This Privacy Policy (“Policy”) describes how REBORN TRAINING SYSTEMS, LLC, a Utah limited liability company (“REBORN”, “Company”, “we”, “us”, or “our”), collects, uses, discloses, and protects the personal information of users (“you”, “your”) when you access or use our website, mobile application, and any related services (collectively, the “Services”). By accessing or using the Services, you acknowledge that you have read, understood, and agreed to the practices described in this Policy.

INFORMATION WE COLLECT

We may collect the following categories of information, either directly from you or automatically through your use of the Services:

Personal Identifiers :

• Full name
• Email address
• Phone number (if provided)
• Payment and billing information
• Health and Biometric Information

We collect sensitive health data relevant to your fitness and wellness, including:

• Heart rate and heart rate variability (HRV)
• Weight, height, and body composition
• Exercise logs and activity levels
• Nutrition and dietary information
• Sleep patterns

Wellness goals and progress metrics

USE OF INFORMATION :

We process your information for the following lawful purposes:

• To create and manage your account
• To personalize health coaching and fitness recommendations
• To monitor progress and provide relevant insights
• To communicate with you, including marketing communications, newsletters, and administrative updates
• To process payments and manage subscriptions
• To improve, maintain, and secure our Services
• To comply with legal obligations and enforce our Terms of Service

LEGAL BASES FOR PROCESSING (for EEA Users) :

If you are located in the European Economic Area (EEA), we rely on the following legal bases under the GDPR:

• Consent: For health-related data and marketing communications
• Contractual necessity: To provide the Services as agreed
• Legal obligation: For compliance with applicable laws
• Legitimate interests: For analytics, security, and service improvements

DISCLOSURE OF INFORMATION :

We do not sell, rent, or share your personal information with third-party advertisers. We may share your data with trusted third parties under the following conditions:

• Service Providers: Payment processors, hosting providers, customer support platforms, and analytics services who assist in delivering our Services.
• Legal Requirements: To comply with applicable law, legal process, or governmental request.
• Business Transfers: In connection with a merger, acquisition, or asset sale, subject to standard confidentiality obligations.

All third parties are contractually obligated to handle your data securely and only for the purposes specified.

DATA RETENTION :

We retain your information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required by law. You may request deletion of your account and associated data at any time, subject to applicable legal retention obligations.

YOUR RIGHTS AND CHOICES :

You may exercise the following rights, subject to applicable law:

• Access: Obtain a copy of your personal data
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request erasure of your data (“right to be forgotten”)
• Objection/Restriction: Limit or object to certain data processing
• Opt-Out: Unsubscribe from marketing communications via email or app settings

To exercise these rights, please contact us at: reborntrainingai@proton.me

DATA SECURITY :

We implement appropriate technical and organizational safeguards to protect your information, including:

• SSL/TLS encryption
• Secure cloud infrastructure
• Access control and authentication protocols
• Regular vulnerability scans and risk assessments

While we strive to protect your data, no system is 100% secure. Please use strong passwords and protect your login credentials.

CHILDREN’S PRIVACY :

Our Services are not intended for children under the age of 13 (or 16 where applicable by law). We do not knowingly collect personal data from children without verifiable parental consent. If we discover such data has been collected, we will delete it promptly.

INTERNATIONAL DATA TRANSFERS :

If you access the Services from outside the United States, you understand and agree that your data may be processed and stored in the United States, where data protection laws may differ from those in your jurisdiction.

CHANGES TO THIS PRIVACY POLICY :

We reserve the right to modify this Policy at any time. Changes will be effective immediately upon posting the updated Policy, with the updated “Effective Date.” Material changes may be communicated via email or prominent notice in the Services.

CONTACT INFORMATION :

For any privacy-related questions, requests, or complaints, please contact: REBORN TRAINING SYSTEMS, LLC Email: reborntrainingai@proton.me Location: Utah, United States