Privacy Policy

Digital Sport Solutions Pte Ltd

Last updated: July 2026

1. Definitions

For the purposes of this Privacy Policy:

• "Company" means Digital Sport Solutions Pte Ltd, a company incorporated in Singapore.
• "Services" means the Periodization App, related websites, software, platforms, and services operated by the Company.
• "Personal Data" has the meaning given under the PDPA and GDPR.
• "Sensitive Data" or "Special Category Data" includes health-related, injury-related, and wellness-related data.
• "User" means any individual accessing or using the Services, including coaches, athletes, parents, and organizational representatives.
• "Processing" has the meaning given under GDPR Article 4.

2. Data Controller

The data controller responsible for Processing Personal Data is:

3. Applicability

This Privacy Policy applies to all Processing of Personal Data carried out by the Company in connection with the Services, regardless of the User's location, subject to applicable law.

4. Categories of Personal Data

4.1 Identification and Contact Data

• name;
• email address;
• age or date of birth;
• gender.

4.2 Sport, Performance, and Training Data

• training plans, sessions, loads, and volumes;
• competition data and performance metrics;
• wellness and self-report questionnaires.

4.3 Health and Sensitive Data

• injury indicators;
• illness, soreness, fatigue, recovery, or readiness markers.

4.4 Technical and Usage Data

• IP addresses;
• device identifiers;
• browser and operating system information;
• cookies and analytics data.

5. Special Category Data and Explicit Consent

Certain data processed through the Services may constitute Special Category Data under GDPR Article 9.

By using the Services and submitting such data, the User:

• provides explicit consent to the Processing of such data;
• acknowledges that such Processing is necessary for performance analysis and monitoring purposes;
• confirms that they are either (i) eighteen (18) years of age or older, or (ii) creating or using an account with the knowledge, consent, and supervision of a parent, legal guardian, coach, or affiliated organization who accepts responsibility for the User's data on their behalf, as confirmed at account creation.

5A. Minors and Age Confirmation

The Services are intended for use by coaches, organizations, and athletes of any age, but self-registration through the sign-up flow requires the registrant to confirm they are 18 or older, or that their account is being created with parental, guardian, or club/organizational authorization. Where an athlete under 18 is added to the Services by a coach or organization rather than self-registering, that coach or organization is responsible for ensuring appropriate parental or guardian consent has been obtained under applicable law. The Company does not knowingly collect Personal Data directly from children through open self-registration without such confirmation.

6. Lawful Bases for Processing

The Company processes Personal Data based on one or more of the following lawful bases:

• consent (including explicit consent for Sensitive Data);
• necessity for performance of a contract;
• legitimate interests pursued by the Company;
• compliance with legal obligations.

7. Purposes of Processing

Personal Data is processed for the purposes of:

• providing and operating the Services;
• enabling training planning, monitoring, and reporting;
• facilitating coach–athlete–organization workflows;
• generating AI-assisted analytical insights;
• maintaining security, integrity, and availability of the Services;
• research, analytics, and service improvement (including anonymized data).

8. Artificial Intelligence and Automated Processing

The Services may use algorithmic, rule-based, and — where introduced — artificial intelligence processing to analyse User-provided data. Where AI-specific features are not yet active, this Section applies prospectively to any such features when introduced.

The User expressly acknowledges that:

• AI outputs are non-diagnostic, non-medical, and advisory only;
• AI outputs may be incomplete, inaccurate, or context-dependent;
• no automated decision-making producing legal or similarly significant effects is performed;
• all decisions remain the responsibility of the User or supervising professional.

9. Disclosure to Third Parties

Personal Data may be disclosed to the following categories of service providers, each acting under appropriate data processing terms:

• cloud infrastructure and database hosting (Google Firebase / Google Cloud Platform);
• website and application hosting (Netlify);
• payment processing, where subscription features are active (e.g., Stripe);
• analytics and monitoring providers, where enabled;
• professional advisers, regulators, or authorities where required by law.

The Company does not sell Personal Data.

9A. Mobile App Distribution

Where the Services are made available through Apple's App Store or Google Play, those platforms may independently collect device- and usage-level data under their own respective privacy policies (Apple Privacy Policy, Google Privacy Policy), separate from and in addition to this Privacy Policy. The Company does not receive payment or subscription details processed through in-app purchase mechanisms, as the Services are not currently sold via in-app purchase.

10. Cross-Border Transfers

Personal Data may be transferred outside the User's jurisdiction. Appropriate safeguards are implemented in accordance with GDPR and PDPA requirements.

11. Data Retention

Personal Data is retained only as long as necessary for the purposes described herein, unless longer retention is required by law.

The Company may anonymize data for long-term statistical or research use.

12. Data Subject Rights

Users have the right to:

• access;
• rectification;
• erasure;
• restriction of processing;
• objection to processing;
• data portability (where applicable);
• withdrawal of consent.

Requests may be submitted to adaoffice@adasports.tech.

13. Security

The Company implements reasonable administrative, technical, and organizational safeguards. However, no system can be guaranteed to be fully secure.

14. Cookies and Tracking

Cookies and similar technologies are used for authentication, analytics, and service optimization.

15. Amendments

This Privacy Policy may be amended at any time. Continued use of the Services constitutes acceptance.