Privacy Policy

Last updated: 11/10/2025

1. DATA CONTROLLER

Name or company name: Eduardo Arnal Velasco

NIF/CIF: ESB32812800

Address: Calle Zulueta 5, Entreplanta B, 48992, Getxo, Bizkaia, España

Contact email: info@trainyourfreedom.com

2. SCOPE

This privacy policy applies to the website www.trainyourfreedom.com, its subdomains and any other service, application or platform linked to Train Your Freedom & Arca.

3. PERSONAL DATA WE PROCESS

We collect and process the following categories of personal data:

  • Identifiers: name, surnames, email, phone.
  • User account: credentials, preferences, settings.
  • Transactional: shipping/billing addresses, products purchased, amounts.
  • Communications: messages, inquiries, contact forms.
  • Technical data: IP address, device type, browser, operating system, site activity.
  • Cookies and similar technologies: see Cookie Policy.
  • Data from Arca App: Bluetooth pairings, usage logs and technical settings (without collecting sensitive personal information).

We do not request specially protected data. If communicated to us, they will be deleted except for legal obligation to retain.

4. PURPOSES AND LEGAL BASES

Purpose: Provide contracted services and manage your account

Legal basis: Contract execution

Purpose: Process payments and orders in the store

Legal basis: Contract execution / Legal obligation

Purpose: Address inquiries and requests

Legal basis: Legitimate interest / Consent

Purpose: Send commercial communications or newsletters

Legal basis: Consent

Purpose: Analyze web/app usage and improve service

Legal basis: Legitimate interest

Purpose: Comply with tax, accounting or legal obligations

Legal basis: Legal obligation

Purpose: Ensure security, fraud detection and technical maintenance

Legal basis: Legitimate interest

5. RETENTION PERIODS

  • Account and billing data: while the contractual relationship exists and during the periods required by law (for example, 6 years according to accounting regulations).
  • Inquiries and support: up to 24 months.
  • Commercial communications: until consent is withdrawn.
  • Technical records: between 12 and 24 months, except security incidents.

6. DATA RECIPIENTS

We may only share data with the following types of third parties:

Service providers (data processors):

All of them act in accordance with GDPR contract and only access necessary data.

We do not sell or transfer personal data to third parties for commercial purposes.

7. INTERNATIONAL TRANSFERS

In case any provider is located outside the European Economic Area (EEA), we guarantee an adequate level of protection through adequacy decisions, standard contractual clauses or additional measures.

8. USER RIGHTS

You can exercise the rights of access, rectification, deletion, limitation, portability, opposition and withdrawal of consent by sending a request to info@trainyourfreedom.com.

Maximum response time: 1 month, extendable to 2 in complex cases.

You can also file a claim with the AEPD: www.aepd.es

9. SECURITY

We apply appropriate technical and organizational measures: TLS encryption, access control, backups, activity logging and data minimization.

10. MINORS

Our services are not directed at minors under 18 years of age.

If we detect information from minors without their guardians' consent, it will be immediately deleted.

11. USE OF COOKIES

We use our own and third-party cookies to guarantee basic operation, analyze traffic, remember preferences and offer personalized content (only with consent).

See Cookie Policy for more information.

12. COMMERCIAL COMMUNICATIONS

We will only send electronic communications if we have your prior consent or if you are already a customer and the communications are about similar products or services.

You can unsubscribe at any time from the email itself or by writing to info@trainyourfreedom.com.

13. PAYMENTS AND GATEWAYS

Payments are made through Paycomet and PayPal, which act as data controllers for banking data.

Arca does not store or access complete card data.

14. INTEGRATED THIRD-PARTY SERVICES

Some sections of the site or app may integrate third-party tools, such as virtual cycling platforms (MyWhoosh, TrainingPeaks Virtual, Zwift), authentication services (Google, Apple, Meta) or analytics.

Each is governed by its own privacy policies.

15. MODIFICATIONS TO THIS POLICY

We reserve the right to modify this Privacy Policy to adapt it to regulatory or service changes.

We will post any update on this same page with the corresponding date.

16. CONTACT

Email: info@trainyourfreedom.com

Postal address: Calle Zulueta 5, Entreplanta B, 48992, Getxo, Bizkaia, España