Privacy Policy

ETAPA LTD

Policy version: 13 July 2026

1. Introduction

This Privacy Policy is provided by ETAPA LTD, a company registered in England and Wales under company number 17130882 with registered office at 306b Cavendish Road, London, United Kingdom, SW12 0PJ (‘we’, ‘our’ or ‘us’) for use of our products and services including our app (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2. What this policy applies to

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3. Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of data	In more detail
Identity and account data you input into the Services Registration is mandatory in order to use the Services	Your email address (from Apple or Google sign-in, or a private relay address if you use Apple's email hiding feature) Information from your chosen sign-in provider (your Apple ID or Google account) Your display name, which you enter when setting up your account Your date of birth, where you choose to provide it, which we use to confirm you are 16 or over A separate contact email address, where you provide one because a private relay address was detected Your country code and time zone A unique account identifier that we generate for you
Data collected when you use specific functions in the Services	Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law, in all cases we will assume it is and treat it in accordance with this policy as if it were)
Data collected when you permit the collection of location data	Details of your location, see the section ‘Location services/data’ below, including: The approximate town or city you enter to search for events or shops Your device's location on a one-off basis, if you tap "detect my location" The starting coordinates of routes you plan Route geometry (GPS tracks) for trips and routes you save GPS route data imported from Strava, if you choose to connect that account Locations you search for when looking up events
Health and special category data collected when you use our coaching, fitness, and wellbeing features	Notes about injuries, pain, or health conditions that you choose to share with us, whether in your free-text introduction to your coach, in weekly check-ins, or elsewhere Your responses to weekly check-ins, including how you are feeling, your energy levels, and any pain you flag Bike fit photos you upload (side, front, and rear) and our AI-generated analysis of them Posture check photos you upload for each riding zone and our AI-generated analysis of them Your exercise and strength training logs, including weight lifted, repetitions, perceived exertion, and any notes you add
Other data the Services collects automatically when you use it	Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use Technical information about your device and connection: device type and model, device operating system and version, unique device or installation identifiers, app version number, mobile network information, time zone settings, IP address, and crash and diagnostic logs
Data collected when you make an enquiry with us	Your name and email address

If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4. Personal information of minors

If we collect personal data from individuals under the age of 18 directly, we will assess their capacity to consent on a case-by-case basis. As a general principle, an individual under the age of 18 may have the capacity to consent if they demonstrate sufficient maturity to understand the nature and consequences of what is being proposed. Where it is determined that the individual does not have such capacity, we will seek verifiable consent from a parent or guardian.

If it is not practicable to assess capacity on a case-by-case basis, we will generally assume that individuals aged 13 and above have the capacity to provide consent, unless there are reasonable grounds to believe otherwise. Parents or guardians may contact us using the details set out below to review, manage, or request deletion of their personal information.

5. Sensitive data

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person's sex life; and data concerning a person's sexual orientation.

Because the Services include coaching, fitness, and wellbeing features, we do collect certain data concerning health as part of the Services, such as information you choose to share about injuries or pain, your check-in responses, and metrics from connected devices. We only collect this data where you choose to provide it or connect a relevant third-party service, and we rely on your explicit consent to process it. Please do not submit sensitive personal data to us that falls outside the categories described in the section ‘Personal data we collect about you’ above, such as information about criminal convictions, racial or ethnic origin, religious beliefs, or sexual orientation.

If you do submit sensitive data to us beyond what is described above, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

6. Location services/data

The Services will request your consent to use location services to precisely identify your location each session (i.e. each time the Services is opened or has been placed in the background for more than 30 seconds). We require access to that data in order to facilitate cycling route planning and geometry mapping, support user searches for local shops and events, detect your location upon request, and integrate GPS route data from connected third-party services.

If you do not provide your consent, you may use the Services but that will mean the “maps” feature on the Services will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.

The location services in the Services will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device's location to “off” using the device's settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.

We exert no control over Google's Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data — please visit their site: https://policies.google.com/privacy. For more information see the section ‘Who we share your personal data with’ below.

7. How your personal data is collected

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

At this point in time, we do not collect any personal information about you using cookies or similar technologies within the app. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy. Our website uses cookies as described in our Cookie Policy.

8. How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) the Maps Function will use data relating to your location only based on your consent as described in ‘Location services/data’ (above)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g. in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

9. Human review of AI companion conversations (opt-in)

To refine the AI companion personas and the quality of their advice, members of Etapa's review team — human staff under contract with us — may review a sample of your AI companion conversations. This processing is strictly opt-in:

Off by default. Human review only happens after you have turned on Help improve your companion in Settings → Companion & health → Privacy.
Personal information is redacted before review. Before any human sees a message, our server strips names, email addresses, phone numbers, postcodes, street addresses, URLs, and card-shaped numbers from the text and replaces them with neutral tokens such as [NAME] or [EMAIL]. Redaction runs server-side and is conservative — we err on the side of removing too much.
What reviewers can access. Redacted companion-chat messages, your training guides and sessions, your weekly check-in answers, and metadata about ride-tip requests. Reviewers cannot see your email address, login credentials, payment details, or any data you have not shared with the AI companion.
Withdrawal. You can switch the toggle off at any time. From that point on, no new conversations are eligible for review. Existing redacted samples may be retained for an internal review window of up to 12 months and are then deleted; deleting your Etapa account removes them immediately.

10. Marketing

We intend to send you email marketing to inform you of our services such as promotions.

We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted in to receiving email marketing from us in the past or except where you were given the option to opt out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

contacting us at helloetapa@gmail.com
using the ‘unsubscribe’ link included in all marketing emails you may receive from us

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

11. Who we share your personal data with

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including our AI, infrastructure, analytics, payments, communications, mapping, and data enrichment providers set out in the table below.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

The table below sets out the processors we use, what we use them for, and the personal data each one receives.

Processor	Purpose and personal data received
AI processing
Anthropic (US)	Claude API for coaching chat, plan generation, bike-fit and posture image analysis, check-ins, and route planning. Receives: rider goals and preferences, chat messages, photos and videos, and optionally Strava ride data.
Perplexity (US)	The sonar-pro model, used for find-a-goal event searches. Receives: search criteria such as goal type, distance, and region. We do not send your name, email address, or account ID.
Infrastructure and hosting
Supabase (EU — eu-west-1)	Our database, file storage for photos and videos, and authentication provider. Receives: stores all personal data described in this policy.
Railway (US)	Hosting for our API server, through which all user requests pass. Receives: personal data processed as part of your requests to the Services.
Vercel (US)	Hosting for our website and admin dashboard. Receives: data submitted through our website.
Analytics and monitoring
PostHog (EU)	Product analytics and session replay, with typed text masked. Receives: events linked to your account ID.
Google Analytics (US)	Analytics for our website only, not the app. Receives: cookies, approximate location, and device information. We do not send your name or email address.
Sentry	Crash and error diagnostics. Receives: your account ID and related technical context.
Payments and subscriptions
RevenueCat	Subscription management across app stores. Receives: subscription and webhook events. No payment card details are shared.
Apple	App Store billing, Apple Sign-In, and push notification delivery (via APNs). Receives: data needed to process billing, sign-in, and push notifications.
Google	Play Store billing, Google Sign-In, and push notification delivery (via FCM). Receives: data needed to process billing, sign-in, and push notifications.
Communications
MailerLite	Marketing and product emails. Receives: your email address and engagement events.
Resend	Transactional email delivery, such as verification codes and other communications. Receives: your email address and message content.
Expo	Push notification delivery. Receives: your device push token.
Slack	Internal webhooks for feedback alerts and error notifications. Receives: no personal data in normal operation.
Third-party data sources (only if you connect them)
Strava	Importing your activity data, such as distance, duration, speed, heart rate, and route. Receives: your Strava activity data. This may optionally be sent on to Anthropic as described above.
Whoop	Importing your recovery, strain, and sleep metrics. Receives: your Whoop health and biometric data.
Maps, routing, and location
Mapbox (US)	Map tiles and road route snapping (Directions API). Receives: coordinates. We do not send your account ID.
Nominatim / OpenStreetMap	Geocoding, converting place names to coordinates. Receives: search queries only, without any user identifiers.
Google Places	Searching for stops along a route, such as cafés or food. Receives: your location queries.
BRouter	Gravel and mountain bike route snapping using OpenStreetMap surface data. Receives: coordinates only.
Content and data enrichment
Firecrawl	Web scraping to support event discovery and popular route lookups. Receives: search queries.
Trailforks	Mountain bike trail discovery (this integration may not yet be live). Receives: your location queries.

We or the third parties mentioned above may occasionally also need to share your personal data with:

external auditors, e.g. in relation to the audit of our accounts and our company — the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors) — the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency — usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Other than as set out in this section, we will not share your personal data with any other third party.

12. How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.

Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

13. De-identified information

The personal data we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process and distribute such information.

14. Automated decision-making

We may use automated systems to make decisions that significantly affect you. These processes may involve the use of personal data to evaluate you. You may request human review of any automated decision by contacting us using the details below.

15. Transferring your personal data out of the UK

As part of providing the Services, we may share your personal data with third parties based outside of the UK.

Under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do so; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by relying on an Adequacy Decision being in place for that country, or entering into an International Data Transfer Agreement.

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

16. Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website.

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data — in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party — in certain situations.
To object to use	The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK's Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email us — see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself (e.g. your full name and username) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

17. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

18. How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

19. Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

20. How to contact us

For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:

Name: Robert Honeybul
Email: helloetapa@gmail.com
ETAPA LTD, 306b Cavendish Road, London, United Kingdom, SW12 0PJ
ICO registration number: ZC179799

We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy. Where we make any significant changes, we will endeavour to notify you by email.