Dokar Sirri

INTRODUCTION

This Privacy Policy describes how KEEZOKU, a simplified joint-stock company (SAS) with a capital of €5,000.00, registered with the R.C.S. of Paris under number 847 647 054, whose headquarters is located at 60 rue François Ier, 75008 Paris, France (hereinafter "Gymkee", "we", "our"), collects, uses, stores, and protects your personal data when you use the Gymkee platform, including the gymkee.com website, the Gymkee Coach web app, and the Gymkee mobile app.

This policy applies to all Gymkee users, whether they are sports coaches (professional users) or their clients/athletes (mobile app users).

Gymkee is committed to complying with the General Data Protection Regulation (GDPR , Regulation EU 2016/679), the French Data Protection Act of January 6, 1978, as amended, and the recommendations of the French Data Protection Authority (CNIL).

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1. DATA CONTROLLER AND CONTACT

1.1 Data Controller

KEEZOKU 60 rue François Ier, 75008 Paris, France SIREN: 847 647 054 E-mail: [email protected]

1.2 Privacy Contact

For any questions about the protection of your personal data or to exercise your rights:

• E-mail: [email protected]
• Postal address: KEEZOKU , Data Protection, 60 rue François Ier, 75008 Paris, France

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2. GYMKEE'S DUAL ROLE

Gymkee acts in two distinct roles under the GDPR:

2.1 Gymkee as Data Controller

KEEZOKU is the data controller for:

• Coach data (account data, billing data, platform usage data);
• Technical and usage data for all users (logs, cookies, browsing data);
• Data necessary for the operation of the platform and mobile app.

2.2 Gymkee as Processor

KEEZOKU acts as a processor (within the meaning of Article 28 of the GDPR) on behalf of Coaches regarding their Clients/Athletes' data. Coaches are the data controllers for the data of their Clients that they collect and use in their coaching activities via Gymkee.

The respective obligations are governed by our Data Processing Agreement (DPA), available at gymkee.com/legal/dpa.

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3. DATA COLLECTED

3.1 Coach Data

Category	Data	Purpose
Identification Data	Name, first name, email address, phone number, profile picture	Account management, communication
Professional Data	Trade name, SIRET/business number, qualifications, specialties	Professional identification
Billing Data	Billing address, payment method (via Stripe), billing history, VAT number	Billing, accounting
Usage Data	Logins, actions on the platform, features used, technical logs	Service improvement, support
Gymkee Pay Data	Stripe Connect account data, transaction history	Payment processing

3.2 Client/Athlete Data

Category	Data	Purpose
Identification Data	Name, first name, email address, profile picture	Account management
Profile Data	Date of birth, gender	Program personalization
Health Data ⚠️	Weight, height, body measurements, body fat percentage, BMI	Progress tracking
Nutritional Data ⚠️	Caloric intake, macronutrients, food journal, dietary preferences, allergies	Nutritional program
Training Data ⚠️	Performance (weights, reps, time), heart rate, session history	Program tracking
Usage Data	Logins, app navigation, notifications	Service operation

⚠️ This data constitutes "health data" within the meaning of Article 9 of the GDPR and benefits from enhanced protection. Their processing is based on your explicit consent, collected separately and specifically.

3.3 Automatically Collected Data

For all users, we automatically collect:

• Technical Data: IP address, browser type, operating system, device type, device identifier, screen resolution;
• Browsing Data: pages viewed, visit duration, actions taken;
• Log Data: connection timestamps, technical errors.

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4. LEGAL BASES AND PURPOSES OF PROCESSING

4.1 Processing Based on Contract Performance (Art. 6(1)(b) GDPR)

• Creation and management of user accounts
• Provision of Services (programs, tracking, messaging)
• Payment processing and billing
• Customer support
• Service-related notifications (updates, maintenance, important changes)

4.2 Processing Based on Explicit Consent (Art. 9(2)(a) GDPR)

• Collection and processing of health data (measurements, nutritional data, training performance)
• Transmission of health data to the Coach for tracking
• Synchronization with third-party health apps (Apple HealthKit, Google Health Connect)

Consent for health data is:

• collected separately and distinctly, not bundled with acceptance of the T&Cs;
• specific to each category of data (measurements, nutrition, training);
• freely given, informed, and unambiguous;
• revocable at any time from the app settings, without affecting the lawfulness of prior processing.

4.3 Processing Based on Consent (Art. 6(1)(a) GDPR)

• Marketing and promotional communications
• Marketing push notifications
• Non-essential cookies and trackers (see our Cookie Policy)

4.4 Processing Based on Legitimate Interest (Art. 6(1)(f) GDPR)

• Platform improvement and usage analysis (aggregated and anonymized statistics)
• Fraud detection and prevention
• Platform security

4.5 Processing Based on Legal Obligation (Art. 6(1)(c) GDPR)

• Retention of billing data (accounting and tax obligations)
• Response to legal requests
• Tax declarations

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5. DATA RECIPIENTS

5.1 Internal Access

Only authorized members of the KEEZOKU team have access to personal data, strictly as necessary for their functions.

5.2 Sub-processors

We share your data with the following sub-processors, who process data on our behalf and according to our instructions:

Sub-processor	Country/Region	Function	Data Concerned
Amazon Web Services (AWS)	EU , eu-west-3 (Paris)	Hosting and infrastructure , HDS Certified	All data
MongoDB Atlas (MongoDB, Inc.)	EU	Database	All application data
Stripe Payments Europe, Ltd.	Ireland/EU	Payment processing	Billing and payment data
Cloudflare, Inc.	United States	Website hosting (Cloudflare Pages)	Navigation data
Algolia	EU	Search engine	Food data, exercises
Segment (Twilio)	United States	Analytics (server-side)	Anonymized usage data
Mixpanel	United States	Analytics	Anonymized usage data
Intercom	United States	Customer support and messaging	Identification data, messages
Google LLC	United States	Analytics (GA4, GTM)	Anonymized browsing data
Meta Platforms, Inc.	United States	Advertising measurement (Meta Pixel)	Anonymized conversion data
FirstPromoter	Netherlands	Affiliate tracking	Referral data
Expo (EAS)	United States	Mobile app distribution	Technical data

The complete and up-to-date list of our sub-processors is available at gymkee.com/legal/sub-processors.

5.3 Transfers Outside the EU

Some of our sub-processors are located outside the European Economic Area (EEA), notably in the United States. These transfers are governed by:

• the Standard Contractual Clauses (SCCs) adopted by the European Commission;
• the EU-US Data Privacy Framework, where applicable;
• additional technical measures (encryption of data in transit and at rest).

5.4 Transmission to the Coach

When you are a Client/Athlete, your data (including health data for which you have given consent) is transmitted to your Coach via the platform. The Coach is the data controller for this data in the context of their coaching relationship with you.

5.5 Other Sharing Cases

We may disclose your data:

• to judicial or administrative authorities, in case of legal requisition;
• to a potential acquirer in case of restructuring, merger, or business transfer, subject to confidentiality obligations.

We never sell your personal data to third parties. We do not use your data for targeted advertising purposes.

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6. DATA RETENTION

Data Category	Retention Period
Account Data (active)	Throughout the contractual relationship
Account Data (after deletion)	30 days after the deletion request, then erased
Health Data	Deleted within 30 days following consent withdrawal or account deletion
Billing Data	10 years from the end of the fiscal year (legal accounting obligation , Art. L123-22 of the Commercial Code)
Stripe Payment Data	Retained by Stripe according to its own retention policy
Connection Logs	12 months (legal obligation , LCEN Art. 6-II)
Analytics Data	Anonymized beyond 26 months
Commercial Prospecting Data	3 years after the last contact
Consent Data (proof)	5 years from withdrawal or expiration of consent

At the end of these periods, the data is deleted or irreversibly anonymized.

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7. DATA SECURITY

7.1 HDS Certified Hosting

The health data processed by Gymkee is hosted on the Amazon Web Services (AWS) infrastructure in the eu-west-3 region (Paris, France). AWS holds the Health Data Hosting (HDS) certification issued in accordance with Article L.1111-8 of the French Public Health Code, attesting to compliance with the security, confidentiality, and availability requirements applicable to the hosting of health data.

7.2 Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or disclosure, including:

Technical measures:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
• Secure authentication and access management
• Regular backups and disaster recovery plan
• Monitoring and intrusion detection
• Separation of environments (development, testing, production)

Organizational measures:

• Limited data access based on the principle of least privilege
• Team training on best data protection practices
• Security incident management procedure
• Regular assessment of security measures

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8. RIGHTS OF DATA SUBJECTS

In accordance with the GDPR and the French Data Protection Act, you have the following rights:

8.1 Right of Access (Art. 15 GDPR)

You can obtain confirmation that data concerning you is being processed and receive a copy.

8.2 Right to Rectification (Art. 16 GDPR)

You can request the correction of inaccurate or incomplete data.

8.3 Right to Erasure (Art. 17 GDPR)

You can request the deletion of your data in the cases provided for by the GDPR. Deletion occurs within one (1) month of the request, subject to legal retention obligations.

8.4 Right to Data Portability (Art. 20 GDPR)

You can receive your data in a structured, commonly used, and machine-readable format (JSON or CSV).

8.5 Right to Restriction of Processing (Art. 18 GDPR)

You can request the restriction of processing in certain cases (dispute of accuracy, unlawful processing, etc.).

8.6 Right to Object (Art. 21 GDPR)

You can object to processing based on legitimate interest for reasons related to your particular situation.

8.7 Right to Withdraw Consent

For processing based on consent (notably health data), you can withdraw your consent at any time:

• from your account settings (app or web);
• by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

8.8 Post-Mortem Directives

In accordance with the French Data Protection Act, you can define directives regarding the retention, deletion, and communication of your data after your death.

8.9 Exercising Rights

To exercise your rights:

• E-mail: [email protected]
• Mail: KEEZOKU , Data Protection, 60 rue François Ier, 75008 Paris, France

We respond to any request within one (1) month. This period may be extended by two (2) months in case of complexity or a large number of requests. We will inform you of any extension.

We may ask you to verify your identity before processing your request.

8.10 Complaint to the CNIL

If you believe that the processing of your data does not comply with the regulations, you can file a complaint with the French Data Protection Authority (CNIL):

• Website: https://www.cnil.fr
• Address: CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07

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9. COOKIES AND TRACKERS

Gymkee uses cookies and trackers. For detailed information on the cookies used, their purposes, and your setting options, please see our Cookie Policy.

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10. MINORS' DATA

Gymkee is not intended for persons under 16 years of age. We do not knowingly collect data from persons under 16. Persons aged 16 to 18 must obtain permission from their legal representative to use Gymkee.

If we become aware that a minor under 16 has provided personal data, we will delete this data as soon as possible.

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11. DATA BREACH NOTIFICATION

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the CNIL within 72 hours in accordance with Article 33 of the GDPR.

If the breach is likely to result in a high risk to your rights and freedoms, we will inform you directly as soon as possible, in accordance with Article 34 of the GDPR, specifying the nature of the breach, the likely consequences, and the measures taken or planned.

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12. POLICY CHANGES

We may change this Privacy Policy at any time. In case of substantial changes, we will inform you by email or via the app at least fifteen (15) days before it takes effect.

The date of the last update is indicated at the top of this page. We encourage you to regularly review this policy.

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13. CONTACT

For any questions about data protection:

KEEZOKU , Data Protection 60 rue François Ier, 75008 Paris, France E-mail: [email protected]