Consumer Health Data Privacy Policy

Who this policy covers

This policy explains how Full Send Solutions, LLC ("AdaptCycling", "we", "us") handles consumer health data. It applies to residents of Washington and Nevada and to consumer health data collected in those states, under the Washington My Health My Data Act (RCW 19.373) and Nevada law (NRS 603A.400 to 603A.550).

Consumer health data we collect

• Heart-rate data recorded during your rides, and the heart-rate zones and maximum heart rate we estimate from it
• Body measurements you give us: weight, sex, and birth date (used to estimate your heart-rate zones)
• Symptoms and how you feel: morning readiness check-ins (for example, tired or sick, and the reasons you pick), post-ride feeling answers, and rest days you take for illness
• Injuries, illnesses, and physical limits you describe to us or to the coach, including limits a clinician set for you
• Inferences we derive from the data above, such as fatigue, readiness, and recovery estimates

Why we collect it and how we use it

We use consumer health data only to provide the coaching you asked for:

• To set your training zones and build and adjust your training plan
• To analyze your rides and give you coaching feedback, in the app and by email
• To adapt your plan when you are tired, sick, or injured
• To answer your questions in the coach chat
• To keep the Service working and secure, including fixing errors

We do not use consumer health data for advertising, and we do not use it to train AI models.

Where it comes from

• You, when you complete your profile, answer a check-in, or message the coach
• The ride sources you connect (Strava, Wahoo, Hammerhead, Polar, intervals.icu, or Rouvy) and ride files you upload
• Our own calculations from the data above

Consumer health data we share, and with whom

We do not sell consumer health data. We share it only in these cases, each necessary to provide the Service you requested:

• Your connected head unit: when you connect Wahoo or Hammerhead, we send your planned workouts and training zones, which can include heart-rate zones, to that account so they appear on your device.

These processors handle consumer health data only on our behalf and under contract with us:

• OpenAI (AI coaching): the data needed to write your plans, analysis, and coach replies
• Neon (database hosting) and Vercel (application hosting): all of the data above, to store it and run the Service
• Resend (email delivery): coaching emails you receive, which can mention your heart rate, fatigue, or illness
• PostHog (error monitoring): short excerpts of coach replies in error reports, which can mention health details

We have no affiliates that receive consumer health data. No other third party collects consumer health data through our Service. We do not use geofencing around any health care location.

Consent

We collect and share consumer health data only as necessary to provide the Service you requested. If we ever want to collect or share it for another purpose, we will first ask for your separate consent, and you can withdraw that consent at any time.

Your rights

• Access: confirm whether we collect, share, or sell your consumer health data, get a copy of it, and get a list of every third party and affiliate we have shared it with, with their contact details
• Review and correction: review your data and ask us to correct it. You can also edit most of it yourself in Settings.
• Deletion: ask us to delete your consumer health data. You can also delete your account yourself (Account → Delete), which deletes it immediately. We tell our processors to delete it too, and copies in backups are deleted within six months.
• Withdraw consent: withdraw any consent you gave us. You can also stop collection by disconnecting a ride source (Account → Data sources).

How to make a request

Email email… from the email address on your account, or tell us which ride source you sign in with so we can confirm it is you. We respond within 45 days. If we need more time, we will tell you why and take up to 45 more days. Requests are free, up to twice a year.

How to appeal

If we decline your request, you can appeal by replying to our decision or emailing email… with "Appeal" in the subject. We answer appeals in writing within 45 days and explain our reasons. If you disagree with the result, you can contact the Washington Attorney General or the Nevada Attorney General.

Changes to this policy

If we change this policy, we update the dates at the top of this page. For a material change, we also tell you by email or in the app before it takes effect, and we ask for your consent where the law requires it.

Contact

Email: email…