Privacy Policy

Effective date: [Effective date]

1. Who we are

Orbit is a personal health and productivity app that turns your Garmin data, journal and habits into daily Recovery, Strain and Sleep scores, with an AI coach. This policy explains what personal data Orbit collects, why, and the rights you have over it.

Data controller: [Controller name], NIF [NIF/CIF], [Address], Spain. Contact: [Contact email].

This policy applies to the Orbit mobile app, the Orbit website and any related services (together, "Orbit"). It complies with the EU General Data Protection Regulation (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

2. What we collect and why

We only collect what Orbit needs to work. Data marked "health" is special-category data, which we process only with your explicit consent.

WhatWhy we use itLegal basisHow long we keep it
Account data: name, email, Google account ID, profile picture (you sign in with Google, so Orbit has no password to store)To create and run your accountPerformance of our contract with youWhile your account exists, then deleted within 30 days
Garmin data (health): heart rate, heart-rate variability, sleep stages, activitiesTo calculate your Recovery, Strain and Sleep scores and trendsYour explicit consentWhile your account exists or until you disconnect Garmin
Training data (health): workouts, personal records, muscle recoveryTo run the Training and Body featuresYour explicit consentWhile your account exists
Nutrition data (health): meals, food logs, diet plansTo run the Meals featureYour explicit consentWhile your account exists
Journal data (health): daily answers, mood, energy, notesTo show which habits and behaviours affect your next-day RecoveryYour explicit consentWhile your account exists
Habits and streaksTo run the Habits featurePerformance of our contract with youWhile your account exists
Coach conversations (health)To answer your questions using your own dataYour explicit consentNot stored: each message is used only to generate its answer, then discarded. We keep usage metadata (such as token counts, without the text) for 90 days
Preferences: units, coach tone, home ringsTo personalise the appPerformance of our contract with youWhile your account exists
Technical data: IP address, device type, app version, error logsTo keep Orbit secure and fix bugsOur legitimate interest in a secure, working serviceUp to 90 days
Website cookies (only if you accept)To understand how the website is usedYour consentSee our Cookie Policy (the website currently sets no such cookies)
[Billing data, if applicable]: name, billing address, transaction records (card details are handled only by our payment provider)To charge for paid plans and meet tax dutiesContract and legal obligation6 years, as required by Spanish law

Your journal notes and Coach messages are free text. Please avoid entering information about other people or sensitive details you don't want stored.

We do not sell your data, use it for advertising, or share it with data brokers.

3. Health data, the AI Coach and Garmin

Your consent. We ask for your explicit consent to process health data when you sign up, and again before you first use the Coach. You can withdraw either consent at any time in Settings. Withdrawing does not affect processing that already happened, but the features that depend on that data will stop working.

The AI Coach. The Coach is an artificial intelligence, not a person, and not a doctor. When you send a message, Orbit sends your message and the relevant parts of your data (scores, training, meals, habits, journal) to our AI provider, DeepInfra, to generate an answer. We send only what is needed for that answer. Our provider is contractually bound to process this data only on our behalf and not to use it to train its models.

Automated analysis. Orbit calculates scores and finds patterns in your data automatically. These results are suggestions for your own wellbeing. They do not produce legal effects or similarly significant decisions about you, and you are always free to ignore them.

Not medical advice. Orbit is a wellness tool, not a medical device. It does not diagnose, treat or prevent any disease. Talk to a healthcare professional about any health concern.

Garmin. When you connect Garmin, you authorise Garmin to send Orbit the data listed in section 2. Garmin processes your data under its own privacy policy. You can disconnect Garmin in Orbit's Settings or in your Garmin account; when you do, we stop receiving new data and delete the Garmin data we hold within [30 days].

4. Who we share data with

We share your data only with service providers who help us run Orbit ("processors"). Each one has signed a data processing agreement with us and may use your data only to provide its service to us.

Orbit's servers and database are self-hosted on hardware we operate in [EU region]; no hosting company has access to them.

ProviderWhat it doesWhere data is processedSafeguard
CloudflareCarries encrypted traffic between the app or website and our servers (Cloudflare Tunnel)[Country]Data processing agreement [+ transfer safeguard]
DeepInfraGenerates Coach answersUnited StatesData processing agreement [+ Standard Contractual Clauses / EU-US Data Privacy Framework]
Junction (Vital)Connects your Garmin account and relays its data to OrbitEUData processing agreement [+ transfer safeguard]
[Email provider]Sends account emails[Country]Data processing agreement [+ transfer safeguard]
[Push notification provider]Sends app notifications[Country]Data processing agreement [+ transfer safeguard]
[Payment provider, if applicable]Processes payments[Country]Data processing agreement [+ transfer safeguard]

Google verifies your identity when you sign in; it is not our processor for your Orbit data. Garmin is not our processor either; it is a separate company that sends us data at your request.

We may also disclose data where Spanish or EU law requires it, for example to courts or public authorities.

International transfers. When a provider processes data outside the European Economic Area, we protect it with an EU adequacy decision (such as the EU-US Data Privacy Framework) or the European Commission's Standard Contractual Clauses. You can ask us for a copy of these safeguards.

5. Your rights

You have the right to:

  • Access your data and get a copy of it.
  • Rectify data that is wrong or incomplete.
  • Erase your data ("right to be forgotten").
  • Restrict how we use your data in certain cases.
  • Object to processing based on our legitimate interests.
  • Portability: receive your data in a machine-readable format (JSON or CSV) or have it sent to another service.
  • Withdraw consent at any time, without affecting earlier processing.

Most of this you can do yourself in Settings: export your data, withdraw consents, disconnect Garmin or delete your account. For anything else, email [Contact email]. We reply within one month, and may ask you to confirm your identity.

If you think we have not handled your data properly, you can complain to the Spanish Data Protection Agency (AEPD) at www.aepd.es, or to the authority in your EU country. We'd appreciate the chance to fix it first.

6. Security

We encrypt data in transit (TLS) and at rest. Orbit has no passwords (you sign in with Google), and the session tokens that keep you signed in are stored only as secure hashes. We limit access to production data to authorised people using multi-factor authentication, and keep access logs. If a data breach is likely to put your rights at risk, we will notify the AEPD within 72 hours and tell you without undue delay.

7. Age limit

Orbit is only for people aged 18 or over. We do not knowingly collect data from anyone younger. If we learn that we have, we will delete it.

8. Cookies

The Orbit website uses only essential cookies unless you accept others in our cookie banner. The app does not use advertising trackers. Details are in our Cookie Policy (itsorbit.app/cookies).

9. Deleting your account

When you delete your account, we delete your personal data within 30 days. Copies in encrypted backups are overwritten within [35 days]. We keep billing records for 6 years only where Spanish tax law requires it.

10. Changes to this policy

We will tell you in the app and by email before any significant change takes effect. If a change needs new consent, we will ask for it.

11. Contact

[Controller name] · [Address] · [Contact email]

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