⚠️ Draft — pending legal review before publication
Version: 1.0In force since:

Informed Consent for Processing of Health Data

iBetterCoach Version: 1.0 Date: [to be defined]

⚠️ Notice: This consent is required by Article 9(2)(a) GDPR for processing of special category (health) data. It must be explicit, separate, granular and informed. Requires legal review before publication.

INTENDED RECIPIENT

This Consent is intended for the Athlete (end user) who uses the iBetterCoach Platform via their Professional Customer (Personal Trainer, nutritionist, physiotherapist, etc.).

This consent must be presented to the Athlete separately from registration, the Terms of Use and the Privacy Policy — through a dedicated, non-pre-ticked checkbox.

1. Who processes my data?

  • Controller: the Professional Customer (PT/nutritionist) who added me to the Platform.
  • Technical processor: iBetterCoach, which provides the Platform and processes data under the Professional Customer's instructions.
  • iBetterCoach Data Protection Officer (DPO): dpo@ibettercoach.com

2. What health data will be collected?

I may be invited to share personal data and health data, namely:

  • Basic identification: name, date of birth, sex, contact
  • Anthropometry: weight, height, perimeters, body fat percentage, bioimpedance data
  • Clinical anamnesis: personal and family history, diseases, surgeries, regular medication, allergies, intolerances, injuries, medical restrictions, chronic pain
  • Lifestyle: sleep, stress, smoking, alcohol consumption, physical activity level
  • Sports data: training history, goals, 1RM, sports injuries
  • Nutritional data: preferences, restrictions, food log
  • Wearable data (optional): heart rate, HRV, sleep, steps, continuous glucose (where applicable)
  • Progress photos (strictly optional, only if I upload them, never mandatory)

3. What will my data be used for?

My data will be used exclusively to:

✓ Allow my professional to perform an adequate anamnesis and assessment ✓ Generate training and nutrition prescription suggestions to be reviewed and validated by the professional ✓ Calculate integrated projections (CurrentClinicalView, ClinicalDeltaView, TrainingImplicationsView, NutritionImplicationsView) to help the professional make better decisions ✓ Track my progress over time ✓ Detect alerts and contraindications to be flagged to the professional ✓ Enable secure communication between me and my professional on the Platform

My data will NOT be used for:

✗ Automated decisions producing legal or similarly significant effects without human intervention — every prescription requires professional validation ✗ Training of third-party AI models — iBetterCoach contractually prohibits its AI partners from retaining or training on my data ✗ Targeted marketing, commercial profiling or advertising ✗ Sale or transfer to third parties (insurers, employers, social networks, etc.)

4. What is the legal basis for the processing?

Because this involves special category data (health), the processing is based on my explicit consent (Article 9(2)(a) GDPR), given:

  • Freely — no adverse consequence for me beyond not being able to use the Platform
  • Specifically — I consent for the purposes expressly identified in this document
  • Informed — I have read and understood all the information in this document
  • Unambiguously — manifested by clear positive action (dedicated checkbox)

5. Who else will access my data?

Only:

  • My Professional Customer (PT/nutritionist who added me)
  • Authorised members of my professional's team (interns, co-trainers, assistants)
  • iBetterCoach, exclusively as a technical processor, to ensure operation, security and support of the Platform
  • iBetterCoach technical sub-processors (Supabase, Clerk, Vercel, etc.), with contractual GDPR obligations
  • Public authorities, only if required by law (court order, validly issued request)

Never: other professionals, other athletes, gyms not authorised by me, insurers, employers, social networks.

6. Will my data leave the European Union?

iBetterCoach prioritises storage in European regions (Frankfurt). Some technical services (authentication, generative AI) may involve transfers to the USA, always covered by:

  • Standard Contractual Clauses (SCC) approved by the European Commission
  • EU-US Data Privacy Framework (where applicable)
  • Pseudonymisation of data before leaving the EU when the AI layer is involved

Can I refuse international transfers? If I refuse, certain features (e.g., AI-generated explanations) may become unavailable, but general use of the Platform remains possible.

7. How long will my data be kept?

  • For as long as the relationship with my professional is active
  • After termination: 30 days to allow me to export or request deletion
  • After this period, the data are deleted, unless a legal retention obligation applies

I may request full deletion or export of my data at any time.

8. What are my rights?

I have the right to:

  • Access my data (Art. 15)
  • Rectify incorrect or outdated data (Art. 16)
  • Erase my data / right to be forgotten (Art. 17)
  • Restrict processing (Art. 18)
  • Object to processing (Art. 21)
  • Portability — receive my data in structured format (JSON, CSV) and transfer them to another controller (Art. 20)
  • Not be subject to automated decisions with significant impact (Art. 22) — iBetterCoach guarantees human validation
  • Withdraw consent at any time, without affecting the lawfulness of prior processing
  • Lodge a complaint with the Portuguese Data Protection Authority (CNPD) — www.cnpd.pt

To exercise any of these rights, I may contact:

iBetterCoach will respond to or forward the request within 30 days, extendable by 60 additional days under the GDPR.

9. What happens if I do not consent?

Use of the iBetterCoach Platform requires acceptance of this consent. If I do not agree, I cannot use the Platform.

This requirement is proportional because health data is strictly necessary for the purpose of the service — safe training or nutrition prescription would not be possible without it. No equivalent service can function without this consent.

Refusal has no other adverse consequences for me. I may continue my relationship with my professional outside the Platform.

10. Can I withdraw consent later?

Yes, at any time and without justification. Withdrawal takes effect for the future and does not affect the lawfulness of processing already carried out.

Withdrawal of consent means I will no longer be able to use the Platform — because the service depends on this processing.

I may withdraw consent through:

  • My account settings on the Platform → "Withdraw consent and delete account"
  • Email to my professional
  • Email to dpo@ibettercoach.com

11. The Platform is an assistance tool — I am responsible for myself

I understand and accept that:

  • iBetterCoach is an assistance tool for my professional and for me. It is not a medical service, it does not replace medical consultation and it does not issue diagnoses.
  • All information, suggestions, plans or recommendations presented by the Platform — including those generated by artificial intelligence — are informative and supportive in nature, and must be reviewed by my professional.
  • The Platform may produce incorrect information. I understand that iBetterCoach uses artificial intelligence models and automated calculations that may generate content that is incorrect, outdated, incomplete or unsuitable for my specific case — including AI "hallucinations" (plausible but factually wrong text). For this reason, I must not treat any information from the Platform as absolute truth, I must keep a critical mindset and I must always validate with my professional and, where appropriate, with a doctor.
  • In case of any doubt about a health matter, symptom, pain, discomfort, medication, allergy, clinical condition or contraindication, I must consult a doctor or other qualified healthcare professional before acting.
  • I am responsible for myself: for my decisions, for respecting my own physical limits, for following my doctor's guidance, for honestly reporting my health status to my professional and for immediately stopping any exercise, meal plan or supplementation if I feel pain, dizziness, breathing difficulty or any other warning sign, and for seeking medical help.
  • The Platform cannot replace my common sense, my self-observation or the direct relationship between me and my healthcare professionals.

12. Consent declaration

I declare that:

  • ☐ I have read and understood this Informed Consent in full
  • ☐ I had the opportunity to ask questions and received clarification
  • ☐ I am 18 years of age or older (minor users require parental authorisation and a separate mechanism)
  • ☐ I understand that iBetterCoach is an assistance tool, that it does not replace medical advice, and that I am responsible for my own health decisions and for consulting qualified healthcare professionals in case of doubt
  • ☐ I understand that the Platform may produce incorrect, inaccurate or unsuitable information for my case, including AI-generated content, and that I must always critically validate it with my professional and, if necessary, with a doctor
  • ☐ I expressly consent to the processing of my health and special category data by iBetterCoach and by my Professional Customer, for the purposes, conditions and periods described herein

Date: [auto-filled by the Platform] Athlete identification: [auto-filled] Associated Professional Customer: [auto-filled] Consent version accepted: 1.0

Document prepared for iBetterCoach. Requires formal legal review before publication. The Consent must be presented to the Athlete as a separate checkbox during onboarding, never grouped with general Terms or Privacy Policy.

This document may be updated. The version in force is always the one available on this page.

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