This is a courtesy translation. If the two versions differ, the Spanish one prevails.
1. Data controller
- Trade name: 2trAIn 4trAIners (2T4T)
- Company name: LMGINC SL
- Tax ID (NIF): B93905438
- Registered office: Calle Lagasca 95, 28006 Madrid (Spain)
- Registration: Madrid Companies Register, Section 8, Sheet M-895517, 1st Entry
- Email: contact@2trainapp.com
2. Why we process your data
We process the data you give us in the access request form (name, email, number of clients, how you coach and, if you write one, your message) to:
- Handle your request for access to 2T4T and get in touch to set you up.
- Learn how you found us (for example, the campaign or website you came from), so we know what works. See section 2a.
- Send you marketing emails about 2trAIn 4trAIners, only if you consent to it.
We don’t use this data for anything else.
2a. Where your request came from
Along with your request we store where you came from: the campaign parameters in the URL (utm_source, utm_medium, utm_campaign, utm_term and utm_content), ad click IDs (Google’s gclid and Meta’s fbclid), the page you landed on, the referring website and the page you sent the form from. We don’t use any third-party analytics or advertising tools on this website. If you accept cookies, your browser remembers that origin for 90 days; if not, it only applies to that visit. To prevent abuse we also store an encrypted, irreversible fingerprint of your IP address, never the IP address itself.
3. Legal basis
The legal basis is your explicit consent (Art. 6.1.a GDPR), which you give by ticking the box accepting this policy before sending the access request form. You can withdraw it at any time, without affecting the lawfulness of earlier processing, by writing to contact@2trainapp.com.
4. Recipients and processors
We don’t share your data with third parties unless the law requires it. The hosting and infrastructure providers of this website and of the 2T4T app can access it as processors (Art. 28 GDPR), under contracts that ensure GDPR compliance: Vercel Inc. (website), Google Cloud Platform (Cloud Run and database in the EU region in Belgium, where requests are stored) and Resend (email delivery).
5. How long we keep it
Access request data is kept while the sales process lasts and, if you don’t become a customer, for 1 year after our last contact, after which it is deleted or anonymized. If you become a customer, your data is kept for as long as the contract lasts and then for the applicable legal limitation periods.
6. Your rights
You can exercise your rights of access, rectification, erasure, objection, portability and restriction of processing, and withdraw your consent, at any time by writing to contact@2trainapp.com. You also have the right to file a complaint with the Spanish Data Protection Agency (aepd.es) if you believe your data isn’t being handled lawfully.
7. Your clients’ health data: who is responsible for what
In the 2T4T app, each trainer records health data about their own clients (for example, injuries), a special category of data under Article 9 GDPR. Responsibilities are split as follows:
- Each trainer is the controller of their own clients’ health data: they decide what data to collect and why (to plan training safely) and obtain each client’s explicit consent.
- LMGINC SL acts as the processor (Art. 28 GDPR) for that data: it provides the technical service, the app, following the trainer’s instructions and never uses the data for its own purposes.
- The app enforces technical isolation per trainer account: one trainer’s client health data is not accessible to any other trainer on the platform, and this is checked on every endpoint.
- To provide the service, LMGINC SL uses these sub-processors: Google Cloud (servers and database in Belgium), Resend (email), Anthropic PBC (US, artificial intelligence: currently, importing plans and training history from PDF, image or CSV files), Cloudflare (delivery of exercise videos), MapTiler (maps for cardio routes) and, only if the client accepts it in the app, Microsoft (Clarity, app usage analytics). Those outside the European Economic Area are covered by standard contractual clauses. The details are in the app privacy policy.
So the person responsible for each client’s health data is their personal trainer. LMGINC SL processes it only on the trainer’s behalf and following their instructions, under the data processing agreement (Art. 28 GDPR) that is part of the terms of service for trainers. If you are a trainer’s client and want to exercise your rights over that data, contact your trainer; you can also write to contact@2trainapp.com and we’ll pass your request on.
8. Security
We apply reasonable technical and organizational measures to protect personal data against unauthorized access, loss or alteration, including the per-trainer isolation described above.
9. Changes to this policy
We may update this policy to reflect changes in the law or the product. The current version is always the one published on this page, with its date.