backupsUp to 7 days [to confirm with the hosting provider's backup settings]
Data sent to the AI providerPlanned: our intended setting is that the AI provider does not keep it after the report is written [to confirm: zero-retention setting evidenced]; any retention the provider's terms still allow, for example for abuse detection, is still to be verified
Record of your consents (a random account identifier, the type of consent, whether it was given or withdrawn, the dates, and the version of this notice it was given against)For the life of the account; then, once the account is deleted, 1,095 days (about three years), blocked (LOPDGDD Art. 32): kept only to prove consent if challenged, then deleted
Records of consent and deletion events (e.g. "consent withdrawn", "deletion completed"), kept with the same random account identifier and no health dataFor the life of the account; then, once the account is deleted, 1,095 days (about three years), blocked, then deleted
Records of other actions on your account (e.g. that disconnecting a provider deleted its data, with counts only)365 days
  • Disconnecting a provider: syncing stops and the access tokens we hold for that provider are deleted immediately. The daily records from that provider, and every AI report based on them or whose source is not recorded, are permanently deleted within 24 hours. Disconnecting in Pacewise does not cancel the access you granted at the provider itself; you can remove it in your account with the provider.
  • Withdrawing wearable-data consent: syncing stops, all your wearable providers are disconnected and the access tokens we hold are deleted immediately. All your daily records and all your AI reports are permanently deleted within 24 hours.
  • Withdrawing AI-coaching consent: no new reports are generated from that moment, and your existing reports are permanently deleted within 24 hours.
  • Deleting your account: for seven days after you ask, you can cancel the request. After that, your account and its data are permanently erased, within 30 days of your request at the latest, except the blocked consent and deletion records described above and copies in database backups until those expire.

Your rights

Access, rectification, erasure, restriction, objection, portability and withdrawal of consent, by writing to privacy@pacewise.io; complaints to the AEPD (www.aepd.es). The minimum age for the service will be 18.

Sources (verified on 2026-10-29; remove before publishing):

  • GDPR — https://www.boe.es/buscar/doc.php?id=DOUE-L-2016-80807: Arts. 5(1)(a), 6(1)(b), 6(1)(f), 7(3), 9(2)(a), 13, 15–21, 22, 77.
  • WP29 Guidelines on transparency WP260 rev.01 (endorsed by the EDPB), para. 27 and Annex: https://ec.europa.eu/newsroom/article29/redirection/document/51025.
  • LOPDGDD — https://www.boe.es/buscar/act.php?id=BOE-A-2018-16673: Arts. 7, 11, 32.
  • Ley 3/1991 de Competencia Desleal — https://www.boe.es/buscar/act.php?id=BOE-A-1991-628: Art. 5.
  • AI provider (planned): Amazon Bedrock data retention https://docs.aws.amazon.com/bedrock/latest/userguide/data-retention.html; data protection https://docs.aws.amazon.com/bedrock/latest/userguide/data-protection.html; Bedrock FAQs https://aws.amazon.com/bedrock/faqs/; AWS Data Processing Addendum https://d1.awsstatic.com/legal/aws-dpa/aws-dpa.pdf (§§3, 12, 16); AWS Customer Agreement §12 https://aws.amazon.com/agreement/ (verified on 2026-10-29).