Privacy Policy

Privacy Policy Website

1. Introduction

In the following, we provide information about the collection of personal data when using

• our website https://www.c5z.tech/
• our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1 Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is lavrik.tech, Rheinstraße 24, Dreieich, Germany, email: info@lavrik.tech. We are legally represented by Dr. Vladimir Lavrik, Tina Sabrina Schlosser-Lavrik.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

• Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
• Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
• Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
• Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4 Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5 Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

• Right of access
• Right to correction or deletion
• Right to limit processing
• Right to object to the processing
• Right to data transferability
• Right to revoke a given consent at any time

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7 No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8 Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

2. Data processing on our website

2.1 Notice for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.

This storage and access is based on the following provisions:

• Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutzgesetz, "TDDDG").
• Otherwise, this storage or access takes place on the basis of the website visitor's consent (Section 25 para. 1 TDDDG).

The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

2.2 Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status/HTTP status code
• Amount of data transferred in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

2.3 Web hosting and provision of the website

Our website is hosted by Heroku Felix. The provider is salesforce.com Germany GmbH, Erika-Mann-Straße 31-37, 80636 Munich. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://www.salesforce.com/de/company/privacy/.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

We use the content delivery network Bootstrap CDN for our website. The provider is Volentio JSD Limited, Suite 2a1, Northside House, Mount Pleasant, Barnet, United Kingdom. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in Great Britain. Further information can be found in the provider's privacy policy at https://www.jsdelivr.com/terms/privacy-policy.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.

2.4 Offer of services

We offer services via our website. In doing so, we process the following data as part of the ordering process:

• email

The processing of the data is carried out for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 s. 1 lit. b GDPR).

2.5 Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

• Stripe Payments Europe, Ltd., Ireland

2.6 Third parties

2.6.1 heyData

We have integrated a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data privacy compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative as confirmation.

As the data is masked after collection, there is no possibility to identify website visitors. Further information is available in the privacy policy of the provider at https://heydata.eu/en/privacy-policy.

3. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

4. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

Privacy Policy Mobile App

Health

We access, collect, and use Health. We access, collect, and use Health Data. This privacy policy explains how we access, collect, and use this data.

Health (also called Health Data and Health info) is accessed and collected by the LAVRIQ Android app from Google Health Connect only after the user turns on Health Connect in Profile → Integrations and grants permission. We do not access or collect Health in the background.

We access, collect, and use Health for the user's own Insights in the app. The Health we access, collect, and use is: Sleep, Heart rate, Respiratory rate, Blood pressure, and Health data history. Health is stored on the user's LAVRIQ account and on the LAVRIQ backend that serves that account. We do not use Health for advertising. We do not sell Health. Except for the LAVRIQ backend that stores the user's account, we share Health with a third party only if the user turns on AI coaching, in which case recovery data such as heart-rate variability and sleep is sent to our AI provider (OpenAI) to generate the requested insights, as described in section 2.9.4. AI coaching is off by default and can be turned off at any time in Profile.

How we access, collect, and use each type of Health is described in section 2.10 Health Data below.

1. Introduction

In the following, we provide information about the collection of personal data when using our mobile app (hereinafter only "App").

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1 Contact details

The controller within the meaning of Art. 4 (7) EU General Data Protection Regulation (GDPR) is lavrik.tech, Rheinstraße 24, Dreieich, Germany, email: info@lavrik.tech. We are legally represented by Dr. Vladimir Lavrik, Tina Sabrina Schlosser-Lavrik.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

• Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
• Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a user purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
• Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
• Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4 Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5 Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

• Right of access
• Right to correction or deletion
• Right to limit processing
• Right to object to the processing
• Right to data transferability
• Right to revoke a given consent at any time

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7 No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8 Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

2. Data processing in the app

2.1 Downloading the app

Our app is ready for download at Google's Play Store (hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.

2.2 Hosting

Our app is hosted by playstore. The provider thereby processes the personal data transmitted via the app, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide an app, so that the legal basis of the data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

2.3 Informative use of our app

When users use our app, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

The data processed to this extent are:

• IP address
• Date and time of the request
• Time zone difference from Greenwich Mean Time (GMT)
• Content of the request (concrete interface)
• Access status/HTTP status code
• Amount of data transferred in each case
• Operating system and its interface
• Language and version of the operating system

2.4 Access to functions or data

The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation.

The data processed or access functions used in this respect are storage, sensors, location.

2.5 Data processing for the provision of functions

In the app, we process data in order to provide the user with functions of the app. The legal basis for the processing is the usage agreement concluded with the user via the app.

The data processed to this extent are: data entered by the user themselves into the app and, if the user opts in, health data read from Google Health Connect as described in section 2.10 as well as data from other connected services the user opts into (for example via Profile → Integrations).

2.6 User account

Users can open a user account in the app. We process the data requested in this context to fulfill the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR. We delete the data when users delete their user account.

2.7 Purchase of products or services

We offer to purchase goods or services via our app. In the ordering process or shipping, we involve the following service providers, who receive only the personal data required in each case to provide a service. The processing of the data takes place for the performance of the contract concluded with the respective user (Art. 6 para. 1 s. 1 lit. b GDPR).

2.8 Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

• Stripe Payments Europe, Ltd., Ireland

2.9 Third-party tools

2.9.1 Stripe

We use Stripe for payments. The provider is Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland. The provider processes payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail addresses, telephone numbers) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR. The processing is necessary for the performance of a contract to which the data subject is a party, or as it is necessary for the performance of pre-contractual measures that are carried out at the request of the data subject.

The legal basis for the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://stripe.com/en-gb-de/privacy.

2.9.2 heyData

We have integrated a data protection seal. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data privacy compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative as confirmation.

As the data is masked after collection, there is no possibility to identify website visitors. Further information is available in the privacy policy of the provider at https://heydata.eu/en/privacy-policy.

2.9.3 Google Health Connect

We use Google Health Connect on Android to read and, where the user has granted a write permission, write selected health and fitness data. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and Google LLC, USA.

Health Connect is an on-device Android platform. After the user turns on Health Connect in Profile → Integrations and grants the relevant permissions, the app uses Health Connect APIs on the device. Google's processing of data in Health Connect is governed by Google's privacy policy.

The types of Health Data we access, how we use them, and with whom they are shared are described in section 2.10.

Further information is available in the provider's privacy policy at https://policies.google.com/privacy.

2.9.4 OpenAI (AI coaching)

We offer optional AI coaching features (training-plan generation, activity insights, a coach story, progress narratives, and a coach chat). When the user turns AI coaching on, the LAVRIQ backend sends the data needed for the requested feature to our AI provider to generate the response. The provider is OpenAI, Inc. and OpenAI Ireland Ltd. ("OpenAI"), which processes the data in the USA.

The app never contacts OpenAI directly; only the LAVRIQ backend does, on behalf of the user's account. Depending on the feature used, the data sent may include: the user's training goal, profile details (such as first name, age, sex, height, and weight), workouts and performance metrics (such as heart rate, power, pace, zones, and FTP), recovery data including heart-rate variability (HRV) and sleep, stated injuries, and the messages the user types into the coach chat.

The legal basis for this processing is the user's explicit consent (Art. 6 para. 1 s. 1 lit. a GDPR, and Art. 9 para. 2 lit. a GDPR for health and recovery data). Consent is off by default: no data is sent to OpenAI until the user enables AI coaching, either during onboarding or in Profile. The user can withdraw consent at any time by turning AI coaching off in Profile; withdrawal does not affect the lawfulness of processing before withdrawal, and it stops any further sharing with OpenAI. Declining or withdrawing consent leaves all other features of the app (recording, sensors, Strava, Health Connect, and so on) fully working.

The legal basis for the transfer to the USA are standard contractual clauses (Art. 46 para. 2 lit. c GDPR), supplemented by a data processing agreement (DPA) with OpenAI. Under that agreement, data submitted via the OpenAI API is not used to train OpenAI's models and is retained only for a limited period for abuse monitoring before deletion.

Further information is available in the provider's privacy policy at https://openai.com/policies/privacy-policy and its API data usage policies at https://openai.com/policies/api-data-usage-policies.

2.10 Health Data

We access, collect, and use Health. We access, collect, and use Health Data from Google Health Connect on Android only after the user turns on Health Connect in Profile → Integrations and grants the corresponding Health Connect permissions. We do not read Health Connect data in the background. When the app comes to the foreground (or at login), we load recent records as described below.

This Health / Health Data is special-category personal data. The legal basis is the user's explicit consent (Art. 6 para. 1 s. 1 lit. a GDPR and Art. 9 para. 2 lit. a GDPR). The user can withdraw consent at any time by disconnecting Health Connect in the app or by revoking Health Connect permissions in the device settings. Withdrawal does not affect the lawfulness of processing until withdrawal. Deleting the LAVRIQ account deletes Health stored on that account as described elsewhere in this privacy policy.

Health

We access, collect, and use Health from Google Health Connect as listed in this section. Health is stored on the user's LAVRIQ account and shown in Insights.

Sleep

We read sleep sessions (SleepSessionRecord), including stages when present. We group those sessions into nights. That night is stored on the user's LAVRIQ account and shown in Insights → Sleep as sleep history: duration, stages, score, quality, and efficiency. We do not write sleep back to Health Connect and do not diagnose sleep disorders.

Heart rate

We do not read heart rate in the background or as a live monitor. After loading recent sleep sessions, we read HeartRateRecord samples only between that night's start and end. We keep average, minimum, and maximum beats per minute for that session (we drop missing or non-positive values). Those figures are stored on the user's LAVRIQ account with the rest of the night and shown in Insights → Sleep as overnight average heart rate. We do not use this read permission for workouts. Workout heart rate may be written to Health Connect with a separate write permission after the user saves a session. We do not write overnight heart rate back to Health Connect and do not diagnose medical conditions.

Respiratory rate

We read RespiratoryRateRecord samples only between that night's start and end. We keep average, minimum, and maximum breaths per minute for that session (we drop missing or non-positive values). Those figures are stored on the user's LAVRIQ account with the rest of the night and shown in Insights → Sleep so the user can review overnight breathing rate next to their sleep. We do not write respiratory rate back to Health Connect.

Blood pressure

We load recent BloodPressureRecord data from the last 30 days. For each reading we keep the timestamp and systolic and diastolic values in mmHg. Those readings are stored on the user's LAVRIQ account and shown in Insights → Blood pressure as a history list and chart so the user can review their own measurements. We do not write blood pressure back to Health Connect and do not diagnose or treat medical conditions.

Health data history

Without history access, Health Connect only returns records from about 30 days before the user granted access. We use history access so Insights can include sleep nights and blood pressure readings the user already has in Health Connect from before they connected LAVRIQ. We still only load recent data: the latest sleep nights (stages, duration, overnight heart rate and respiratory rate) and recent blood pressure readings. We do not use history access to import workouts.

Use, storage and sharing of Health

Health / Health Data from Health Connect is stored on the user's LAVRIQ account and on the LAVRIQ backend that serves that account, so the user can review it in Insights. We do not use this Health for advertising. We do not use it for analytics beyond the user's own history in the app. We do not sell Health. Except for the LAVRIQ backend that stores the user's account, we share this Health with a third party only if the user turns on AI coaching, in which case recovery data such as heart-rate variability and sleep is sent to our AI provider (OpenAI) to generate the requested insights, as described in section 2.9.4. AI coaching is off by default and can be withdrawn at any time in Profile.

3. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

4. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.