Privacy Policy

Effective date: September 1, 2025

1. Introduction

Kotcha prioritizes data protection. The company explains what information is collected during use of websites and applications, how that information is utilized, sharing practices with third parties, and user rights regarding personal data.

The data controller is PACEUP SAS, a French company headquartered at 39 Rue de la Gare de Reuilly, 75012 Paris, France (registration number 943460865). Kotcha operates as a trading name for PACEUP SAS.

Users consent to data practices described in this policy by using the Services. Questions should be directed to support@kotcha.com. The policy may be updated periodically; continued use indicates acceptance of changes.

2. What Do We Collect and Why?

The company collects information to provide Services and enhance user experience.

Name, DOB, gender, profile picture, contact details

• Purpose: Record-keeping; service provision; event/offer communications (with consent); merchandise shipping.
• Legal basis: Consent; contract fulfillment.

Payment information

• Purpose: Subscription and merchandise purchases.
• Legal basis: Contract fulfillment.

Location and health/fitness data

• Purpose: Workout recording; partner imports (Garmin, Apple); anonymized coaching insights via LLM partners.
• Legal basis: Consent; contract fulfillment.

Technical/device/usage information

• Purpose: Service improvement; business operations; data accuracy and privacy maintenance.
• Legal basis: Contract fulfillment; legitimate business interests.

Other Processing Scenarios

• Business transactions (sales, mergers, acquisitions, bankruptcies) may involve data sharing.
• Anonymous aggregated information supports Service administration and may be shared with business partners.

3. How Long Do You Keep It For?

Personal data retention occurs only as long as necessary for Service provision. Legal obligations may require extended retention. Specific retention periods are available upon request.

Users may request data deletion at any time (see Section 7).

4. Who Is It Shared With?

The company does not sell personal information but shares it with selected third parties to provide Services.

Cloud Storage/Hosting (Supabase, Railways)

• Purpose: Service hosting; USA-based data storage.
• Legal basis: Contract fulfillment.

Communication Platforms (Intercom)

• Purpose: In-app messaging.
• Legal basis: Contract fulfillment.

CRM Providers

• Purpose: Customer relationship management.
• Legal basis: Consent; contract fulfillment.

Analytics Tools

• Purpose: Product analysis; technical data collection (IP, identifiers, usage history).
• Legal basis: Legitimate business interests.

Payment Processors

• Purpose: Payment/billing processing.
• Legal basis: Contract fulfillment.

Advertising/Marketing Partners

• Purpose: Website/social statistics; interaction tracking; ad personalization; campaign optimization.
• Legal basis: Consent.

AI Partners

• Purpose: Personalized coaching insights.
• Legal basis: Consent.

Compliance/Legal Providers

• Purpose: Legal obligation assistance.
• Legal basis: Legitimate business interests.

5. User Account Assistance Mode

Upon explicit user request and consent, Kotcha employees may temporarily access user accounts for troubleshooting. In this mode:

• Employees may view activity data but cannot access location or health data.
• Access is restricted to trained, designated personnel with confidentiality obligations.

Contact support@kotcha.com for questions.

6. How Is My Information Protected?

Data security measures include:

• SSL encryption for data transmission.
• Industry-standard protections for stored and transmitted data.
• Restricted authorized access.

No transmission method is 100% secure; Kotcha cannot guarantee absolute security but employs commercially acceptable protective means.

Data breaches presenting high risk trigger notification to authorities within 72 hours and to users when required or appropriate.

Personal information is not sold, distributed, or leased without permission or legal requirement.

7. What Are My Rights in Respect of the Personal Data You Hold?

Users may request:

• Access: receive data copies and verify lawful processing.
• Correction: rectify incomplete or inaccurate information.
• Erasure: delete data where processing lacks justification or upon exercising objection rights.
• Restriction: suspend processing during accuracy disputes or legal claims.
• Portability: receive data in structured, machine-readable formats for transfer to other controllers.
• Objection: contest processing based on legitimate interests (company must cease unless overriding grounds exist).
• Automated Decision-Making Objection: request human intervention for solely automated decisions with significant effects.
• Consent Withdrawal: withdraw consent at any time (affecting future processing only).

Exercise rights or ask questions by emailing support@kotcha.com.

8. What Is Your Policy Regarding Children?

Services are not intended for individuals under 18 years old. Technical measures prevent account creation by minors. The company does not knowingly collect data from children under 18 and will delete information, terminate accounts, and restrict access upon discovering such collection.

Parents aware of child data collection should contact the company.

9. How Can I Contact You?

For questions or concerns regarding this Privacy Policy and data handling security, contact support@kotcha.com. The Data Protection Officer is reachable at the same email address.