Effective date: Feb 13th, 2023

  • This privacy policy (this “Privacy Policy”) informs you of Rewire Fitness, Inc.’s and its subsidiaries (“Rewire”, “us”, “we”, or “our”) policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.This Privacy Policy supplements and forms a part of our Terms and Conditions for use of our Service. We use your data to provide and to improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions. DEFINITIONS
    • “Service” means our mobile application, website, social media accounts, online courses, message boards, online dashboard, and digital content operated by us and/or our affiliates.
    • “Personal Data” means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession) and that comes into our possession through use of the Service.
    • “Usage Data” is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
    • “User” is any living individual who is using our Service and is the subject of Personal Data.



    We collect several different types of information for various purposes to provide and to improve our Service to you. The type of data that we collect, our relationship with the Personal Data, and your relationship with the Personal Data may vary based on applicable law. For instance, if you are a resident of California, or if you live in the European Union (“EU“)/European Economic Area (“EEA”), or if you live in the United Kingdom (“UK“), you may have certain rights to the Personal Data. We describe these rights and these variations in this Privacy Policy.

    Types of Personal Data Collected

    Contact Data

    While using our Service, we may ask you to provide us with certain Personal Data that can be used to contact or to identify you. Personal Data collected in this way may include, but is not limited to:

    • Email address
    • First name and last name
    • Phone number
    • Address, City, State, Province, ZIP/Postal code, Country

    We may use your Personal Data to contact you with newsletters, marketing or promotional materials, online courses, surveys and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

    Health and Fitness Data

    While using our Service, we may ask you to provide us with certain health and fitness data in order to provide you with personalized features and performance-related metrics, which may include, but is not limited to:

    • Birthday
    • Height
    • Weight
    • Sleep data (including wake up time, time asleep, REM & deep sleep)
    • Functional Threshold Power (FTP)
    • Lactate Threshold Heart Rate (LTHR)
    • Heart Rate data (such as max heart rate, average heart rate, resting heart rate and heart rate variability)
    • Your chosen or preferred sports
    • Weekly mental load
    • Cognitive readiness measures (such as reaction time, lapses, misses and mental load)
    • Physical readiness measures (such as training load and muscle soreness)
    • Emotional readiness measures (such as subjective ratings of rest, readiness, frustration and stress)
    • Neuro-Training performance data (such as reaction time or accuracy)
    • Recovery performance data (such as subjective improvement)
    • Subjective performance measures (such as rating of perceived exertion)
    • Physical performance measures (such as power and heart rate)
    • Workout data (such as workout duration, intensity, distance completed and number of workouts completed)

    Health and fitness data may be imported automatically through services that you choose to connect with in the Rewire system, such as Strava, Apple Health, Google Fit, Oura Ring and other services that capture health and fitness data. (We encourage you to consult the Terms of Use and Privacy Policies of the service(s) that you use to understand how they use your data and what rights you may have.)

    Communications to Us

    Usage Data

    When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, GPS location and other diagnostic data.

    Tracking & Cookies Data

    We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information in connection therewith.

    Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used (such as GPS, beacons, tags and scripts) to collect and track information and to improve and analyze our Service.

    You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

    Examples of cookies we use:

    • Session Cookies. We use session cookies to operate our Service.
    • Preference Cookies. We use preference cookies to remember your preferences and various settings.
    • Security Cookies. We use security cookies for security purposes.


    Rewire uses the collected Personal Data for various purposes:

    • To provide and maintain our Service
    • To manage and support your use of our Service
    • To notify you about changes to our Service
    • To allow you to participate in interactive features of our Service when you choose to do so
    • To provide customer support
    • To gather analysis or valuable information so that we can improve our Service
    • To monitor the usage of and interest in our Service
    • To develop new products for our Service
    • To detect, prevent and address technical issues
    • To verify account access
    • To provide you by email or text message with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information



    If you are from the EU/EEA or UK, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

    We may process your Personal Data because:

    • We need to perform a contract with you
    • You have given us permission to do so
    • The processing is in our legitimate interests and it is not overridden by your rights
    • For payment processing purposes
    • To comply with the law



    We will retain your Personal Data only for as long as you use our Service or as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and/or to enforce our legal agreements and policies.

    Rewire will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

    When we no longer are required to retain Personal Data, we will destroy, erase, or de-identify that data in compliance with data retention policies and applicable law.


    Individuals in the EU/UK should be aware that Rewire may transfer your personal data to a third party in countries outside the EU for further processing in accordance with the purposes set out in this Privacy Policy. In particular, your personal data may be transferred throughout Rewire and to our service providers located abroad. Any such Data transfer is based on one of the legal bases described below. Users can inquire with Rewire to learn which legal basis applies to which specific service.

    Data transfer abroad based on standard contractual clauses

    If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Rewire according to “standard contractual clauses” provided by the European Commission.

    This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact Rewire through the contact details provided in the present document.

    Data transfer abroad based on consent

    If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.

    In such cases, Rewire shall inform Users appropriately and collect their explicit consent.


    Business Partners and Service Providers

    We may share your Personal Data with our business partners and affiliates who support the Service or with whom we may jointly offer products and services, or whose products and services we believe may be of interest to you.  At your request, and with your express consent, we may share certain specified Personal Data with registered fitness coaches who will review and analyze certain Personal Data in furtherance of services that you choose.

    We may share your Personal Data with vendors and service providers to support the Service and to carry out business functions, including payment processing and data support. Please see below under “Service Providers” for further information.

    Our policy is to enter into agreements with these third-parties that prohibit further use or disclosure of Personal Data and that ensure adequate protections in place in compliance with applicable law.

    Business Transaction

    If Rewire is involved in a merger, acquisition, reorganization, bankruptcy, receivership, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is so transferred and becomes subject to a different Privacy Policy.

    Disclosure for Law Enforcement

    Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

    Legal Requirements

    We may disclose your Personal Data in the good faith belief that such action is necessary:

    • To comply with a legal obligation
    • To protect and defend the rights or property of Rewire
    • To prevent or investigate possible wrongdoing in connection with the Service
    • To protect the personal safety of Users or the public
    • To protect against legal liability



    The security of your Personal Data is important to us. We undertake measures to help ensure security of that data, including reasonable and appropriate administrative, technical, and physical security measures designed to protect against the loss, misuse or alteration of Personal Data. But remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.


    We do not support Do Not Track. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

    You can enable or disable Do Not Track by visiting the “Preferences” or “Settings” page of your web browser.


    If you are a resident of the EU/EEA, UK or California, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

    If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

    In certain circumstances, you have the following data protection rights:

    • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
    • The right of rectification. You have the right to have your information corrected if that information is inaccurate or incomplete.
    • The right to object. You have the right to object to our processing of your Personal Data.
    • The right of restriction. You have the right to request that we restrict the processing of your personal information.
    • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
    • The right to withdraw consent. You also have the right to withdraw your consent at any time where Rewire relied on your consent to process your personal information.

    Please note that we may ask you to verify your identity before responding to such requests.

    You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA if you are an EEA resident, or your local data protection authority in the UK if you are a UK resident or the California Attorney General’s Office if you are a California resident.


    We may employ third-party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used (“Service Providers”).

    These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


    We may use Service Providers to monitor and analyze the use of our Service.

    • Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google in their Privacy Policy: more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
    • Firebase is an analytics service provided by Google. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google in their Privacy Policy: We also encourage you to review Google’s policy for safeguarding your data: For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page:
    • We use AppsFlyer for attribution analytics. In connection with this service, we may collect, process and use certain non-personal and personal data from the Users of these mobile apps, as further described hereafter: Anonymized (hashed) IP address, Anonymous identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar identifiers, Installation and first opening of an app on your mobile device, User interactions within an app (e.g. in-app purchases, registration, etc.), and Information regarding which advertisements the User has seen or clicked on. AppsFlyer does not combine the collected non-personal data with any other data that would enable AppsFlyer to personally identify the User. You can find out more about AppsFlyer privacy here:
    • We use Amplitude to process Usage Data for the purpose of better understanding usage habits, preferences and needs and to continuously improve the Service and offer the best possible User experience tailored to our customers’ needs, as well as for the purpose of driving sales and renewals and to provide you with marketing communications which we tailor to your needs. You can find out more about Amplitude privacy here:


    Behavioral Remarketing

    We use remarketing services to advertise on third-party websites to you after you visit our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

    Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA at, the Digital Advertising Alliance of Canada in Canada at or the European Interactive Digital Advertising Alliance in Europe at, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy:



    We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

    We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

    The payment processors we work with are:

    • Stripe’s privacy policy can be viewed at




    Our Service may contain links to other websites that are not operated by us. If you click a third-party link, you will be directed to that third-party’s website. We strongly advise you to review the privacy policy of every website you visit.

    We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services.


    Our Service is not intended for anyone under the age of 13, and no one under the age of 13 may provide any information to the Service. We do not knowingly collect Personal Data from anyone under the age of 13. If you believe we might have any information from or about a child under age 13, please contact us. If we become aware that we have collected Personal Data from children under the age of 13 without parental consent, we will take all reasonable steps to remove such information from our databases.


    We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

    We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Effective date” at the top of this Privacy Policy.

    You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


    Individuals outside the European Union, European Economic Area, United Kingdom or Switzerland with inquiries or complaints regarding this Privacy Policy should first contact Rewire at:

    Data Controller, Rewire Fitness, Inc.
    249 State Route 208
    New Paltz, NY
    United States
    Contact email: [email protected] 

    Individuals in the European Union, European Economic Area, United Kingdom or Switzerland with inquiries or complaints regarding this Privacy Policy should first contact Rewire at:

    Data Controller, Rewire Limited
    35, De Soldanis Street,
    Victoria (GOZO), VCT 1040
    Contact email: [email protected]