Effective Date
29 April 2026
Version
Version 1.0
By creating an account or using our services, you confirm that you have read and understood this policy.
LODE Fitness Ltd ("LODE", "we", "us", "our") is a company incorporated in England and Wales (registered address: 7 Simpson Street, London SW11 3HN). We operate the LODE Fitness mobile application (the "App") and the website lodefitness.com (the "Site").
We are the data controller for the personal data described in this Privacy Policy, and are registered with the Information Commissioner's Office (ICO) as a data controller. LODE Fitness Ltd does not meet the threshold requiring a mandatory Data Protection Officer under UK GDPR Article 37. However, we have designated a privacy contact responsible for data protection matters. If you have any questions or concerns, you can contact our privacy team at privacy@lodefitness.com.
This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the LODE App or Site. It also explains your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Please read this policy carefully before using the App or Site.
We process your data to:
Lawful basis: performance of a contract (UK GDPR Article 6(1)(b)) - it is necessary to provide you with the services you have subscribed to.
We use aggregated, anonymised usage data to analyse how users interact with the App, identify bugs or usability issues, and improve our algorithms and features. No individually identifiable data is used for this purpose.
Lawful basis: legitimate interests (UK GDPR Article 6(1)(f)).
We may contact you by email or push notification to:
Lawful basis: contract performance (UK GDPR Article 6(1)(b)) for essential service notifications; consent (Article 6(1)(a)) for optional alerts and marketing communications.
Push notifications require your consent under the Privacy and Electronic Communications Regulations (PECR) and UK GDPR. You will be asked for this consent when you first install the App. You can manage your notification preferences at any time via your Profile Settings in the App.
We may process your data where required to comply with a legal obligation (UK GDPR Article 6(1)(c)), for example in response to a lawful request from a regulatory authority.
Data relating to your health (including heart rate, training load, injury history, and biometric information derived from wearable devices) constitutes special category data under UK GDPR Article 9. We process this data only on the basis of your explicit consent (Article 9(2)(a)), which you provide when you connect your Garmin account and set up your profile.
You may withdraw this consent at any time in two ways: (1) via your Profile Settings in the App, where you can disconnect your wearable integration and stop health data processing without deleting your account; or (2) by deleting your account entirely.
Withdrawing consent for health data processing will disable core App features that depend on that data. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to withdrawal.
We share your data with trusted third-party service providers who process data on our behalf, including:
All third-party processors are bound by data processing agreements and are required to process data only on our instructions and in accordance with UK GDPR.
When you connect your Garmin account, your activity data is routed to LODE via Terra using the Garmin Health API. Garmin's own privacy policy governs their handling of your data on their platform. We recommend reviewing Garmin's privacy policy. Your health data is not shared with any other party and does not leave the LODE platform once received.
We may disclose your personal data if required to do so by law, court order, or at the request of a government or regulatory authority. We will notify you of any such disclosure where legally permitted to do so.
If LODE Fitness Ltd is involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.
We do not sell, rent, or trade your personal data to third parties for marketing or commercial purposes.
We aim to process and store your data within the UK or EEA. Where any transfer outside these regions is necessary (for example, to a third-party service provider), we ensure appropriate safeguards are in place, such as UK standard contractual clauses or an adequacy decision, in accordance with UK GDPR Chapter 5.
We retain different categories of your data for different periods:
| Data Category | Retention Period |
|---|---|
| Account and profile data | Duration of account + 30 days after closure |
| Training and health data | Duration of account + 30 days after closure |
| App usage and diagnostic logs | Maximum 12 months |
| Communications (support emails, messages) | 3 years from communication date |
| Financial and billing records | 7 years (HMRC requirement) |
Anonymised, aggregated data derived from your usage (from which you cannot be identified) may be retained indefinitely for research and service improvement purposes.
The LODE App uses automated processing to generate personalised outputs. This processing works as follows:
This constitutes automated processing under UK GDPR Article 22. However, it does not constitute solely automated decision-making that produces legal or similarly significant effects because: (a) the outputs are guidance-based, not binding; (b) you retain full discretion over whether to follow any suggested plan; and (c) no decision is made about you by LODE that carries legal weight or significantly affects your rights.
A Data Protection Impact Assessment (DPIA) has been conducted in accordance with UK GDPR Article 35.
Under UK GDPR, you have the following rights in relation to your personal data:
To exercise any of these rights, please contact us at privacy@lodefitness.com. We will respond within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
Our website (lodefitness.com) uses cookies and similar technologies. Full details of every cookie we use, their purpose, duration, and the legal basis for each are set out in our standalone Cookie Policy.
The App itself does not use browser cookies. Analytics within the App use anonymised identifiers only.
The LODE App is not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child under 16, please contact us at privacy@lodefitness.com and we will delete it promptly.
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it from unauthorised access, disclosure, alteration, or destruction. These measures include encryption in transit (TLS) and at rest, access controls, and regular security reviews.
No method of data transmission or storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the ICO in accordance with our legal obligations.
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or via an in-app notification at least 14 days before the changes take effect. The updated policy will always be available on our website at lodefitness.com/privacy.
Your continued use of the App or Site after the effective date of any changes constitutes your acceptance of the updated policy.
Privacy Contact / Data Protection Lead