This policy explains how The Aquatic Coach handles personal and health-related coaching data under the EU General Data Protection Regulation (GDPR).
1. Who we are
Business name: The Aquatic Coach
Data controller: Andy Astfalck
Address: Vaartweg 107, 1217 SM Hilversum, Netherlands
KVK: 61356751 · BTW: NL002517921B21
Contact: andyastfalck@gmail.com
Because coaching requires analysis of training and recovery, we process special category data (health and biometrics) such as heart rate, power, pace, sleep, and wellness metrics. We only do this with appropriate legal safeguards.
2. Data we collect
Standard personal data
- Name, email, phone, and messaging handles (Telegram or WhatsApp if you use them)
- Information from application and onboarding forms
- Billing details when applicable
- Coaching correspondence and programme preferences
Health and biometric data (with explicit consent)
- Activities, power, heart rate, pace, cadence, and session summaries
- Wellness and recovery metrics (sleep, HRV, subjective readiness where recorded)
- Physiological benchmarks and derived coaching analyses
- Plans, compliance records, race results, and AI-assisted coaching summaries
Data may come from devices and platforms you connect (e.g. Garmin, Strava) via Intervals.icu, or from information you provide directly.
This website
The marketing site is static HTML with no tracking cookies by default. Application messages are sent via your email client to us — we do not store them in a third-party form database unless we tell you otherwise.
3. Lawful basis
- Contract — delivering coaching you signed up for
- Legal obligation — tax and invoicing records
- Explicit consent (Art. 9 GDPR) — biometric and health data for performance coaching
We do not rely on “legitimate interest” alone for special category health data. You will be asked for clear consent in onboarding before biometric tracking begins. You may withdraw consent at any time, though that may limit the analytics we can provide.
4. How we use data
To prescribe and adjust training, review sessions, monitor load and recovery, communicate about your programme, and meet legal obligations. We do not sell your data.
5. Third-party processors
We share data only with providers that help operate coaching, under appropriate agreements:
- Intervals.icu — training plans, activities, wellness sync
- Google Workspace / Google Drive — coach workspace sync and email
- Google Gemini — AI-assisted coaching summaries (task-limited data only)
- Garmin / Strava / device vendors — source data via your connections
- Open-Meteo — weather context (approximate location/time only)
- Vercel — hosts this public website (static pages only)
- Cloudflare (when enabled) — secure access for the athlete portal
- Payment processors (e.g. Stripe, when used) — subscriptions and invoices
Some providers process data outside the EEA (including the US). We rely on their GDPR terms, adequacy decisions, or Standard Contractual Clauses where required.
6. Security
- Coaching data accessible only to the coach
- API keys and credentials stored separately from public systems
- Password-protected devices, encryption where supported, two-factor authentication on cloud accounts
- Data minimisation and privacy impact assessments for high-risk biometric processing
We will notify you and the Dutch supervisory authority (Autoriteit Persoonsgegevens) of a breach where legally required.
7. Retention
- Coaching and biometric data — for your coaching relationship, then deleted or anonymised within a reasonable period after termination
- Financial records — as required by Dutch tax and KVK law (typically up to seven years)
- Marketing enquiries — only as long as needed to respond
8. Your rights
Under the GDPR you may request access, rectification, erasure, restriction, portability, or object to certain processing. You may withdraw consent at any time.
Contact andyastfalck@gmail.com — we respond within one month. You can also manage device data in Intervals.icu, Garmin Connect, or similar platforms.
Complaints: Autoriteit Persoonsgegevens (AP), Netherlands.
9. Cookies
No tracking or analytics cookies by default. Our host may use essential technical cookies for delivery and security. If analytics are added later, this section will be updated.
10. Changes
We update this policy when services or legal requirements change. Material changes for existing athletes will be communicated directly.
11. Contact
The Aquatic Coach · Andy Astfalck
Vaartweg 107, 1217 SM Hilversum, Netherlands
KVK 61356751 · BTW NL002517921B21
andyastfalck@gmail.com ·
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