1 — Data controller
[LEGAL ENTITY NAME], registered under SIRET [NUMBER], with its registered office at [ADDRESS], Paris, France, is the data controller within the meaning of Article 4(7) of the RGPD.
Data Protection Officer (DPO) / Privacy contact: privacy@fuelnode.fr
2 — Data we collect
2.1 Data provided directly by the User
- Account data: name, email address, password (hashed), language preference
- Physical data: age, weight, height, sex
- Training data: sport, experience level, weekly training hours, training days, session distance, training location, training phase, goal event, target finish time
- Dietary data: GI sensitivity, GI triggers, caffeine tolerance, dietary restrictions, format preferences, sweet/savory preference, current fueling practices, cuisine inspiration
- Delivery data: address or point relais preference, delivery day
- Payment data: processed and stored exclusively by Stripe; Fuelnode does not store credit card numbers
- Free-text inputs: worst fueling experience, product feedback, race reports
2.2 Data collected automatically
- Device and usage data: device type, operating system, app version, session duration, screens visited, feature usage patterns
- Location data: approximate location (arrondissement or city) for delivery routing and weather-based protocol adjustments; precise GPS coordinates are not collected unless explicitly consented to
2.3 Data from connected services (with explicit consent)
- Apple Health / HealthKit: heart rate, HRV, resting heart rate, sleep data, step count, workout data
- Garmin Connect: training load, VO2max estimate, heart rate zones, workout history, sleep data
Connected service data is accessed only after the User explicitly enables the integration in the App's settings. The User may disconnect at any time.
2.4 Data generated by the service
- AI-generated protocols: fueling protocols, macro targets, product selections, protocol versions, fueling scores
- Feedback data: product ratings, GI feedback, race feedback, protocol satisfaction scores
3 — Purposes and legal bases
- Contract performance (Article 6(1)(b) RGPD): generating personalized protocols, curating box contents, processing orders, managing subscriptions, delivering products, processing payments, providing customer support
- Legitimate interest (Article 6(1)(f) RGPD): improving algorithms and product recommendations, analysing aggregate usage patterns, preventing fraud, ensuring service security, sending service-related communications
- Consent (Article 6(1)(a) RGPD): accessing HealthKit/Garmin data, sending marketing communications, processing location data beyond delivery purposes, sharing anonymised product satisfaction data with brand partners
4 — Data sharing
4.1 Service providers (data processors)
- Supabase Inc. (USA) — Database hosting & authentication — SCCs in place
- Anthropic Inc. (USA) — AI protocol & content generation (Claude API) — SCCs in place; data pseudonymised; not retained beyond API call
- Stripe Inc. (USA) — Payment processing — PCI-DSS Level 1; SCCs in place
- Mondial Relay (France) — Delivery logistics — name, address & package reference only
- Vercel / Lovable — App hosting infrastructure
- api-adresse.data.gouv.fr (French Government API) — Weather geocoding — postcode or commune name; no profile data shared; public data source
4.2 Brand partners — Fuelnode may share anonymised, aggregated product satisfaction data with sports nutrition brand partners (e.g., product ratings by athlete segment). This data is never individually identifiable and is shared only with the User's prior consent obtained via an in-app opt-in. The User may withdraw this consent at any time.
4.3 No sale of personal data — Fuelnode does not sell, rent, or trade personal data to third parties for their own marketing purposes.
5 — International data transfers
Certain service providers are located in the United States (Supabase, Anthropic, Stripe). All transfers to countries outside the European Economic Area are secured by Standard Contractual Clauses (SCCs) adopted by the European Commission, in compliance with Articles 46(2)(c) of the RGPD. Copies of the applicable SCCs are available upon request.
6 — Data retention
- Account data — Duration of account + 3 years after deletion
- Protocol history — Duration of subscription; deleted within 30 days of account deletion
- Payment records — 10 years (Code de commerce, Article L123-22)
- Usage analytics — Anonymised after 26 months
- HealthKit / Garmin data — Not stored permanently; used in real-time and discarded after processing
- Marketing consent records — 3 years from last interaction (CNIL recommendation)
7 — Your rights
Under the RGPD and French data protection law, the User has the following rights:
- Right of access (Article 15 RGPD): obtain a copy of all personal data held
- Right of rectification (Article 16): correct inaccurate data
- Right of erasure (Article 17): request deletion of personal data ("right to be forgotten")
- Right to restriction (Article 18): restrict processing in certain circumstances
- Right to data portability (Article 20): receive personal data in a structured, machine-readable format (JSON or CSV)
- Right to object (Article 21): object to processing based on legitimate interest, including profiling
- Right to withdraw consent: withdraw consent at any time for processing based on consent, without affecting the lawfulness of prior processing
To exercise any of these rights, contact privacy@fuelnode.fr or use the in-app data management tools in Settings > My Data. Fuelnode will respond within 30 days. If unsatisfied, the User may lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL): www.cnil.fr.
8 — Data security
Fuelnode implements appropriate technical and organisational measures to protect personal data, including:
- Encryption in transit (TLS 1.2+) and at rest (AES-256)
- Hashed passwords (bcrypt via Supabase Auth)
- Role-based access control to production databases
- Regular security reviews and dependency updates
- No storage of raw credit card data (Stripe handles all payment data)
- Pseudonymisation of athlete data sent to the AI engine (user_id only, no name or email)
9 — Cookies
The Site uses only strictly necessary cookies for authentication, session management, and language preferences. No advertising or tracking cookies are used. Analytics, if implemented, use privacy-respecting, cookieless tools (e.g., Plausible Analytics) or require prior consent.
10 — Children
Fuelnode is intended for adults aged 18 and over. We do not knowingly collect personal data from children under 18. If we become aware that data has been collected from a minor, we will delete it promptly.
11 — App store data safety declarations
11.1 Apple App Store privacy nutrition labels
- Health & Fitness — Exercise data, body measurements (linked to identity, used for app functionality)
- Location — Coarse location (linked to identity, used for delivery and weather-based protocol adjustments)
- Contact Info — Name, email (linked to identity, used for app functionality and customer support)
- Identifiers — User ID (linked to identity, used for app functionality)
- Usage Data — Product interaction, feature usage (linked to identity, used for analytics and product improvement)
- Purchases — Purchase history (linked to identity, used for app functionality)
- Data not collected — Precise location, financial info (handled by Stripe), contacts, browsing history, search history, sensitive info, photos/videos
11.2 Google Play data safety section
- Data shared with third parties: anonymised usage analytics only (not sold)
- Data collected: name, email, address, health info (exercise, body measurements), app activity, device info
- Security practices: data encrypted in transit; data can be deleted by user request
- Data deletion: users can request account and data deletion via the App or by emailing privacy@fuelnode.fr; deletion is completed within 30 days
12 — Changes to this policy
Fuelnode may update this Privacy Policy from time to time. Material changes will be communicated via email and/or in-app notification at least 15 days before taking effect. The current version is always available at fuelnode.fr/privacy and within the App.