Privacy Policy

Swetro Inc. — Effective April 2026

1. Scope

This Privacy Policy applies to all personal data collected through the Swetro platform, including the website at https://swetro.com, the Swetro mobile application and any related services (collectively, the “Platform”). It does not apply to information collected offline or through channels other than the Platform.

2. Consent

By creating an account or using the Platform, you accept this Privacy Policy and consent to the collection, processing and use of your data as described here. Where required by applicable law, we will request your explicit consent before processing certain categories of data, including health and physical activity data.

3. Information we collect

3.1. Account and registration data

When you register, we collect:

• Full name and username
• Email address and, optionally, phone number and social media handles
• Race goal (10K, half marathon or marathon), event date, event city and current level of preparation
• Payment and billing information (processed by our payment provider; Swetro does not store full card details)

3.2. Physical activity data

The core of Swetro’s service is the analysis of your physical activity. We collect:

• Activity data imported automatically from connected devices and applications (Garmin, Apple Health, Coros, Polar, IGPSport, Wahoo, Suunto and others you authorize)
• Manually uploaded activities
• Derived metrics generated by our analysis system (SWAY), such as training load, effort density, cardiac efficiency, recovery indicators and injury risk signals

3.3. Goal and context data

To personalize your experience and generate relevant analyses, we collect information about your race goal, the date and city of your target event (used to contextualize variables such as altitude and temperature) and your self-reported level of preparation.

3.4. Usage and technical data

We automatically collect technical data when you use the Platform, including IP addresses, browser type, device identifiers, session timestamps, pages visited and interaction data. This data is used for service operation, fraud prevention and improvement of the Platform.

4. How we use your information

We use the data we collect to:

• Provide and operate the Platform, including generating personalized training analyses and recommendations
• Assign you to a cohort of users with a similar goal and context, enabling the comparison and motivation features
• Send you analysis summaries, progress updates, alerts and service communications
• Process subscription payments and manage your billing
• Detect and prevent fraud and unauthorized access
• Analyze aggregated and anonymized data to improve the Platform and develop new features
• Comply with applicable legal obligations

5. Automated analysis and artificial intelligence

Swetro uses artificial intelligence systems to process your physical activity data and generate personalized insights. These analyses are produced algorithmically and are informational in nature. They do not constitute medical, physiotherapy or certified sports training advice. Swetro is not responsible for the decisions you make based on these analyses.

You have the right to request human review of any automated analysis that significantly affects your experience on the Platform. To do so, contact us at hello@swetro.com.

6. Cohorts and comparison between users

As part of the service, Swetro groups users into cohorts based on shared characteristics (goal, level and event context). Within your cohort, certain performance metrics may be visible to other members, such as distances covered or your relative position in the group. This information is limited to performance data and does not include your contact details or full identity, unless you choose to display them publicly through your username.

By using the Platform, you understand and accept that this comparison functionality is an essential part of the service.

7. Brand challenges and sharing data with partner brands

Swetro may offer challenges, events or communities organized together with brands or corporate clients (“Brand Activities”). Participation in these Brand Activities is always voluntary.

By signing up for a Brand Activity, you expressly authorize Swetro to share the following data with the organizing brand:

• Your contact details (name, email address and phone number if registered)
• Your physical activity data related to the Brand Activity (distances, times, performance metrics and progress recorded during the period of the challenge or event)

The sole purpose of this data exchange is the management, communication and follow-up of the Brand Activity you chose to participate in. Swetro contractually requires partner brands to process your data in accordance with applicable data protection legislation and solely for the purposes of the Brand Activity. Swetro does not sell your personal data to third parties.

You may revoke this authorization at any time by withdrawing from the corresponding Brand Activity, without affecting the data processing carried out prior to your withdrawal. If you want the partner brand to delete the data already shared, you must contact it directly, as Swetro does not control third-party systems.

8. Sharing data with third parties

Swetro does not sell or rent your personal data. We may share data in the following cases:

• Service providers: We share data with trusted providers that help us operate the Platform (payment processors, cloud hosting, analytics tools). These providers are contractually required to process data solely on our behalf and in accordance with this policy.
• Device integrations: When you connect third-party devices or applications (Garmin, Apple Health, Suunto), data flows between those services and Swetro subject to each provider’s privacy policy. You are responsible for reviewing and accepting those policies.
• Partner brands: As described in Section 7, only when you voluntarily sign up for a Brand Activity.
• Legal obligations: We may disclose data when required by law, a court order or a government authority.
• Business transfers: In the event of a merger, acquisition or sale of assets, your data may be transferred as part of the transaction, with prior notice.

9. Data retention

We retain your personal data while your account is active or as necessary to provide the service. If you delete your account, we will delete or anonymize your personal data within 90 days, unless applicable law requires longer retention or retention is necessary for legitimate purposes such as fraud prevention or dispute resolution.

Aggregated and anonymized data derived from your activity may be retained indefinitely to improve the Platform, as it cannot be linked back to you personally.

10. Security

Swetro implements technical and organizational measures to protect your data against unauthorized access, loss or alteration, including encryption in transit and at rest, access controls and periodic security reviews. However, no system is completely secure and we cannot guarantee absolute security. In the event of a data breach that may affect your rights, we will notify you in accordance with applicable law.

11. Cookies and tracking technologies

The Platform uses cookies and similar technologies to operate the service, remember your preferences, analyze usage and, where applicable, support advertising activities. You can control cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

Our advertising partners may use cookies, JavaScript or web beacons in their ads to measure campaign effectiveness. Swetro does not control these third-party technologies.

12. Your privacy rights

12.1. All users

Regardless of your location, you can:

• Access the personal data we hold about you
• Correct inaccurate data
• Request the deletion of your data (subject to legal retention requirements)
• Withdraw consent to processing where consent is the legal basis
• Request a copy of your data in a portable format

12.2. Users in Colombia (Law 1581 of 2012)

Users in Colombia have the following rights over their personal data under Statutory Law 1581 of 2012 and its implementing decrees: to know, update and rectify their data; to request proof of the authorization granted; to be informed about the use of their data; to file complaints with the Superintendence of Industry and Commerce (SIC); to revoke the authorization and/or request the deletion of data when constitutional and legal principles, rights and guarantees are not respected; and to access their personal data free of charge.

To exercise these rights, send your request to hello@swetro.com. Swetro will respond within the timeframes established by Colombian law (10 business days for inquiries, 15 business days for claims).

12.3. California residents (CCPA)

California residents have the right to request disclosure of the specific personal information collected about them; to request the deletion of their personal information; and to opt out of the sale of their personal information. Swetro does not sell personal data. To exercise these rights, contact us at hello@swetro.com.

12.4. EEA and UK residents (GDPR)

If you are located in the European Economic Area or the United Kingdom, you have the rights of access, rectification, erasure, restriction of processing, objection and data portability. You also have the right to lodge a complaint with your local supervisory authority. To exercise these rights, contact us at hello@swetro.com.

13. Children’s privacy

The Platform is not directed at anyone under 18 years of age. Swetro does not knowingly collect personal data from minors. If you believe a minor has provided us with personal information, contact us at hello@swetro.com and we will delete it immediately.

14. Changes to this policy

We may update this Privacy Policy periodically. If we make substantial changes, we will notify you by email to your registered address and/or by a prominent notice on the Platform at least 15 days before the effective date. Continued use of the Platform after that date will constitute acceptance of the updated policy.

15. Contact

Swetro Inc.
651 N Broad St, Suite 201, Middletown, Delaware 19709
hello@swetro.com