Privacy notice

1. Who we are

CONTROL is run by [Orbriva Systems Ltd, company number ____, registered office ]. We are the "controller" of your information. ICO registration number: []. Contact for anything about your data: privacy@orbriva.com.

2. What CONTROL is, and isn't

CONTROL helps adult athletes record and review training, wellbeing and pain, and flags concerns for discussion with coaches or practitioners. It does not diagnose, predict injury, or guide treatment or return-to-play decisions. Decisions stay with you, your coach and your physio or doctor.

3. What we collect

Account details: name, email, age confirmation (18+), password (stored securely by our login provider).
About you and your sport: role, format, rough training load, and any injury history you choose to type in.
Health and training information: sleep, soreness, pain, load, sessions, check-ins, test results, and head-impact history. This is "special category" health data under UK GDPR.
Apple Health (only if you tick consent 2 and upload an export): sleep and activity values from the file you upload, which you confirm. CONTROL does not connect to Apple Health or read it automatically.
Feedback (only if you opt in): survey answers and notes from an end-of-pilot call.
Technical: basic logs needed to run and secure the app (e.g. sign-in times). We don't use advertising or analytics trackers (checked by Milo, 12 Oct; any future analytics must be cookie-free and added here).

4. Why we use it, and our legal basis

Use	Legal basis (A)
Running your account and the pilot	Contract: Article 6(1)(b)
Storing and showing your health and training information	Your explicit consent: Article 9(2)(a), consent 1
Apple Health import	Explicit consent, consent 2
Pilot feedback contact	Consent, consent 3
Keeping consent and billing records	Legal obligation / legitimate interests: Article 6(1)(c)/(f)
We don't sell your data, use it for advertising, or use it to train AI models.

5. Automated flags

CONTROL compares your entries against your own usual range and may flag a change worth reviewing. This is information for you, not a decision about you. Nothing is decided automatically that has a legal or similarly significant effect on you (A: lawyer to confirm Article 22 doesn't apply).

6. Who we share it with

Only service providers who process it for us under contract:

Supabase: database and login, stored in the EU (Ireland).
Vercel: hosts the app. Its servers currently run in the US (Washington DC), so your data passes through the US while you use the app. [We plan to move this to Dublin before the pilot; update this line once moved. If it stays in the US, the legal review must confirm the transfer safeguard (A).]
Microsoft 365: our email. We share with no coach or club during the pilot (coach sharing comes later and will need a new, separate consent). We'd only disclose data to others if the law requires it.

7. How long we keep it (pending approval of item 39)

Account, health and training data: while your account is active.
Apple Health imports: the imported sleep, steps and heart-rate values are deleted (on our systems and in your browser) when you untick consent 2. Any value you accepted into a check-in answer becomes part of that check-in and stays until the check-in is deleted. The export file is read on your own device and is never uploaded or stored by us; only the sleep, steps and heart-rate values you confirm are saved, along with the name of the source app and device (for example "Your iPhone").
If you use CONTROL before signing in (guest mode), your entries are kept in your browser's storage on that device. They stay there after you sign in until you clear your browser data. Use your own device, not a shared one.
Pilot data: deleted or anonymised within 30 days of the pilot ending, unless you choose to carry on.
Inactive accounts: deleted after 24 months without signing in, with warnings first.
Deleting your account: 30-day grace period, then permanent deletion (or straight away if you ask).
Backups: [only once Supabase Pro or the Step 0 manual backup is in place; don't promise backups yet].
Consent records: account life plus 6 years (proof of consent only, no health data).
Usage logs with no health data: 12 months.

8. Your rights

You can: access your data; correct it; delete it; export it; withdraw any consent at any time under You, in Your consents (this doesn't affect what we did before); object or ask us to restrict use. Email privacy@orbriva.com and we'll reply within one month. You can complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113. We'd appreciate the chance to sort it out first.

9. Security

Your data is encrypted in transit and when stored. Database access rules limit each account to its own records, and only Orbriva's founder has admin access. We'll tell you, and the ICO where required, if a breach affects your data.

10. Changes

We'll tell you in the app before any important change. Version: draft 0.1, [date].

If you visit orbriva.com

What we collect: we don't use analytics, advertising or tracking cookies on orbriva.com. Our website host, Cloudflare (Cloudflare Pages), briefly processes standard technical data, such as your IP address, browser type and the pages requested, so the site can be delivered and kept secure. [Confirm Cloudflare Pages log retention.] The CONTROL app itself is hosted by Vercel in Dublin (dub1).
Cookies: the site sets no cookies unless you sign in to CONTROL. Signing in uses only strictly necessary cookies or storage to keep you signed in. [Confirm with Milo that the marketing pages set none.]
If you email us: we use your message and email address only to reply. We keep them for up to [12 months] unless they relate to a data request, in which case they're kept with that request's record.
Pilot interest: [only if the site gets a sign-up form. Not planned. Tell Ivy first if it's added.]
Where it's processed: Cloudflare's global network (the website) and Vercel in Dublin (the app). Any transfers outside the UK are covered by each provider's data processing agreement and the UK's approved transfer safeguards.