Last Updated: October 6, 2026
Factors Athletic Training Software Inc. (“Factors,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal and physiological data of our users (“you” or “Athlete”).
This Privacy Policy explains how we collect, use, process, and safeguard your information when you use the Factors mobile application, website, and associated services (collectively, the “Services”).
2. How We Use Your Information & Biometric Data
We use your data solely to deliver, maintain, and optimize the Services for track cycling athletes. Our insights are for training purposes only. They are not medical advice, and the Services are not a medical device: they do not diagnose, treat, or prevent any condition.
A. Deterministic & Algorithmic Processing
- Track Cycling-Specific Nervous System Analysis: We process your physiological metrics using proprietary, deterministic algorithms, signal-processing routines, and rule-based mathematical calculations. These calculations evaluate how your autonomic nervous system responds specifically to track cycling training loads (such as high-cadence neuromuscular efforts, maximum power sprints, and high-intensity anaerobic work).
- Personalized Baseline Monitoring: Your biometric data is evaluated dynamically relative to your own historical baselines to generate individual recovery, readiness, and strain trends.
B. Strict Prohibition on Machine Learning & Model Training
- No Artificial Intelligence / LLM Training: Factors does not feed, pool, or process data retrieved from third-party wearable APIs or integrations (including WHOOP, Garmin, Apple HealthKit, or Google Health Connect) to train, test, evaluate, benchmark, fine-tune, improve, or develop machine learning (ML), large language models (LLMs), or any other artificial intelligence system. This applies equally to anything derived from that data, including Coach Kilo questions, answers, conversation logs, and summaries that involve it, and it applies even when the data is anonymized or aggregated. We do not allow any third party, including our AI provider, to use it for these purposes.
- Runtime-Only Inputs: Wearable metrics are used only as runtime inputs for your own analysis, and, if you consent, for Coach Kilo’s answers to you and your coaches (see C). They are not added to any training dataset.
C. Coach Kilo (AI Coach): AI Transparency Statement
Coach Kilo is an AI coach that answers your training questions in the app. It is powered by Google Gemini, a large language model provided by Google, which runs under a paid Google Cloud agreement that does not permit Google to use our data to train or improve its models.
- Your consent comes first: Coach Kilo uses your device data only after you explicitly agree. We ask before its first answer, and you can change your choice at any time in Settings → Coach Kilo or by telling Kilo in the chat (for example, “stop using my data”).
- What is sent: With your consent, to answer a question, Kilo looks up the data it needs and sends it to Google Gemini with your question and the recent conversation. This can include your rides and power data, personal bests, effort traces, sleep, recovery and readiness, nutrition, and daily energy, including data from Garmin and WHOOP devices. Without your consent, Kilo answers without any device data: it uses only what you enter yourself, such as journal body stats and gym sessions.
- Your coaches: If you accept a coach, Kilo can answer your coach’s questions about your training, under the same consent you gave.
- Answers are informational: They are generated by AI, can be wrong, and are not medical advice.
- Journal notes: We also use Google Gemini to score the overall mood (positive or negative) of the notes you write in your journal, for your Vibes scorecard. Only the text of the note is sent.
3. Data Sharing & Third-Party Integrations
We do not sell, rent, or trade your personal or biometric information. We share data only under the following limited circumstances:
- Connected Service Providers: We exchange data with third-party platforms (e.g., WHOOP, Garmin, Apple HealthKit) strictly as directed and authorized by you via standard OAuth consent flows.
- Your Coaches: If you invite or accept a coach in Factors, that coach can see your training, recovery, and wearable data (including Garmin and WHOOP data) for as long as the coaching relationship lasts. You can remove a coach at any time in Settings.
- Service Providers (Processors): We use the following providers to run the Services. They process data only on our instructions and under data-protection agreements:
- Google Cloud (hosting, databases, and data processing)
- Google Gemini (Coach Kilo, and the mood score for journal notes; see Section 2.C)
- Supabase (sign-in and account authentication)
- Terra (tryterra.co) (connection to some wearable services, such as WHOOP, and to Garmin for accounts that connected Garmin before our direct connection)
- Amazon Web Services (email delivery and file storage)
- Amplitude (app usage analytics; it does not receive your wearable or biometric data)
- Apple App Store, Google Play, and Stripe (subscriptions and payments)
- Compliance & Legal Obligations: We may disclose information if required by law, subpoena, or valid legal process.
Third-Party Attributions
- Garmin: All uses of Garmin device-sourced data within Factors are provided in accordance with Garmin Connect Developer Guidelines. See Section 5 (Garmin Connect) below.
- WHOOP: Biometric outputs sourced from WHOOP hardware are retrieved via the official WHOOP API and processed in strict adherence to WHOOP API Terms of Use.
4. Data Storage, Security, and Retention
- Data Security: We implement industry-standard encryption protocols (TLS/SSL in transit, AES-256 at rest) to protect your biometric and account data from unauthorized access.
- Data Retention: We retain your physiological and workout metrics for as long as your account remains active to provide historical trends.
- Disconnecting a Wearable: When you disconnect an integration, we stop collecting data from it. The data already synced, including Garmin data, stays in your history until you delete your account or ask us to delete it (for Garmin, see Section 5).
- Deleting Your Account: When you delete your account, we delete your personal data and your Coach Kilo conversations from our active databases. We delete all of your Garmin data (see Section 5). Other wearable and workout data may be kept in anonymized form, so that it can no longer be linked to you. Database backups that still contain your personal data expire within 7 days.
5. Garmin Connect
This section applies to data we receive from Garmin, whether through our direct connection to Garmin Connect or, for accounts that connected Garmin earlier, through Terra.
- What we receive: Only the categories you share with Factors in Garmin Connect: activities (including activity files), health and wellness data (such as sleep, HRV, resting heart rate, Body Battery, stress, skin temperature, and daily activity), and, if you allow it, your history from before you connected.
- How we use it: To show it to you (and to coaches you accept) with Garmin’s attribution, and to calculate your training, recovery, and power insights. With your consent, Coach Kilo also uses it to answer you and your coaches (Section 2.C). We never sell Garmin data, and we never use it, or anything derived from it, to train, test, evaluate, or improve any AI model (Section 2.B).
- Changing permissions: If you stop sharing a category in Garmin Connect, we stop receiving it at once. Data already received stays in your history until you delete your Factors account or ask us to delete it.
- Deletion: We keep your Garmin data, including data received earlier through Terra, so that disconnecting and reconnecting does not cost you your history. We delete all of your Garmin data when you delete your Factors account, or at any time on request at admin@factorstraining.com. Disconnecting Garmin Connect in Factors, or removing Factors from your Garmin Connect account, stops us receiving any further Garmin data.
- Garmin’s own handling of your data is described in Garmin’s privacy policy at garmin.com/privacy.
6. Your Rights and Choices
- Disconnect Wearables: You may revoke Factors’ access to your WHOOP, Garmin, or Apple Health data at any time via the Settings menu in the app or directly through the third-party provider’s account permissions page.
- Coach Kilo: You may give or withdraw consent for Coach Kilo to use your device data at any time (Section 2.C).
- Account Deletion & Data Export: You can delete your account in the app (Settings), and you have the right to request a full export of your track session data or the complete deletion of your account and associated personal data by contacting us at admin@factorstraining.com.
7. Children’s Privacy
Our Services are not intended for individuals under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal or biometric information from children.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect updates to our technology or legal requirements. We will notify you of material changes via in-app notifications or email prior to the changes taking effect.
