Privacy Policy & Cookie Policy

Last updated: 15 April 2026

Scope of this Policy

This Privacy Policy and Cookie Policy (the "Policy") applies to users of the Traininpink website (www.traininpink.net) and the Traininpink mobile application (the "Application") outside of Italy.

Users located in Italy are governed by the Italian-language privacy and cookie policy available at: https://www.traininpink.net/it/privacy-policy/

By accessing the Site or the Application, you acknowledge that you have read this Policy and understand how your personal data is processed.

Data Controller

The Data Controller is:

Traininpink RR DMCC Dubai, United Arab Emirates Email: team@traininpink.net

(referred to in this Policy as "Traininpink", "we", "us" or the "Data Controller").

For all matters relating to the processing of your personal data, including the exercise of your rights, please write to team@traininpink.net.

Applicable Law

Traininpink is established in the Dubai Multi Commodities Centre (DMCC), United Arab Emirates, and processes personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "UAE PDPL").

In addition, where applicable, we comply with:

• the EU General Data Protection Regulation (Regulation (EU) 2016/679, "EU GDPR") for users located in the European Economic Area;
• the UK General Data Protection Regulation and the Data Protection Act 2018 ("UK GDPR") for users located in the United Kingdom;
• the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA") for users located in California; and
• any other applicable data protection laws in the jurisdictions where our users are located.

Categories of Personal Data Processed

Depending on the circumstances, Traininpink may process the following categories of personal data:

• identification data (name, surname, age);
• contact data (residential or domicile address, email, telephone number);
• photographs that you may upload to your personal account area;
• purchase details (in particular, training plans purchased) and information regarding your use of the Site and/or the Application;
• data relating to physical activity carried out through the Application (information collected during our training plans, such as activity type, duration, pace, etc.);
• lifestyle data (e.g., sleep quality, steps, water intake) which may be entered by the user directly into the Application or imported from third-party platforms (e.g., Google Fit or Apple Health) where the user chooses to import such data;
• health-related data (e.g., pregnancy status) collected through the training quiz that the user may complete in order to identify the most suitable Traininpink program for their needs.

Purposes of Processing, Legal Basis and Nature of Provision

The Data Controller will process personal data for the following purposes:

• Service delivery. Identification, contact, physical activity and lifestyle data are processed in order to provide the service purchased by the user. Provision of such data is necessary for the performance of the service contract to which the user is a party. Failure to provide such data will make it impossible for Traininpink to deliver the service.
• Legal and accounting compliance. Identification data and purchase data are processed to comply with applicable accounting, tax and administrative obligations to which the Data Controller is subject.
• Site and Application administration and improvement. Personal data referred to in point (4) above are processed for the administrative and technical management of the Site and the Application, to send service-related notices, to provide user assistance, and to enable users to send anonymous feedback regarding the program completed. The legal basis is the legitimate interest of the Data Controller in ensuring the optimal functioning and improvement of the Site and Application.
• Direct marketing. Contact data may be used by Traininpink to send promotional communications regarding services similar to those already purchased by the user. The user is at all times entitled to request that data not be processed for this purpose or, where processing is already underway, to exercise the right to object. Where local law requires opt-in consent for marketing communications (including in the EEA, UK and certain other jurisdictions), such communications will only be sent on the basis of the user's prior consent, which may be withdrawn at any time.
• Personalisation of the user account. Data relating to age or personal images may be used solely to personalise the user's account area in the course of service delivery. Provision of such data is optional and does not affect the delivery of the service.
• Health-based program recommendation. Health-related data may be used to identify the Traininpink program best suited to the user's needs. Such data is provided to Traininpink based on the user's express consent. Provision is optional, but failure to provide it will make it impossible for Traininpink to recommend the most appropriate program.

For users in the EEA and UK, the legal bases under the EU/UK GDPR are: Article 6(1)(b) (contract) for purposes 1 and 5; Article 6(1)(c) (legal obligation) for purpose 2; Article 6(1)(f) (legitimate interests) for purposes 3 and 4; Article 6(1)(a) (consent) and Article 9(2)(a) (explicit consent for health data) for purpose 6.

Processing by Third Parties

To receive payment for the services provided, Traininpink relies on a third-party payment service provider, which acts as an independent data controller for the collection of payment data and the processing necessary to finalise the payment requested by the user. In relation to user payments, Traininpink only processes the data received from the provider regarding the outcome of the payments, which is necessary to enable Traininpink to deliver the services purchased. Traininpink does not collect or process any further payment data of the user.

The Site and the Application contain icons that allow the user to access Traininpink's profile on social media channels such as Facebook, Instagram, TikTok, Spotify and YouTube. Traininpink is not responsible for the data collection and processing activities carried out by the platforms to which the Application links.

Retention Periods

Personal data will be retained only for the time necessary to pursue the purposes for which it was collected, in accordance with the principle of data minimisation.

In particular:

• personal data processed to deliver the services purchased by the user (purpose 1 above) will be retained for a period of 10 (ten) years from the conclusion of the user's last training plan. During this period, the Data Controller will implement data minimisation measures. After 24 (twenty-four) months of inactivity of the user's profile, the Data Controller will send the user a notice regarding the planned deletion of the profile, allowing the user to object to deletion within 30 (thirty) days. In the event of objection, the Data Controller will send a new notice after a further 24 (twenty-four) months;
• personal data relating to age or personal images contained in the user's profile (purpose 5 above) will be deleted upon deletion of the profile, in accordance with the preceding paragraph;
• even in the event of account deletion by the user, personal data processed to ensure compliance with Traininpink's legal, judicial and administrative obligations, as well as to manage Traininpink's involvement in administrative and judicial proceedings (purpose 2 above), will be retained for 10 years from the end of the provision of Traininpink's services to the user;
• personal data processed for the administrative and technical management of the Site and the Application, to send service-related notices, to provide user assistance, or to enable the user to send anonymous feedback regarding the program completed (purpose 3 above) will be deleted after 24 (twenty-four) months of inactivity of the user's profile;
• contact data processed to send promotional communications for marketing purposes (purpose 4 above) will be retained for 24 (twenty-four) months from the user's last interaction with the Application and/or the Site, after which Traininpink will send the user a notice regarding the planned deletion of the profile, allowing the user to object to deletion within 30 (thirty) days. In the event of objection, the Data Controller will continue to send promotional communications and will send a new notice after a further 24 (twenty-four) months. The user is at all times entitled to request that data not be processed for this purpose or to exercise the right to object;
• health-related data collected through the training quiz will be retained for a period of 5 (five) years from the completion of the quiz. During this period, the Data Controller will implement data minimisation measures. The user is at all times entitled not to complete the quiz or, where processing of such data is already underway, to exercise the right to withdraw consent.

Recipients of Personal Data and International Transfers

The number of persons with access to your personal data is limited. Only individuals who need to process personal data in accordance with the purposes set out above have access to it.

We may share personal data with suppliers and partners that perform services on our behalf or otherwise collaborate with us, including our payment service provider and any IT service providers.

As Traininpink is established in the United Arab Emirates, personal data of users located outside the UAE will be transferred to the UAE for processing. Personal data may also be transferred to other countries where our service providers are located, including India, Australia and the United States.

Where personal data of EEA or UK users is transferred to countries that have not been the subject of an adequacy decision by the European Commission or the UK government, we rely on appropriate safeguards, including the Standard Contractual Clauses approved by the European Commission (and the UK International Data Transfer Addendum where applicable), supplemented by additional measures where necessary to ensure an adequate level of protection.

The current list of recipients located outside the user's country may be requested at any time by writing to team@traininpink.net.

Your Rights

Subject to applicable law and to the legitimate defence needs (including judicial defence) of the Data Controller, you may exercise the following rights in relation to your personal data:

• Right of access: the right to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to obtain access to such data and further information regarding its origin, purposes, categories of data processed, recipients of communication and/or transfer, etc.
• Right to rectification: the right to obtain the correction of inaccurate personal data without undue delay, as well as the integration of incomplete personal data.
• Right to erasure: the right to obtain the deletion of personal data without undue delay where: (i) the data is no longer necessary for the purposes of processing; (ii) consent has been withdrawn and there is no other legal basis for processing; (iii) the data has been unlawfully processed; or (iv) the data must be deleted to comply with a legal obligation.
• Right to object: the right to object at any time to the processing of personal data based on the legitimate interest of the Data Controller, including processing for direct marketing purposes.
• Right to restriction of processing: the right to obtain restriction of processing where the accuracy of the data is contested, where processing is unlawful, or where the user has objected to processing.
• Right to data portability (where applicable): the right to receive personal data concerning you in a structured, commonly used and machine-readable format, and to transmit such data to another controller.
• Right to withdraw consent (where processing is based on consent): the right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

Additional rights for California residents (CCPA/CPRA): If you are a California resident, you also have the right to know what personal information we collect, use, disclose and sell or share; the right to delete personal information; the right to correct inaccurate personal information; the right to opt out of the sale or sharing of personal information; the right to limit the use of sensitive personal information; and the right not to be discriminated against for exercising your rights. Traininpink does not sell personal information for monetary consideration. To exercise these rights, please write to team@traininpink.net.

Right to lodge a complaint: EEA users may lodge a complaint with the data protection authority of their country of residence. UK users may lodge a complaint with the UK Information Commissioner's Office (ICO). UAE users may lodge a complaint with the UAE Data Office.

To exercise any of the above rights, please write to team@traininpink.net.