PRIVACY POLICY

TroponinIQ.com Privacy Policy

Type of website: AI Coaching Software (SaaS)

Effective date: 16th day of March, 2026

---

TroponinIQ.com (the "Site") is owned and operated by Cymbal Group LLC. Cymbal Group LLC is the data controller and can be contacted at:

support@troponiniq.com

8480 N. 32nd St.

Unit 101

Richland, MI 49083

---

Purpose

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:

1. The personal data we will collect;
2. Use of collected data;
3. Who has access to the data collected;
4. How we handle AI-processed data;
5. The rights of Site users; and
6. The Site's cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.

---

GDPR

For users in the European Union, we adhere to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

---

Consent

By using our Site, users agree that they consent to the conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by: contacting us via email at support@troponiniq.com or by canceling your subscription through your account settings.

---

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR. We rely on the following legal bases to collect and process the personal data of users in the EU:

1. Users have provided their consent to the processing of their data for one or more specific purposes;
2. Processing of user personal data is necessary for the performance of a contract (i.e., providing our AI coaching service); and
3. Processing of user personal data is necessary for us to comply with a legal obligation.

---

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically

When you visit and use our Site, we may automatically collect and store the following information:

1. IP address;
2. Location;
3. Browser type and device information;
4. Clicked links; and
5. Content viewed.

Data Collected When You Create an Account or Use Our Service

We may also collect the following data when you register for an account, subscribe to our service, or interact with our AI coaching system:

1. First and last name;
2. Email address;
3. Payment information (processed securely through Stripe — we do not store full credit card numbers);
4. Subscription and billing history;
5. Conversation and chat data submitted to the AI coaching system;
6. Health, fitness, nutrition, and physique-related information you provide during coaching interactions; and
7. Photos or images you upload for physique assessment or progress tracking.

This data is collected through: account registration forms, subscription checkout (via Stripe), and direct interaction with the AI coaching interface.

---

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

1. Improving site performance and user experience; and
2. Understanding usage patterns to improve our service.

The data we collect when you use our AI coaching service is used for the following purposes:

1. Providing personalized AI-powered nutrition, training, and coaching guidance;
2. Processing your subscription payments;
3. Improving the quality and accuracy of our AI coaching system; and
4. Communicating with you about your account or service updates.

Important note on AI-processed data: When you interact with our AI coaching system, your conversation data (including any health, nutrition, training, or physique information you share) is processed by our AI model to generate coaching responses. This data is used solely to provide and improve the coaching service. We do not sell your conversation data or use it for advertising purposes.

---

Who We Share Personal Data With

Employees

We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Service Providers

We use the following third-party service providers who may process your data on our behalf:

1. Stripe — for secure payment processing;
2. Anthropic — as the AI model provider that processes conversation data to deliver coaching responses; and
3. Vercel — for website hosting and delivery.

These providers process data only as necessary to perform their services and are bound by their own privacy policies and data protection obligations.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

1. If the law requires it;
2. If it is required for any legal proceeding;
3. To prove or protect our legal rights; and
4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another site, please note that we are not responsible for and have no control over their privacy policies and practices.

---

How Long We Store Personal Data

User data will be stored for as long as your account remains active or as needed to provide you with our services. If you cancel your subscription and request account deletion, your personal data will be deleted within 30 days, except where we are required by law to retain it.

Anonymized and aggregated data that cannot identify you may be retained indefinitely for service improvement purposes.

---

How We Protect Your Personal Data

We take the security of your data seriously and implement the following measures:

1. All data transmitted between your browser and our servers is encrypted using TLS/SSL;
2. Payment data is handled entirely by Stripe and is never stored on our servers;
3. Access to user data is restricted to authorized personnel only; and
4. We conduct regular reviews of our data handling practices.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains some risk. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

---

Your Rights as a User

Under the GDPR, you have the following rights:

1. Right to be informed;
2. Right of access;
3. Right to rectification;
4. Right to erasure;
5. Right to restrict processing;
6. Right to data portability; and
7. Right to object.

For California residents: Under the California Consumer Privacy Act (CCPA), you have the right to know what personal data we collect, request deletion of your data, and opt out of the sale of your data. We do not sell personal data.

---

Children

We do not knowingly collect or use personal data from children under 16 years of age. Our AI coaching service is intended for adults. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data, their parent or guardian may contact us using the information below.

---

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to whom we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR or CCPA, please contact us at:

support@troponiniq.com

8480 N. 32nd St., Unit 101

Richland, MI 49083

---

Do Not Track Notice

Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not track the users of our Site over time and across third-party websites and therefore do not respond to browser-initiated DNT signals.

---

Cookie Policy

A cookie is a small file stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

1. Functional cookies — used to remember your selections and preferences (such as login status) so that they are saved for your next visit;
2. Analytical cookies — used to improve the design and functionality of our Site by collecting data on how you access and use our Site, such as content you access and how long you stay; and
3. Authentication cookies — used to manage your logged-in session and ensure secure access to your coaching account.

---

Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

---

Complaints

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner, you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority in your jurisdiction.

---

Contact Information

If you have any questions, concerns, or complaints, you can contact TroponinIQ at:

support@troponiniq.com

8480 N. 32nd St., Unit 101

Richland, MI 49083