Privacy Policy
Last updated: April 15, 2026
ТрейнЕриа ЕООД ("Company", "we", "us"), VAT ID: BG203549497, operates Objective Numbers Coaching. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our Service.
1. Data Controller
ТрейнЕриа ЕООД, ул. 27ми Юли 28, ет. 1, ап. 1 (офис 1), Варна 9000, Bulgaria. Contact: [email protected]
2. Data We Collect
Account Data: email address, password (stored as a one-way hash — we cannot read your password), display name.
Coaching Conversation Data: text messages, email exchanges, and transcripts of live video sessions with the AI coaching companion. This data is essential to provide personalized coaching and conversation continuity across sessions.
Technical Data: IP address, browser type and version, operating system, device type, browser language. Collected automatically when you use the Service.
Geolocation Data: approximate location derived from your IP address (country, city level). We do not use GPS or precise location tracking.
Payment Data: payment processing is handled entirely by Stripe, Inc. We do not store your credit card number, CVV, or full card details. We store only: Stripe customer ID, subscription status, billing amounts, and payment dates.
Profile Images: if you use live video coaching, a profile image may be generated from your webcam feed using AI. This image is stored locally on our servers and used only as your chat avatar.
3. How We Use Your Data
We use your data to: provide and personalize the coaching service; maintain conversation context across sessions and modalities (video, text, email); process payments and manage subscriptions; send transactional emails (confirmation, receipts); detect and prevent fraud, abuse, and unauthorized access; improve the Service.
4. Legal Basis for Processing (GDPR)
Contract performance: processing your account, conversations, and payments is necessary to deliver the Service you subscribed to.
Legitimate interests: security monitoring, fraud prevention, and service improvement.
Consent: where required by law, such as for optional marketing communications (we currently do not send marketing emails).
5. Third-Party Services
We share data with the following third parties, strictly for service delivery:
Stripe, Inc. (San Francisco, USA) — payment processing. Stripe processes your payment card data under their own privacy policy. stripe.com/privacy
Anthropic, PBC (San Francisco, USA) — AI language model provider for text and email coaching. Your conversation text is sent to Anthropic's API for response generation. Anthropic does not use API data to train models. anthropic.com/privacy
Google LLC (Mountain View, USA) — AI model provider for live video coaching (Gemini) and avatar generation. Video frames and audio are processed in real-time. policies.google.com/privacy
LiveKit, Inc. — real-time video and audio infrastructure for live coaching sessions. livekit.io/privacy
Sinch (Mailgun) — email delivery for transactional emails and email coaching. sinch.com/privacy-notice
Cloudflare, Inc. — CDN, DDoS protection, and DNS. cloudflare.com/privacypolicy
We do not sell your data to any third party. We do not use your data for advertising.
6. Data Storage and Security
Your data is stored on dedicated servers located in the European Union (Strasbourg, France). We implement the following security measures: encrypted connections (TLS/HTTPS) for all data in transit; passwords hashed with BCrypt; authenticated API access with HMAC-signed tokens; rate limiting and bot protection on all endpoints.
7. Data Retention
We retain your data for as long as your account is active. If you delete your account, your personal data and conversation history will be deleted within 30 days, except where retention is required by law (e.g., financial records under Bulgarian accounting law: 5 years).
8. Your Rights (GDPR)
If you are in the European Economic Area, you have the right to: access your personal data; rectify inaccurate data; erase your data ("right to be forgotten"); restrict processing; data portability (receive your data in a structured format); object to processing; withdraw consent at any time; lodge a complaint with a supervisory authority (Commission for Personal Data Protection, Bulgaria).
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
9. Cookies
We use essential cookies only — session cookies required for authentication and the functioning of the Service. We do not use advertising or tracking cookies. No cookie consent banner is required for essential-only cookies under GDPR.
10. Children
The Service is not intended for anyone under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, contact us immediately.
11. International Data Transfers
Some of our third-party providers are based in the United States. Data transfers to the US are covered by the EU-US Data Privacy Framework, Standard Contractual Clauses (SCCs), or equivalent safeguards as required by GDPR.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via email. The "Last updated" date at the top indicates when the policy was last revised.
13. Contact
ТрейнЕриа ЕООД
ул. 27ми Юли 28, ет. 1, ап. 1 (офис 1)
Варна 9000, Bulgaria
VAT ID: BG203549497
Email: [email protected]