Privacy Policy

Last updated: 14 October 2026.

This Privacy Policy explains how we collect, use, and protect your personal data when you visit our website (swimtraxx.com), make a purchase from our online store, or use the Swimtraxx Hub application (the “App”).

1. Who we are

The data controller responsible for your personal data is Smient vzw. For any question about this Privacy Policy, or to exercise your data-protection rights, please contact us through our contact page.

2. What data we collect

2.1 Website and online store

When you visit our website or place an order, we may collect:

Order and billing data — name, billing and shipping address, email, phone number, VAT number (if provided), order contents, order history, and notes you add to your order
Payment data — handled directly by our payment processor. We do not store your full card details; we only receive a transaction reference
Shipping data — we share your delivery address with our shipping carrier to fulfil your order
Technical data — IP address, browser type, device type, referring URL, and pages visited, collected automatically via server logs and analytics
Cookies — see Section 7 below

2.2 Swimtraxx Hub App

When you use our App, we may collect:

Account data — email address, display name, authentication credentials (managed via supported third-party sign-in providers or email and password), and account timestamps
Swim session data — heart rate, lap times, distance, duration, stroke type and rate, stroke count, stroke length, breath count, turn time, and underwater time recorded from your Swimtraxx device
Wellness data — subjective ratings of perceived exertion and responses to wellness and injury questionnaires you choose to complete
Team data — training group membership, workout plans, season plans, and coaching relationships (if you use the App in a team context)
Diagnostics — crash reports and performance metrics collected via a crash-reporting service

2.3 My Recovery (health data)

My Recovery is an optional part of Swimtraxx Hub. It is off until you turn it on. It helps you see how you recover by putting a short morning check-in and a weekly health check next to your training load. It does not diagnose, treat or give advice about any medical condition and it is not medical advice.

What we collect, only if you turn it on

Your morning check-in: sleep quality, fatigue, stress, muscle soreness and mood, each on a scale of 1 to 7.
The bedtime and wake-up time you enter, and the hours slept we work out from them.
If you connect sleep data in My Recovery settings: your bedtime, wake-up time and time asleep, read only from Apple Health or Health Connect. We never write anything to them, and reading stops when you stop it in My Recovery settings or take away access in that app.
Your weekly health check: whether a health problem affected your training, what kind of problem it is (injury, illness or other), the body area, and a short note of up to 40 characters if you choose to write one.
Health problems you report yourself.
Your choice of who sees My Recovery, and a short log of when you turned it on or off or deleted your data, with the version of this policy you accepted.

We do not collect your location, photos, or any free-text diary through My Recovery.

Why we use it, and our legal basis

We use this data to show you how you recover and, only if you choose to share, to let your coaches see it. Your answers are health data, a special category of personal data. We process them only on the basis of your explicit consent (Article 9(2)(a) GDPR), which you give when you choose who sees it and turn My Recovery on. Consent is optional: Swimtraxx Hub works without My Recovery.

If you are under 16, please ask a parent or guardian to read this with you and to turn My Recovery on together.

Who can see it

Only you, unless you choose to share. You make that choice when you turn My Recovery on, and you can change it for each team at any time in My Recovery settings.
Shared: the owner, coaches and assistant coaches of that team can see your answers, your sleep times and your status.
Hidden: they see nothing, not even that you use My Recovery.
Hidden applies to the coaches of that team; a coach who also coaches a team you share with still sees your recovery.
Other swimmers cannot see it. Swimtraxx support staff do not have access to it. We never use it for advertising and never share it with third parties.
When you leave a team, its coaches lose access at once.

Your control

Turn off My Recovery in My Recovery settings. Coaches lose access immediately and reminders stop. Your data is kept until you delete it, so you can turn it on again.
Delete my recovery data in My Recovery settings. This permanently deletes your check-ins, sleep times, weekly health checks and reported problems. We keep only the short consent log (when you accepted, withdrew or deleted) until you delete your account, so that we can show what you agreed to.
Deleting your account removes all of it, within 30 days.
You can also use the rights listed in this policy: access, rectification, erasure, portability, restriction, objection and withdrawing consent. Contact privacy@swimtraxx.com.

How it is kept safe

Your My Recovery data is stored with our cloud provider with the same protection as the rest of your Swimtraxx Hub data, encrypted in transit and at rest. It is stored in Google Cloud in the European Union. Access is enforced by security rules: a coach can read it only for a swimmer who shares with a team that coach works with. The reminders you get are notifications created on your device. Your answers are never placed in a notification, a log or analytics.

How long we keep it

Until you delete it with Delete my recovery data or delete your account.

Changes

If we change how My Recovery uses your data, we will ask for your consent again before the change applies to you.

3. Why we use your data

We process your personal data for the following purposes, on the legal bases shown:

Processing your order and delivering your purchase — contract performance (Art. 6(1)(b) GDPR)
Issuing invoices and keeping accounting records — legal obligation under Belgian VAT and accounting law (Art. 6(1)(c) GDPR)
Providing the Swimtraxx Hub App functionality — contract performance (Art. 6(1)(b) GDPR)
Responding to support and contact requests — legitimate interest in providing customer service (Art. 6(1)(f) GDPR)
Improving our website and App — legitimate interest in diagnostics and aggregate analytics (Art. 6(1)(f) GDPR)
Sending service notices (order updates, account notifications) — contract performance
Optional third-party integrations you choose to enable — your explicit consent (Art. 6(1)(a) GDPR), which you may withdraw at any time

Emails from us

If you have a Swimtraxx Hub account, we may email you about the product itself: new features, changes that affect how you use the app, and occasional tips to get more out of it. If you have not used the app for a while, we may also send you a short reminder of what has changed since your last visit. We send these on the basis of our legitimate interest in supporting the people who use our app. Every such email has an unsubscribe link, and unsubscribing never affects your account. Receipts, security and account notices are part of the service and are sent regardless.

We do not sell your personal data, and we do not use your data for third-party advertising.

4. Who has access to your data

We share your data only where necessary, with the following categories of recipients:

Our processors, acting on our behalf under data-processing agreements: authentication and cloud-infrastructure providers (for the App), a payment processor, a shipping carrier, a transactional email provider, and an aggregate-analytics provider
Optional third-party services you choose to connect — only when you explicitly link your account
Authorities, where required by law (for example, in response to a valid court order or tax investigation)

5. International transfers

Some of our processors operate data centres or process data outside the European Economic Area, including in the United States. Where this is the case, transfers are governed by the EU–US Data Privacy Framework or by Standard Contractual Clauses approved by the European Commission, which provide an appropriate level of protection for your data. You can request information about the applicable safeguards through our contact page.

6. How long we keep your data

Order and invoice data — retained for 10 years, as required by Belgian VAT and accounting law
Account and profile data (App) — retained until you delete your account
Swim session and health data (App) — retained until you delete your account
My Recovery data: until you delete it or delete your account
Support and contact correspondence — retained for up to 3 years after your last interaction with us
Server logs — retained for up to 12 months
Diagnostic data — retained for up to 90 days

Invoice and order data that we are legally required to retain cannot be deleted on request during the statutory retention period. In such cases, we will restrict processing of that data to the legal obligation only and will not use it for any other purpose.

7. Cookies

Our website uses cookies and similar technologies to operate correctly and to measure how visitors use the site. We use:

Strictly necessary cookies — required for the shop, checkout, and cart to function (for example, session cookies and security tokens). These cannot be disabled without breaking basic site functionality.
Analytics cookies — used by a third-party analytics service to understand site usage in aggregate form and improve the website. No personally identifying profile of you is built.

You can control or block cookies through your browser settings. Blocking strictly necessary cookies may prevent the online store from working correctly.

8. Your rights

Under the General Data Protection Regulation (GDPR) and Belgian data-protection law, you have the right to:

Access the personal data we hold about you
Request correction of inaccurate data
Request deletion of your data, subject to our legal retention obligations (see Section 6)
Request restriction of processing
Request data portability for data you have provided to us
Object to processing carried out on the basis of our legitimate interest
Withdraw consent at any time, for processing that is based on your consent

To exercise any of these rights, please contact us through our contact page. We will respond within one month of receiving your request, as required by Art. 12(3) GDPR. My Recovery asks for a parent’s help under 16.

If you believe we are not handling your personal data correctly, you have the right to lodge a complaint with the competent data-protection supervisory authority. For Belgium, this is the Gegevensbeschermingsautoriteit / Autorité de protection des données (Drukpersstraat 35, 1000 Brussels — dataprotectionauthority.be).

9. Children

Our website, online store, and Swimtraxx Hub App are not directed at children under 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe we have collected data from your child, please contact us through our contact page and we will delete it. My Recovery asks for a parent’s help under 16.

10. Changes to this Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page will reflect the most recent version. Material changes will be communicated through our website or, for App users, through the App.

Change history: 14 October 2026, added the My Recovery (health data) section.