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PrivacyLast updated : 02/04/2026

PRIVACY POLICY

WELLMATE – VERSION 2.0

Contents

  1. 1. 1. Data controller
  2. 2. 2. Scope
  3. 3. 3. Personal data collected
  4. 4. 4. Purposes of processing
  5. 5. Article 4a – Processing for communication and marketing purposes (Coaches only)
  6. 6. 5. Legal bases for processing
  7. 7. 6. Artificial intelligence and automated processing
  8. 8. 7. Access to and sharing of data
  9. 9. 8. Analysis, anonymisation and service improvement
  10. 10. 9. Data retention periods
  11. 11. 10. User rights
  12. 12. 11. Data security
  13. 13. 12. Transfers outside the European Union
  14. 14. 13. Changes to the privacy policy
  15. 15. 14. Contact and complaints
1. Data controller

Personal data collected through the WellMate PRO and WellMate Training services is processed by:

KP INDUSTRIES

Société par actions simplifiée (SAS)

Laval Trade and Companies Register no. 924 920 861

Registered office: 6 rue Léonard de Vinci, 53810 Changé – France

Contact email: contact@wellmate.fr

KP INDUSTRIES acts as the data controller within the meaning of Regulation (EU) 2016/679 (GDPR).

2. Scope

This privacy policy applies to all users of the WellMate services, namely:

  • Coaches using WellMate PRO,
  • Athletes using WellMate Training.

It describes how personal data is collected, used, retained and protected.

3. Personal data collected

Depending on the user’s profile and how the services are used, WellMate may collect the following categories of data:

3.1 Identification data

  • first name, last name,
  • email address,
  • user ID,
  • profile picture (optional).

3.2 Training and nutrition data

  • training goals,
  • self-reported or tracked physical activities,
  • nutrition data,
  • meal photos submitted by the Athlete,
  • measurements and tracking indicators.

3.3 Content data

  • messages exchanged,
  • training programmes,
  • reports, notes, comments,
  • content created or shared through the platform.

3.4 Technical data

  • connection logs,
  • device and browser information,
  • security and audit data.
4. Purposes of processing

Data is processed for the following purposes:

  • providing and operating the WellMate services,
  • managing user accounts,
  • training and nutrition tracking,
  • communication between Coaches and Athletes,
  • assistance and support,
  • security and abuse prevention,
  • improving the services and features,
  • improving and training the artificial intelligence tools,
  • internal statistical analysis.
Article 4a – Processing for communication and marketing purposes (Coaches only)

The contact details of Coach users of WellMate PRO may be used by KP INDUSTRIES for communication, information and prospecting purposes relating to the WellMate services.

This processing may include:

  • sending commercial or informational communications;
  • carrying out marketing and advertising activities to promote the WellMate services, including through partner advertising platforms.

The data used for these purposes is strictly limited to what is necessary (in particular the email address) and may be shared in hashed form with advertising partners.

This processing never concerns Athlete users.

5. Legal bases for processing

The processing carried out by WellMate relies on the following legal bases:

  • performance of the contract (Terms of Use / Terms of Sale),
  • the legitimate interest of KP INDUSTRIES (security, service improvement),
  • the Coach user’s explicit consent for processing for communication and marketing purposes,
  • the user’s consent where required (in particular for certain AI processing or optional content),
  • compliance with legal obligations.
6. Artificial intelligence and automated processing

Some WellMate features rely on artificial intelligence systems enabling in particular:

  • the analysis of training or nutrition data,
  • the estimation of nutritional composition from text or photos,
  • the generation of summaries, reports or assisted content.

This processing:

  • relies on probabilistic models,
  • produces no automated decision within the meaning of article 22 of the GDPR,
  • has no autonomous legal effect on users.

Results generated by the AI are indicative and do not replace human expertise.

7. Access to and sharing of data

7.1 Access by Coaches

Coaches have access to the data of the Athletes linked to them, exclusively as part of their coaching relationship.

7.2 Processors

Some data may be processed by providers acting as processors, in particular for:

  • hosting,
  • payment (Stripe),
  • sending emails,
  • technical operation of the services,
  • carrying out communication and marketing activities, subject to the consent of the Coaches concerned.

These providers are bound by strict contractual confidentiality and security obligations.

7.3 No sale of data

Personal data is never sold or transferred to third parties for commercial purposes.

8. Analysis, anonymisation and service improvement

Users authorise WellMate to:

  • analyse data in order to improve the services,
  • anonymise data for statistical and technical uses,
  • use anonymised data to improve the performance of the AI tools.

Anonymised data no longer allows the individuals concerned to be identified.

9. Data retention periods

Personal data is retained:

  • for as long as the account is used,
  • then archived or deleted in accordance with articles 17 and 5(1) of GDPR EU2016/679,
  • some data may be retained in anonymised form for statistical purposes.
10. User rights

In accordance with the GDPR, users have the following rights:

  • right of access,
  • right to rectification,
  • right to erasure,
  • right to restriction of processing,
  • right to object,
  • right to data portability.

Coach users may object to, or withdraw their consent for, the processing of their data for communication and marketing purposes at any time, with no impact on their access to the WellMate services.

Requests can be sent to:

contact@wellmate.fr

A response will be provided within the statutory time limits.

11. Data security

KP INDUSTRIES implements appropriate technical and organisational measures to guarantee the security, confidentiality and integrity of personal data.

12. Transfers outside the European Union

As part of certain technical services, data may be transferred outside the European Union.

These transfers are governed by appropriate safeguards in accordance with the GDPR (standard contractual clauses, adequacy decisions, etc.).

13. Changes to the privacy policy

This privacy policy may be amended at any time to reflect legal, regulatory or functional changes to the services.

In the event of a material change, users will be informed.

14. Contact and complaints

For any question relating to the protection of personal data, users can contact:

contact@wellmate.fr

They also have the right to lodge a complaint with the competent supervisory authority (the French CNIL).

PRIVACY POLICY – WELLMATE – VERSION 2.0 – Last updated: 02/04/2026 — Courtesy translation: only the French version is legally binding.