{"roots":["20:474"],"nodeById":{"20:474":{"type":"WEBPAGE","id":"20:474","name":"/privacy","absoluteBoundingBox":{"x":2017.0,"y":0.0,"width":2711.0,"height":8177.0},"isolatedAbsoluteRenderBounds":{"x":2017.0,"y":0.0,"width":2711.0,"height":8177.0},"relativeTransform":[[1.0,0.0,2017.0],[0.0,1.0,0.0]],"size":{"x":2711.0,"y":8177.0},"fills":[{"opacity":0.298039227724075,"blendMode":"NORMAL","type":"SOLID","color":{"r":1.0,"g":1.0,"b":1.0,"a":1.0},"visible":true}],"strokeAlign":"INSIDE","strokes":[],"accessibleHTMLTag":"AUTO","isDecorativeImage":false,"ariaAttributes":{},"interactions":[],"children":["20:475","20:503","20:531"]},"20:531":{"type":"FRAME","id":"20:531","name":"Mobile","absoluteBoundingBox":{"x":4289.0,"y":100.0,"width":375.0,"height":8013.0},"isolatedAbsoluteRenderBounds":{"x":4289.0,"y":100.0,"width":375.0,"height":8013.0},"relativeTransform":[[1.0,0.0,2272.0],[0.0,1.0,100.0]],"size":{"x":375.0,"y":8013.0},"fills":[{"blendMode":"NORMAL","type":"SOLID","color":{"r":1.0,"g":1.0,"b":1.0,"a":1.0},"visible":true,"opacity":1.0}],"strokeAlign":"INSIDE","strokes":[],"effects":[],"accessibleHTMLTag":"AUTO","isDecorativeImage":false,"ariaAttributes":{},"interactions":[],"clipsContent":true,"overflowDirection":"VERTICAL_SCROLLING","layoutMode":"VERTICAL","counterAxisAlignItems":"CENTER","counterAxisSizingMode":"FIXED","isBreakpointFrame":true,"children":["20:567","20:532"]},"20:544":{"type":"TEXT","id":"20:544","name":"Privacy Policy of Neutom Last Updated: January 13, 2026 At Neutom your privacy and data security are non-negotiable pillars. This Privacy Policy details how we collect, use, store, protect, and manage the information you provide when using our cycling data analysis platform. Our commitment is to transparency, integrity, and your complete control over your data. We do not share your personal or performance data with third parties for commercial purposes, and you have full autonomy to manage your data at any time. 1. Who Are We? We are a platform specialized in providing in-depth performance analysis and training insights for endurance athletes. We use data from cycling computers (such as Garmin, Wahoo, etc.) to transform your training data into actionable information. Our goal is to empower you to achieve your best results, based on concrete data, precise analysis, and with the utmost security and privacy. 2. Data We Collect To operate and provide our performance analysis services, we collect the following categories of data, always with your explicit and informed consent: Identification and Contact Data: Registration Information: Your full name, email address, and an encrypted password for secure platform access. Profile Information: Data you voluntarily add to your profile, such as date of birth, weight, height, gender, cyclist type (road, MTB), training zones (FTP, heart rate thresholds), which are crucial for personalizing analyses and training metrics. Purpose: Account management, experience personalization, and direct communication. Cycling Performance Data: Activity Files: Primarily through the upload of files generated by cycling computers and third-party applications (e.g., .fit, .gpx, .tcx from Garmin, Wahoo, Strava, etc.). These files are the backbone of our analyses and contain a wealth of information, including: Location Data (GPS): Route covered, geographical coordinates, speed, distance, elevation (gain/loss). Physiological Data: Heart rate (average, maximum, zones), cadence, body temperature (if available from sensor). Power Data: Watts (average, maximum, normalized – NP), Intensity Factor (IF), Training Stress Score (TSS), power balance (if available). Equipment Data: Information about the bicycle used, connected sensors (power meter, GPS, HR monitor). Environmental Data: Ambient temperature, barometric pressure (if captured by the device). Purpose: Conducting detailed performance analyses, monitoring progress, identifying training trends, calculating specific metrics, and generating personalized reports. Training Data and Goals: Manual Information: Data you directly enter into the platform about your training plans, short and long-term goals, specific equipment, health status, and any relevant observations about your sessions. Purpose: To contextualize and enrich performance analyses, allowing for more precise feedback aligned with your goals. Platform Usage Data: Platform Interaction: Information about how you navigate and use our features (pages visited, functionalities accessed, session duration, clicks, etc.). We collect this through cookies and similar technologies. Technical Data: IP address, browser type, operating system, device IDs. Purpose: To improve platform usability, identify and correct errors, optimize performance, and develop new features, always aiming to enhance your experience. This data is often collected in an anonymized and aggregated manner, when possible, to avoid individual identification. 3. How We Use Your Data Your data is used strictly for the purposes for which it was collected, always with the aim of optimizing your performance and your experience on the platform: To Provide and Personalize Our Essential Services: Analyze your cycling data to generate detailed performance reports (e.g., power zones, cadence distribution, elevation analysis). Identify training trends and progress over time (e.g., FTP increase, endurance improvement). Offer personalized feedback and training recommendations based on your data and goals. Visualize your routes and activity maps. To Improve the Platform and User Experience: Use usage data (anonymized and aggregated) to understand how users interact with the platform, identify bottlenecks, and enhance existing functionalities or develop new ones. For example, if many users click on a certain button, it may indicate the need to optimize that function. Direct and Relevant Communication: Send notifications about your performance, such as weekly summaries or new personal best alerts via email or in-platform. Communicate important platform updates, new features, or changes to the Privacy Policy. Provide training tips, relevant articles, and information that may assist your goals, always with an opt-out option for marketing communications. Customer Support and Troubleshooting: To answer your questions, resolve technical issues, and provide necessary support efficiently and effectively. 4. No Data Sharing with Third Parties This is a fundamental and non-negotiable premise of our platform: We do not share, sell, rent, trade, or disclose your personal or performance data with third-party companies for marketing, advertising, market research, or any other commercial purpose. Your data is yours and remains under our control. Your data is processed and stored on our secure servers, or in third-party cloud computing services (sub-processors) that operate strictly under our instructions and are bound by stringent confidentiality and data protection agreements. These sub-processors are not permitted to use your data for their own purposes or for any purpose other than to help us provide the service to you. Limited Exceptions (only if strictly necessary and legally justifiable): We may be required to disclose your personal data in response to valid and binding legal processes, such as court orders, subpoenas, warrants, or to comply with applicable laws and regulations. This may also occur when we believe in good faith that disclosure is necessary to: Protect our legal rights, property, or safety, or the safety of our users or the public. Investigate fraudulent or illegal activities. Respond to a legitimate governmental request. Protect your vital interests or those of another natural person. 5. Your Full Control and Rights Over Your Data You have full control over your data at [Your Coaching/Platform Name] and can exercise your rights at any time. We guarantee the following rights, in accordance with applicable data protection laws (such as LGPD in Brazil and GDPR in Europe): Access and Data Portability: You can access, view, and download your own performance data (including original cycling computer files, such as .fit, .gpx, .tcx) at any time through your account's dashboard or settings section on the platform. This allows you to take your data to another service if you wish. Right to Rectification: You can edit and update your personal and profile information (e.g., weight, FTP, email) directly in your account settings, ensuring your data is always accurate and up-to-date. Right to Erasure (Right to Be Forgotten): You have the right to request the deletion of all your personal and performance data from our systems. Upon requesting deletion, all your data will be permanently removed from our active systems and backups, with the exception of data we are legally obligated to retain for a certain period (e.g., tax records, security audit logs). The deletion process may take up to7 business-days to be completed across all our systems and backups. Right to Withdraw Consent: You can review and change your consent preferences for data collection and use at any time, especially for marketing communications. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal. Right to Object to Processing: You can object to certain processing of your data if there are legitimate reasons related to your particular situation, or in cases of profiling and direct marketing. Right to Restriction of Processing: You can request the restriction of processing of your data under certain circumstances, such as when the accuracy of the data is contested by you, or when processing is unlawful, but you object to deletion. Right to Lodge a Complaint with a Supervisory Authority: You have the right to file a complaint with a competent data protection authority in your country if you believe your privacy rights have been violated. To exercise any of these rights, access your account settings or contact us through the channels indicated in Section 9. Our goal is to respond to all legitimate requests within 48 hours. 6. Data Security We employ robust and state-of-the-art technical, administrative, and organizational security measures to protect your data against unauthorized access, alteration, disclosure, accidental or unlawful destruction. Our security practices include, but are not limited to: Encryption: All data in transit between your browser and our servers is protected by TLS/SSL (Transport Layer Security/Secure Sockets Layer) encryption. Data at rest (stored) is also encrypted using standards such as AES-256. Strict Access Controls: We implement Role-Based Access Control (RBAC) to ensure that only authorized personnel have access to data, and only to the extent necessary to perform their duties. Multi-Factor Authentication (MFA): For internal access to our systems and, if available, for user access to the platform, to add an extra layer of security. Continuous Monitoring: Our systems are monitored 24/7 to detect and prevent suspicious activities or unauthorized access attempts. Security Audits: We conduct regular security audits and penetration testing to identify and mitigate vulnerabilities. Regular Backups: We maintain data backups to ensure recovery in case of failures, protecting against data loss. Anonymization and Pseudonymization: Where appropriate and technically feasible, we apply anonymization and pseudononymization techniques to protect data identity. Incident Response Plan: We have a security incident response plan to act quickly and mitigate any data breaches, notifying authorities and affected users as required by law. 7. Data Retention Your performance data and personal information are retained as long as your account is active on Neutom and as long as necessary to provide the requested services, fulfill legal obligations, or resolve disputes. Active Accounts: We retain your data so you can access your training history and ongoing analyses. Account Deletion: If you choose to delete your account or request data deletion, it will be removed from our active systems and backups as described in the \"Your Full Control and Rights Over Your Data\" section. The permanent deletion process aims to remove all identifiable data. Legal Obligations: In some situations, we may be required to retain certain data for a longer period to comply with legal, regulatory, tax obligations, or for auditing purposes. In such cases, the data will be stored securely and isolated, with restricted access, only for the time required by law. 8. Changes to This Privacy Policy We may update our Privacy Policy periodically to reflect changes in our data practices, new platform functionalities, or for legal and regulatory reasons. We will notify you of any significant changes through your account, via email, or by a prominent notice on our platform before the changes take effect. We advise you to review this Policy regularly to stay informed about how we protect your information. Continued use of the platform after the publication of a revised Privacy Policy implies your acceptance of the new terms. 9. Contact If you have any questions about this Privacy Policy, our data practices, or wish to exercise any of your rights, please contact us via: Email: neutomapp@gmail.com","absoluteBoundingBox":{"x":4313.0,"y":368.0,"width":327.0,"height":7705.0},"isolatedAbsoluteRenderBounds":{"x":4313.32958984375,"y":372.818176269531,"width":326.134765625,"height":7674.63623046875},"relativeTransform":[[1.0,0.0,0.0],[0.0,1.0,0.0]],"size":{"x":327.0,"y":7705.0},"fills":[{"opacity":0.550000011920929,"blendMode":"NORMAL","type":"SOLID","color":{"r":0.0,"g":0.0,"b":0.0,"a":1.0},"visible":true}],"strokeAlign":"OUTSIDE","layoutAlign":"STRETCH","strokes":[],"effects":[],"accessibleHTMLTag":"AUTO","isDecorativeImage":false,"ariaAttributes":{},"interactions":[],"characterStyleOverrides":[],"characters":"Privacy Policy of Neutom\nLast Updated: January 13, 2026\nAt Neutom your privacy and data security are non-negotiable pillars. This Privacy Policy details how we collect, use, store, protect, and manage the information you provide when using our cycling data analysis platform. Our commitment is to transparency, integrity, and your complete control over your data.\nWe do not share your personal or performance data with third parties for commercial purposes, and you have full autonomy to manage your data at any time.\n1. Who Are We?\nWe are a platform specialized in providing in-depth performance analysis and training insights for endurance athletes. We use data from cycling computers (such as Garmin, Wahoo, etc.) to transform your training data into actionable information. Our goal is to empower you to achieve your best results, based on concrete data, precise analysis, and with the utmost security and privacy.\n2. Data We Collect\nTo operate and provide our performance analysis services, we collect the following categories of data, always with your explicit and informed consent:\nIdentification and Contact Data:\nRegistration Information: Your full name, email address, and an encrypted password for secure platform access.\nProfile Information: Data you voluntarily add to your profile, such as date of birth, weight, height, gender, cyclist type (road, MTB), training zones (FTP, heart rate thresholds), which are crucial for personalizing analyses and training metrics.\nPurpose: Account management, experience personalization, and direct communication.\nCycling Performance Data:\nActivity Files: Primarily through the upload of files generated by cycling computers and third-party applications (e.g., .fit, .gpx, .tcx from Garmin, Wahoo, Strava, etc.). These files are the backbone of our analyses and contain a wealth of information, including:\nLocation Data (GPS): Route covered, geographical coordinates, speed, distance, elevation (gain/loss).\nPhysiological Data: Heart rate (average, maximum, zones), cadence, body temperature (if available from sensor).\nPower Data: Watts (average, maximum, normalized – NP), Intensity Factor (IF), Training Stress Score (TSS), power balance (if available).\nEquipment Data: Information about the bicycle used, connected sensors (power meter, GPS, HR monitor).\nEnvironmental Data: Ambient temperature, barometric pressure (if captured by the device).\nPurpose: Conducting detailed performance analyses, monitoring progress, identifying training trends, calculating specific metrics, and generating personalized reports.\nTraining Data and Goals:\nManual Information: Data you directly enter into the platform about your training plans, short and long-term goals, specific equipment, health status, and any relevant observations about your sessions.\nPurpose: To contextualize and enrich performance analyses, allowing for more precise feedback aligned with your goals.\nPlatform Usage Data:\nPlatform Interaction: Information about how you navigate and use our features (pages visited, functionalities accessed, session duration, clicks, etc.). We collect this through cookies and similar technologies.\nTechnical Data: IP address, browser type, operating system, device IDs.\nPurpose: To improve platform usability, identify and correct errors, optimize performance, and develop new features, always aiming to enhance your experience. This data is often collected in an anonymized and aggregated manner, when possible, to avoid individual identification.\n3. How We Use Your Data\nYour data is used strictly for the purposes for which it was collected, always with the aim of optimizing your performance and your experience on the platform:\nTo Provide and Personalize Our Essential Services:\nAnalyze your cycling data to generate detailed performance reports (e.g., power zones, cadence distribution, elevation analysis).\nIdentify training trends and progress over time (e.g., FTP increase, endurance improvement).\nOffer personalized feedback and training recommendations based on your data and goals.\nVisualize your routes and activity maps.\nTo Improve the Platform and User Experience:\nUse usage data (anonymized and aggregated) to understand how users interact with the platform, identify bottlenecks, and enhance existing functionalities or develop new ones. For example, if many users click on a certain button, it may indicate the need to optimize that function.\nDirect and Relevant Communication:\nSend notifications about your performance, such as weekly summaries or new personal best alerts via email or in-platform.\nCommunicate important platform updates, new features, or changes to the Privacy Policy.\nProvide training tips, relevant articles, and information that may assist your goals, always with an opt-out option for marketing communications.\nCustomer Support and Troubleshooting:\nTo answer your questions, resolve technical issues, and provide necessary support efficiently and effectively.\n4. No Data Sharing with Third Parties\nThis is a fundamental and non-negotiable premise of our platform:\nWe do not share, sell, rent, trade, or disclose your personal or performance data with third-party companies for marketing, advertising, market research, or any other commercial purpose. Your data is yours and remains under our control.\nYour data is processed and stored on our secure servers, or in third-party cloud computing services (sub-processors) that operate strictly under our instructions and are bound by stringent confidentiality and data protection agreements. These sub-processors are not permitted to use your data for their own purposes or for any purpose other than to help us provide the service to you.\nLimited Exceptions (only if strictly necessary and legally justifiable): We may be required to disclose your personal data in response to valid and binding legal processes, such as court orders, subpoenas, warrants, or to comply with applicable laws and regulations. This may also occur when we believe in good faith that disclosure is necessary to:\nProtect our legal rights, property, or safety, or the safety of our users or the public.\nInvestigate fraudulent or illegal activities.\nRespond to a legitimate governmental request.\nProtect your vital interests or those of another natural person.\n5. Your Full Control and Rights Over Your Data\nYou have full control over your data at [Your Coaching/Platform Name] and can exercise your rights at any time. We guarantee the following rights, in accordance with applicable data protection laws (such as LGPD in Brazil and GDPR in Europe):\nAccess and Data Portability:\nYou can access, view, and download your own performance data (including original cycling computer files, such as .fit, .gpx, .tcx) at any time through your account's dashboard or settings section on the platform.\nThis allows you to take your data to another service if you wish.\nRight to Rectification:\nYou can edit and update your personal and profile information (e.g., weight, FTP, email) directly in your account settings, ensuring your data is always accurate and up-to-date.\nRight to Erasure (Right to Be Forgotten):\nYou have the right to request the deletion of all your personal and performance data from our systems. Upon requesting deletion, all your data will be permanently removed from our active systems and backups, with the exception of data we are legally obligated to retain for a certain period (e.g., tax records, security audit logs).\nThe deletion process may take up to7 business-days to be completed across all our systems and backups.\nRight to Withdraw Consent:\nYou can review and change your consent preferences for data collection and use at any time, especially for marketing communications. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal.\nRight to Object to Processing:\nYou can object to certain processing of your data if there are legitimate reasons related to your particular situation, or in cases of profiling and direct marketing.\nRight to Restriction of Processing:\nYou can request the restriction of processing of your data under certain circumstances, such as when the accuracy of the data is contested by you, or when processing is unlawful, but you object to deletion.\nRight to Lodge a Complaint with a Supervisory Authority:\nYou have the right to file a complaint with a competent data protection authority in your country if you believe your privacy rights have been violated.\nTo exercise any of these rights, access your account settings or contact us through the channels indicated in Section 9. Our goal is to respond to all legitimate requests within 48 hours.\n6. Data Security\nWe employ robust and state-of-the-art technical, administrative, and organizational security measures to protect your data against unauthorized access, alteration, disclosure, accidental or unlawful destruction. Our security practices include, but are not limited to:\nEncryption: All data in transit between your browser and our servers is protected by TLS/SSL (Transport Layer Security/Secure Sockets Layer) encryption. Data at rest (stored) is also encrypted using standards such as AES-256.\nStrict Access Controls: We implement Role-Based Access Control (RBAC) to ensure that only authorized personnel have access to data, and only to the extent necessary to perform their duties.\nMulti-Factor Authentication (MFA): For internal access to our systems and, if available, for user access to the platform, to add an extra layer of security.\nContinuous Monitoring: Our systems are monitored 24/7 to detect and prevent suspicious activities or unauthorized access attempts.\nSecurity Audits: We conduct regular security audits and penetration testing to identify and mitigate vulnerabilities.\nRegular Backups: We maintain data backups to ensure recovery in case of failures, protecting against data loss.\nAnonymization and Pseudonymization: Where appropriate and technically feasible, we apply anonymization and pseudononymization techniques to protect data identity.\nIncident Response Plan: We have a security incident response plan to act quickly and mitigate any data breaches, notifying authorities and affected users as required by law.\n7. Data Retention\nYour performance data and personal information are retained as long as your account is active on Neutom and as long as necessary to provide the requested services, fulfill legal obligations, or resolve disputes.\nActive Accounts: We retain your data so you can access your training history and ongoing analyses.\nAccount Deletion: If you choose to delete your account or request data deletion, it will be removed from our active systems and backups as described in the \"Your Full Control and Rights Over Your Data\" section. The permanent deletion process aims to remove all identifiable data.\nLegal Obligations: In some situations, we may be required to retain certain data for a longer period to comply with legal, regulatory, tax obligations, or for auditing purposes. In such cases, the data will be stored securely and isolated, with restricted access, only for the time required by law.\n8. Changes to This Privacy Policy\nWe may update our Privacy Policy periodically to reflect changes in our data practices, new platform functionalities, or for legal and regulatory reasons. We will notify you of any significant changes through your account, via email, or by a prominent notice on our platform before the changes take effect. We advise you to review this Policy regularly to stay informed about how we protect your information. Continued use of the platform after the publication of a revised Privacy Policy implies your acceptance of the new terms.\n9. 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Policy of Neutom Last Updated: January 13, 2026 At Neutom your privacy and data security are non-negotiable pillars. This Privacy Policy details how we collect, use, store, protect, and manage the information you provide when using our cycling data analysis platform. Our commitment is to transparency, integrity, and your complete control over your data. We do not share your personal or performance data with third parties for commercial purposes, and you have full autonomy to manage your data at any time. 1. Who Are We? We are a platform specialized in providing in-depth performance analysis and training insights for endurance athletes. We use data from cycling computers (such as Garmin, Wahoo, etc.) to transform your training data into actionable information. Our goal is to empower you to achieve your best results, based on concrete data, precise analysis, and with the utmost security and privacy. 2. Data We Collect To operate and provide our performance analysis services, we collect the following categories of data, always with your explicit and informed consent: Identification and Contact Data: Registration Information: Your full name, email address, and an encrypted password for secure platform access. Profile Information: Data you voluntarily add to your profile, such as date of birth, weight, height, gender, cyclist type (road, MTB), training zones (FTP, heart rate thresholds), which are crucial for personalizing analyses and training metrics. Purpose: Account management, experience personalization, and direct communication. Cycling Performance Data: Activity Files: Primarily through the upload of files generated by cycling computers and third-party applications (e.g., .fit, .gpx, .tcx from Garmin, Wahoo, Strava, etc.). These files are the backbone of our analyses and contain a wealth of information, including: Location Data (GPS): Route covered, geographical coordinates, speed, distance, elevation (gain/loss). Physiological Data: Heart rate (average, maximum, zones), cadence, body temperature (if available from sensor). Power Data: Watts (average, maximum, normalized – NP), Intensity Factor (IF), Training Stress Score (TSS), power balance (if available). Equipment Data: Information about the bicycle used, connected sensors (power meter, GPS, HR monitor). Environmental Data: Ambient temperature, barometric pressure (if captured by the device). Purpose: Conducting detailed performance analyses, monitoring progress, identifying training trends, calculating specific metrics, and generating personalized reports. Training Data and Goals: Manual Information: Data you directly enter into the platform about your training plans, short and long-term goals, specific equipment, health status, and any relevant observations about your sessions. Purpose: To contextualize and enrich performance analyses, allowing for more precise feedback aligned with your goals. Platform Usage Data: Platform Interaction: Information about how you navigate and use our features (pages visited, functionalities accessed, session duration, clicks, etc.). We collect this through cookies and similar technologies. Technical Data: IP address, browser type, operating system, device IDs. Purpose: To improve platform usability, identify and correct errors, optimize performance, and develop new features, always aiming to enhance your experience. This data is often collected in an anonymized and aggregated manner, when possible, to avoid individual identification. 3. How We Use Your Data Your data is used strictly for the purposes for which it was collected, always with the aim of optimizing your performance and your experience on the platform: To Provide and Personalize Our Essential Services: Analyze your cycling data to generate detailed performance reports (e.g., power zones, cadence distribution, elevation analysis). Identify training trends and progress over time (e.g., FTP increase, endurance improvement). Offer personalized feedback and training recommendations based on your data and goals. Visualize your routes and activity maps. To Improve the Platform and User Experience: Use usage data (anonymized and aggregated) to understand how users interact with the platform, identify bottlenecks, and enhance existing functionalities or develop new ones. For example, if many users click on a certain button, it may indicate the need to optimize that function. Direct and Relevant Communication: Send notifications about your performance, such as weekly summaries or new personal best alerts via email or in-platform. Communicate important platform updates, new features, or changes to the Privacy Policy. Provide training tips, relevant articles, and information that may assist your goals, always with an opt-out option for marketing communications. Customer Support and Troubleshooting: To answer your questions, resolve technical issues, and provide necessary support efficiently and effectively. 4. No Data Sharing with Third Parties This is a fundamental and non-negotiable premise of our platform: We do not share, sell, rent, trade, or disclose your personal or performance data with third-party companies for marketing, advertising, market research, or any other commercial purpose. Your data is yours and remains under our control. Your data is processed and stored on our secure servers, or in third-party cloud computing services (sub-processors) that operate strictly under our instructions and are bound by stringent confidentiality and data protection agreements. These sub-processors are not permitted to use your data for their own purposes or for any purpose other than to help us provide the service to you. Limited Exceptions (only if strictly necessary and legally justifiable): We may be required to disclose your personal data in response to valid and binding legal processes, such as court orders, subpoenas, warrants, or to comply with applicable laws and regulations. This may also occur when we believe in good faith that disclosure is necessary to: Protect our legal rights, property, or safety, or the safety of our users or the public. Investigate fraudulent or illegal activities. Respond to a legitimate governmental request. Protect your vital interests or those of another natural person. 5. Your Full Control and Rights Over Your Data You have full control over your data at [Your Coaching/Platform Name] and can exercise your rights at any time. We guarantee the following rights, in accordance with applicable data protection laws (such as LGPD in Brazil and GDPR in Europe): Access and Data Portability: You can access, view, and download your own performance data (including original cycling computer files, such as .fit, .gpx, .tcx) at any time through your account's dashboard or settings section on the platform. This allows you to take your data to another service if you wish. Right to Rectification: You can edit and update your personal and profile information (e.g., weight, FTP, email) directly in your account settings, ensuring your data is always accurate and up-to-date. Right to Erasure (Right to Be Forgotten): You have the right to request the deletion of all your personal and performance data from our systems. Upon requesting deletion, all your data will be permanently removed from our active systems and backups, with the exception of data we are legally obligated to retain for a certain period (e.g., tax records, security audit logs). The deletion process may take up to7 business-days to be completed across all our systems and backups. Right to Withdraw Consent: You can review and change your consent preferences for data collection and use at any time, especially for marketing communications. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal. Right to Object to Processing: You can object to certain processing of your data if there are legitimate reasons related to your particular situation, or in cases of profiling and direct marketing. Right to Restriction of Processing: You can request the restriction of processing of your data under certain circumstances, such as when the accuracy of the data is contested by you, or when processing is unlawful, but you object to deletion. Right to Lodge a Complaint with a Supervisory Authority: You have the right to file a complaint with a competent data protection authority in your country if you believe your privacy rights have been violated. To exercise any of these rights, access your account settings or contact us through the channels indicated in Section 9. Our goal is to respond to all legitimate requests within 48 hours. 6. Data Security We employ robust and state-of-the-art technical, administrative, and organizational security measures to protect your data against unauthorized access, alteration, disclosure, accidental or unlawful destruction. Our security practices include, but are not limited to: Encryption: All data in transit between your browser and our servers is protected by TLS/SSL (Transport Layer Security/Secure Sockets Layer) encryption. Data at rest (stored) is also encrypted using standards such as AES-256. Strict Access Controls: We implement Role-Based Access Control (RBAC) to ensure that only authorized personnel have access to data, and only to the extent necessary to perform their duties. Multi-Factor Authentication (MFA): For internal access to our systems and, if available, for user access to the platform, to add an extra layer of security. Continuous Monitoring: Our systems are monitored 24/7 to detect and prevent suspicious activities or unauthorized access attempts. Security Audits: We conduct regular security audits and penetration testing to identify and mitigate vulnerabilities. Regular Backups: We maintain data backups to ensure recovery in case of failures, protecting against data loss. Anonymization and Pseudonymization: Where appropriate and technically feasible, we apply anonymization and pseudononymization techniques to protect data identity. Incident Response Plan: We have a security incident response plan to act quickly and mitigate any data breaches, notifying authorities and affected users as required by law. 7. Data Retention Your performance data and personal information are retained as long as your account is active on Neutom and as long as necessary to provide the requested services, fulfill legal obligations, or resolve disputes. Active Accounts: We retain your data so you can access your training history and ongoing analyses. Account Deletion: If you choose to delete your account or request data deletion, it will be removed from our active systems and backups as described in the \"Your Full Control and Rights Over Your Data\" section. The permanent deletion process aims to remove all identifiable data. Legal Obligations: In some situations, we may be required to retain certain data for a longer period to comply with legal, regulatory, tax obligations, or for auditing purposes. In such cases, the data will be stored securely and isolated, with restricted access, only for the time required by law. 8. Changes to This Privacy Policy We may update our Privacy Policy periodically to reflect changes in our data practices, new platform functionalities, or for legal and regulatory reasons. We will notify you of any significant changes through your account, via email, or by a prominent notice on our platform before the changes take effect. We advise you to review this Policy regularly to stay informed about how we protect your information. Continued use of the platform after the publication of a revised Privacy Policy implies your acceptance of the new terms. 9. Contact If you have any questions about this Privacy Policy, our data practices, or wish to exercise any of your rights, please contact us via: Email: neutomapp@gmail.com","absoluteBoundingBox":{"x":2321.0,"y":505.0,"width":800.0,"height":4628.0},"isolatedAbsoluteRenderBounds":{"x":2321.37084960938,"y":511.295440673828,"width":797.60009765625,"height":4593.5908203125},"relativeTransform":[[1.0,0.0,0.0],[0.0,1.0,0.0]],"size":{"x":800.0,"y":4628.0},"fills":[{"opacity":0.550000011920929,"blendMode":"NORMAL","type":"SOLID","color":{"r":0.0,"g":0.0,"b":0.0,"a":1.0},"visible":true}],"strokeAlign":"OUTSIDE","layoutAlign":"STRETCH","strokes":[],"effects":[],"accessibleHTMLTag":"AUTO","isDecorativeImage":false,"ariaAttributes":{},"interactions":[],"characterStyleOverrides":[],"characters":"Privacy Policy of Neutom\nLast Updated: January 13, 2026\nAt Neutom your privacy and data security are non-negotiable pillars. This Privacy Policy details how we collect, use, store, protect, and manage the information you provide when using our cycling data analysis platform. Our commitment is to transparency, integrity, and your complete control over your data.\nWe do not share your personal or performance data with third parties for commercial purposes, and you have full autonomy to manage your data at any time.\n1. Who Are We?\nWe are a platform specialized in providing in-depth performance analysis and training insights for endurance athletes. We use data from cycling computers (such as Garmin, Wahoo, etc.) to transform your training data into actionable information. Our goal is to empower you to achieve your best results, based on concrete data, precise analysis, and with the utmost security and privacy.\n2. Data We Collect\nTo operate and provide our performance analysis services, we collect the following categories of data, always with your explicit and informed consent:\nIdentification and Contact Data:\nRegistration Information: Your full name, email address, and an encrypted password for secure platform access.\nProfile Information: Data you voluntarily add to your profile, such as date of birth, weight, height, gender, cyclist type (road, MTB), training zones (FTP, heart rate thresholds), which are crucial for personalizing analyses and training metrics.\nPurpose: Account management, experience personalization, and direct communication.\nCycling Performance Data:\nActivity Files: Primarily through the upload of files generated by cycling computers and third-party applications (e.g., .fit, .gpx, .tcx from Garmin, Wahoo, Strava, etc.). These files are the backbone of our analyses and contain a wealth of information, including:\nLocation Data (GPS): Route covered, geographical coordinates, speed, distance, elevation (gain/loss).\nPhysiological Data: Heart rate (average, maximum, zones), cadence, body temperature (if available from sensor).\nPower Data: Watts (average, maximum, normalized – NP), Intensity Factor (IF), Training Stress Score (TSS), power balance (if available).\nEquipment Data: Information about the bicycle used, connected sensors (power meter, GPS, HR monitor).\nEnvironmental Data: Ambient temperature, barometric pressure (if captured by the device).\nPurpose: Conducting detailed performance analyses, monitoring progress, identifying training trends, calculating specific metrics, and generating personalized reports.\nTraining Data and Goals:\nManual Information: Data you directly enter into the platform about your training plans, short and long-term goals, specific equipment, health status, and any relevant observations about your sessions.\nPurpose: To contextualize and enrich performance analyses, allowing for more precise feedback aligned with your goals.\nPlatform Usage Data:\nPlatform Interaction: Information about how you navigate and use our features (pages visited, functionalities accessed, session duration, clicks, etc.). We collect this through cookies and similar technologies.\nTechnical Data: IP address, browser type, operating system, device IDs.\nPurpose: To improve platform usability, identify and correct errors, optimize performance, and develop new features, always aiming to enhance your experience. This data is often collected in an anonymized and aggregated manner, when possible, to avoid individual identification.\n3. How We Use Your Data\nYour data is used strictly for the purposes for which it was collected, always with the aim of optimizing your performance and your experience on the platform:\nTo Provide and Personalize Our Essential Services:\nAnalyze your cycling data to generate detailed performance reports (e.g., power zones, cadence distribution, elevation analysis).\nIdentify training trends and progress over time (e.g., FTP increase, endurance improvement).\nOffer personalized feedback and training recommendations based on your data and goals.\nVisualize your routes and activity maps.\nTo Improve the Platform and User Experience:\nUse usage data (anonymized and aggregated) to understand how users interact with the platform, identify bottlenecks, and enhance existing functionalities or develop new ones. For example, if many users click on a certain button, it may indicate the need to optimize that function.\nDirect and Relevant Communication:\nSend notifications about your performance, such as weekly summaries or new personal best alerts via email or in-platform.\nCommunicate important platform updates, new features, or changes to the Privacy Policy.\nProvide training tips, relevant articles, and information that may assist your goals, always with an opt-out option for marketing communications.\nCustomer Support and Troubleshooting:\nTo answer your questions, resolve technical issues, and provide necessary support efficiently and effectively.\n4. No Data Sharing with Third Parties\nThis is a fundamental and non-negotiable premise of our platform:\nWe do not share, sell, rent, trade, or disclose your personal or performance data with third-party companies for marketing, advertising, market research, or any other commercial purpose. Your data is yours and remains under our control.\nYour data is processed and stored on our secure servers, or in third-party cloud computing services (sub-processors) that operate strictly under our instructions and are bound by stringent confidentiality and data protection agreements. These sub-processors are not permitted to use your data for their own purposes or for any purpose other than to help us provide the service to you.\nLimited Exceptions (only if strictly necessary and legally justifiable): We may be required to disclose your personal data in response to valid and binding legal processes, such as court orders, subpoenas, warrants, or to comply with applicable laws and regulations. This may also occur when we believe in good faith that disclosure is necessary to:\nProtect our legal rights, property, or safety, or the safety of our users or the public.\nInvestigate fraudulent or illegal activities.\nRespond to a legitimate governmental request.\nProtect your vital interests or those of another natural person.\n5. Your Full Control and Rights Over Your Data\nYou have full control over your data at [Your Coaching/Platform Name] and can exercise your rights at any time. We guarantee the following rights, in accordance with applicable data protection laws (such as LGPD in Brazil and GDPR in Europe):\nAccess and Data Portability:\nYou can access, view, and download your own performance data (including original cycling computer files, such as .fit, .gpx, .tcx) at any time through your account's dashboard or settings section on the platform.\nThis allows you to take your data to another service if you wish.\nRight to Rectification:\nYou can edit and update your personal and profile information (e.g., weight, FTP, email) directly in your account settings, ensuring your data is always accurate and up-to-date.\nRight to Erasure (Right to Be Forgotten):\nYou have the right to request the deletion of all your personal and performance data from our systems. Upon requesting deletion, all your data will be permanently removed from our active systems and backups, with the exception of data we are legally obligated to retain for a certain period (e.g., tax records, security audit logs).\nThe deletion process may take up to7 business-days to be completed across all our systems and backups.\nRight to Withdraw Consent:\nYou can review and change your consent preferences for data collection and use at any time, especially for marketing communications. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal.\nRight to Object to Processing:\nYou can object to certain processing of your data if there are legitimate reasons related to your particular situation, or in cases of profiling and direct marketing.\nRight to Restriction of Processing:\nYou can request the restriction of processing of your data under certain circumstances, such as when the accuracy of the data is contested by you, or when processing is unlawful, but you object to deletion.\nRight to Lodge a Complaint with a Supervisory Authority:\nYou have the right to file a complaint with a competent data protection authority in your country if you believe your privacy rights have been violated.\nTo exercise any of these rights, access your account settings or contact us through the channels indicated in Section 9. Our goal is to respond to all legitimate requests within 48 hours.\n6. Data Security\nWe employ robust and state-of-the-art technical, administrative, and organizational security measures to protect your data against unauthorized access, alteration, disclosure, accidental or unlawful destruction. Our security practices include, but are not limited to:\nEncryption: All data in transit between your browser and our servers is protected by TLS/SSL (Transport Layer Security/Secure Sockets Layer) encryption. Data at rest (stored) is also encrypted using standards such as AES-256.\nStrict Access Controls: We implement Role-Based Access Control (RBAC) to ensure that only authorized personnel have access to data, and only to the extent necessary to perform their duties.\nMulti-Factor Authentication (MFA): For internal access to our systems and, if available, for user access to the platform, to add an extra layer of security.\nContinuous Monitoring: Our systems are monitored 24/7 to detect and prevent suspicious activities or unauthorized access attempts.\nSecurity Audits: We conduct regular security audits and penetration testing to identify and mitigate vulnerabilities.\nRegular Backups: We maintain data backups to ensure recovery in case of failures, protecting against data loss.\nAnonymization and Pseudonymization: Where appropriate and technically feasible, we apply anonymization and pseudononymization techniques to protect data identity.\nIncident Response Plan: We have a security incident response plan to act quickly and mitigate any data breaches, notifying authorities and affected users as required by law.\n7. Data Retention\nYour performance data and personal information are retained as long as your account is active on Neutom and as long as necessary to provide the requested services, fulfill legal obligations, or resolve disputes.\nActive Accounts: We retain your data so you can access your training history and ongoing analyses.\nAccount Deletion: If you choose to delete your account or request data deletion, it will be removed from our active systems and backups as described in the \"Your Full Control and Rights Over Your Data\" section. The permanent deletion process aims to remove all identifiable data.\nLegal Obligations: In some situations, we may be required to retain certain data for a longer period to comply with legal, regulatory, tax obligations, or for auditing purposes. In such cases, the data will be stored securely and isolated, with restricted access, only for the time required by law.\n8. Changes to This Privacy Policy\nWe may update our Privacy Policy periodically to reflect changes in our data practices, new platform functionalities, or for legal and regulatory reasons. We will notify you of any significant changes through your account, via email, or by a prominent notice on our platform before the changes take effect. We advise you to review this Policy regularly to stay informed about how we protect your information. Continued use of the platform after the publication of a revised Privacy Policy implies your acceptance of the new terms.\n9. Contact\nIf you have any questions about this Privacy Policy, our data practices, or wish to exercise any of your rights, please contact us via:\nEmail: 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Policy of Neutom Last Updated: January 13, 2026 At Neutom your privacy and data security are non-negotiable pillars. This Privacy Policy details how we collect, use, store, protect, and manage the information you provide when using our cycling data analysis platform. Our commitment is to transparency, integrity, and your complete control over your data. We do not share your personal or performance data with third parties for commercial purposes, and you have full autonomy to manage your data at any time. 1. Who Are We? We are a platform specialized in providing in-depth performance analysis and training insights for endurance athletes. We use data from cycling computers (such as Garmin, Wahoo, etc.) to transform your training data into actionable information. Our goal is to empower you to achieve your best results, based on concrete data, precise analysis, and with the utmost security and privacy. 2. Data We Collect To operate and provide our performance analysis services, we collect the following categories of data, always with your explicit and informed consent: Identification and Contact Data: Registration Information: Your full name, email address, and an encrypted password for secure platform access. Profile Information: Data you voluntarily add to your profile, such as date of birth, weight, height, gender, cyclist type (road, MTB), training zones (FTP, heart rate thresholds), which are crucial for personalizing analyses and training metrics. Purpose: Account management, experience personalization, and direct communication. Cycling Performance Data: Activity Files: Primarily through the upload of files generated by cycling computers and third-party applications (e.g., .fit, .gpx, .tcx from Garmin, Wahoo, Strava, etc.). These files are the backbone of our analyses and contain a wealth of information, including: Location Data (GPS): Route covered, geographical coordinates, speed, distance, elevation (gain/loss). Physiological Data: Heart rate (average, maximum, zones), cadence, body temperature (if available from sensor). Power Data: Watts (average, maximum, normalized – NP), Intensity Factor (IF), Training Stress Score (TSS), power balance (if available). Equipment Data: Information about the bicycle used, connected sensors (power meter, GPS, HR monitor). Environmental Data: Ambient temperature, barometric pressure (if captured by the device). Purpose: Conducting detailed performance analyses, monitoring progress, identifying training trends, calculating specific metrics, and generating personalized reports. Training Data and Goals: Manual Information: Data you directly enter into the platform about your training plans, short and long-term goals, specific equipment, health status, and any relevant observations about your sessions. Purpose: To contextualize and enrich performance analyses, allowing for more precise feedback aligned with your goals. Platform Usage Data: Platform Interaction: Information about how you navigate and use our features (pages visited, functionalities accessed, session duration, clicks, etc.). We collect this through cookies and similar technologies. Technical Data: IP address, browser type, operating system, device IDs. Purpose: To improve platform usability, identify and correct errors, optimize performance, and develop new features, always aiming to enhance your experience. This data is often collected in an anonymized and aggregated manner, when possible, to avoid individual identification. 3. How We Use Your Data Your data is used strictly for the purposes for which it was collected, always with the aim of optimizing your performance and your experience on the platform: To Provide and Personalize Our Essential Services: Analyze your cycling data to generate detailed performance reports (e.g., power zones, cadence distribution, elevation analysis). Identify training trends and progress over time (e.g., FTP increase, endurance improvement). Offer personalized feedback and training recommendations based on your data and goals. Visualize your routes and activity maps. To Improve the Platform and User Experience: Use usage data (anonymized and aggregated) to understand how users interact with the platform, identify bottlenecks, and enhance existing functionalities or develop new ones. For example, if many users click on a certain button, it may indicate the need to optimize that function. Direct and Relevant Communication: Send notifications about your performance, such as weekly summaries or new personal best alerts via email or in-platform. Communicate important platform updates, new features, or changes to the Privacy Policy. Provide training tips, relevant articles, and information that may assist your goals, always with an opt-out option for marketing communications. Customer Support and Troubleshooting: To answer your questions, resolve technical issues, and provide necessary support efficiently and effectively. 4. No Data Sharing with Third Parties This is a fundamental and non-negotiable premise of our platform: We do not share, sell, rent, trade, or disclose your personal or performance data with third-party companies for marketing, advertising, market research, or any other commercial purpose. Your data is yours and remains under our control. Your data is processed and stored on our secure servers, or in third-party cloud computing services (sub-processors) that operate strictly under our instructions and are bound by stringent confidentiality and data protection agreements. These sub-processors are not permitted to use your data for their own purposes or for any purpose other than to help us provide the service to you. Limited Exceptions (only if strictly necessary and legally justifiable): We may be required to disclose your personal data in response to valid and binding legal processes, such as court orders, subpoenas, warrants, or to comply with applicable laws and regulations. This may also occur when we believe in good faith that disclosure is necessary to: Protect our legal rights, property, or safety, or the safety of our users or the public. Investigate fraudulent or illegal activities. Respond to a legitimate governmental request. Protect your vital interests or those of another natural person. 5. Your Full Control and Rights Over Your Data You have full control over your data at [Your Coaching/Platform Name] and can exercise your rights at any time. We guarantee the following rights, in accordance with applicable data protection laws (such as LGPD in Brazil and GDPR in Europe): Access and Data Portability: You can access, view, and download your own performance data (including original cycling computer files, such as .fit, .gpx, .tcx) at any time through your account's dashboard or settings section on the platform. This allows you to take your data to another service if you wish. Right to Rectification: You can edit and update your personal and profile information (e.g., weight, FTP, email) directly in your account settings, ensuring your data is always accurate and up-to-date. Right to Erasure (Right to Be Forgotten): You have the right to request the deletion of all your personal and performance data from our systems. Upon requesting deletion, all your data will be permanently removed from our active systems and backups, with the exception of data we are legally obligated to retain for a certain period (e.g., tax records, security audit logs). The deletion process may take up to7 business-days to be completed across all our systems and backups. Right to Withdraw Consent: You can review and change your consent preferences for data collection and use at any time, especially for marketing communications. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal. Right to Object to Processing: You can object to certain processing of your data if there are legitimate reasons related to your particular situation, or in cases of profiling and direct marketing. Right to Restriction of Processing: You can request the restriction of processing of your data under certain circumstances, such as when the accuracy of the data is contested by you, or when processing is unlawful, but you object to deletion. Right to Lodge a Complaint with a Supervisory Authority: You have the right to file a complaint with a competent data protection authority in your country if you believe your privacy rights have been violated. To exercise any of these rights, access your account settings or contact us through the channels indicated in Section 9. Our goal is to respond to all legitimate requests within 48 hours. 6. Data Security We employ robust and state-of-the-art technical, administrative, and organizational security measures to protect your data against unauthorized access, alteration, disclosure, accidental or unlawful destruction. Our security practices include, but are not limited to: Encryption: All data in transit between your browser and our servers is protected by TLS/SSL (Transport Layer Security/Secure Sockets Layer) encryption. Data at rest (stored) is also encrypted using standards such as AES-256. Strict Access Controls: We implement Role-Based Access Control (RBAC) to ensure that only authorized personnel have access to data, and only to the extent necessary to perform their duties. Multi-Factor Authentication (MFA): For internal access to our systems and, if available, for user access to the platform, to add an extra layer of security. Continuous Monitoring: Our systems are monitored 24/7 to detect and prevent suspicious activities or unauthorized access attempts. Security Audits: We conduct regular security audits and penetration testing to identify and mitigate vulnerabilities. Regular Backups: We maintain data backups to ensure recovery in case of failures, protecting against data loss. Anonymization and Pseudonymization: Where appropriate and technically feasible, we apply anonymization and pseudononymization techniques to protect data identity. Incident Response Plan: We have a security incident response plan to act quickly and mitigate any data breaches, notifying authorities and affected users as required by law. 7. Data Retention Your performance data and personal information are retained as long as your account is active on Neutom and as long as necessary to provide the requested services, fulfill legal obligations, or resolve disputes. Active Accounts: We retain your data so you can access your training history and ongoing analyses. Account Deletion: If you choose to delete your account or request data deletion, it will be removed from our active systems and backups as described in the \"Your Full Control and Rights Over Your Data\" section. The permanent deletion process aims to remove all identifiable data. Legal Obligations: In some situations, we may be required to retain certain data for a longer period to comply with legal, regulatory, tax obligations, or for auditing purposes. In such cases, the data will be stored securely and isolated, with restricted access, only for the time required by law. 8. Changes to This Privacy Policy We may update our Privacy Policy periodically to reflect changes in our data practices, new platform functionalities, or for legal and regulatory reasons. We will notify you of any significant changes through your account, via email, or by a prominent notice on our platform before the changes take effect. We advise you to review this Policy regularly to stay informed about how we protect your information. Continued use of the platform after the publication of a revised Privacy Policy implies your acceptance of the new terms. 9. Contact If you have any questions about this Privacy Policy, our data practices, or wish to exercise any of your rights, please contact us via: Email: neutomapp@gmail.com","absoluteBoundingBox":{"x":3505.0,"y":417.0,"width":640.0,"height":5434.0},"isolatedAbsoluteRenderBounds":{"x":3505.37084960938,"y":423.295440673828,"width":638.346435546875,"height":5399.5908203125},"relativeTransform":[[1.0,0.0,0.0],[0.0,1.0,0.0]],"size":{"x":640.0,"y":5434.0},"fills":[{"opacity":0.550000011920929,"blendMode":"NORMAL","type":"SOLID","color":{"r":0.0,"g":0.0,"b":0.0,"a":1.0},"visible":true}],"strokeAlign":"OUTSIDE","layoutAlign":"STRETCH","strokes":[],"effects":[],"accessibleHTMLTag":"AUTO","isDecorativeImage":false,"ariaAttributes":{},"interactions":[],"characterStyleOverrides":[],"characters":"Privacy Policy of Neutom\nLast Updated: January 13, 2026\nAt Neutom your privacy and data security are non-negotiable pillars. This Privacy Policy details how we collect, use, store, protect, and manage the information you provide when using our cycling data analysis platform. Our commitment is to transparency, integrity, and your complete control over your data.\nWe do not share your personal or performance data with third parties for commercial purposes, and you have full autonomy to manage your data at any time.\n1. Who Are We?\nWe are a platform specialized in providing in-depth performance analysis and training insights for endurance athletes. We use data from cycling computers (such as Garmin, Wahoo, etc.) to transform your training data into actionable information. Our goal is to empower you to achieve your best results, based on concrete data, precise analysis, and with the utmost security and privacy.\n2. Data We Collect\nTo operate and provide our performance analysis services, we collect the following categories of data, always with your explicit and informed consent:\nIdentification and Contact Data:\nRegistration Information: Your full name, email address, and an encrypted password for secure platform access.\nProfile Information: Data you voluntarily add to your profile, such as date of birth, weight, height, gender, cyclist type (road, MTB), training zones (FTP, heart rate thresholds), which are crucial for personalizing analyses and training metrics.\nPurpose: Account management, experience personalization, and direct communication.\nCycling Performance Data:\nActivity Files: Primarily through the upload of files generated by cycling computers and third-party applications (e.g., .fit, .gpx, .tcx from Garmin, Wahoo, Strava, etc.). These files are the backbone of our analyses and contain a wealth of information, including:\nLocation Data (GPS): Route covered, geographical coordinates, speed, distance, elevation (gain/loss).\nPhysiological Data: Heart rate (average, maximum, zones), cadence, body temperature (if available from sensor).\nPower Data: Watts (average, maximum, normalized – NP), Intensity Factor (IF), Training Stress Score (TSS), power balance (if available).\nEquipment Data: Information about the bicycle used, connected sensors (power meter, GPS, HR monitor).\nEnvironmental Data: Ambient temperature, barometric pressure (if captured by the device).\nPurpose: Conducting detailed performance analyses, monitoring progress, identifying training trends, calculating specific metrics, and generating personalized reports.\nTraining Data and Goals:\nManual Information: Data you directly enter into the platform about your training plans, short and long-term goals, specific equipment, health status, and any relevant observations about your sessions.\nPurpose: To contextualize and enrich performance analyses, allowing for more precise feedback aligned with your goals.\nPlatform Usage Data:\nPlatform Interaction: Information about how you navigate and use our features (pages visited, functionalities accessed, session duration, clicks, etc.). We collect this through cookies and similar technologies.\nTechnical Data: IP address, browser type, operating system, device IDs.\nPurpose: To improve platform usability, identify and correct errors, optimize performance, and develop new features, always aiming to enhance your experience. This data is often collected in an anonymized and aggregated manner, when possible, to avoid individual identification.\n3. How We Use Your Data\nYour data is used strictly for the purposes for which it was collected, always with the aim of optimizing your performance and your experience on the platform:\nTo Provide and Personalize Our Essential Services:\nAnalyze your cycling data to generate detailed performance reports (e.g., power zones, cadence distribution, elevation analysis).\nIdentify training trends and progress over time (e.g., FTP increase, endurance improvement).\nOffer personalized feedback and training recommendations based on your data and goals.\nVisualize your routes and activity maps.\nTo Improve the Platform and User Experience:\nUse usage data (anonymized and aggregated) to understand how users interact with the platform, identify bottlenecks, and enhance existing functionalities or develop new ones. For example, if many users click on a certain button, it may indicate the need to optimize that function.\nDirect and Relevant Communication:\nSend notifications about your performance, such as weekly summaries or new personal best alerts via email or in-platform.\nCommunicate important platform updates, new features, or changes to the Privacy Policy.\nProvide training tips, relevant articles, and information that may assist your goals, always with an opt-out option for marketing communications.\nCustomer Support and Troubleshooting:\nTo answer your questions, resolve technical issues, and provide necessary support efficiently and effectively.\n4. No Data Sharing with Third Parties\nThis is a fundamental and non-negotiable premise of our platform:\nWe do not share, sell, rent, trade, or disclose your personal or performance data with third-party companies for marketing, advertising, market research, or any other commercial purpose. Your data is yours and remains under our control.\nYour data is processed and stored on our secure servers, or in third-party cloud computing services (sub-processors) that operate strictly under our instructions and are bound by stringent confidentiality and data protection agreements. These sub-processors are not permitted to use your data for their own purposes or for any purpose other than to help us provide the service to you.\nLimited Exceptions (only if strictly necessary and legally justifiable): We may be required to disclose your personal data in response to valid and binding legal processes, such as court orders, subpoenas, warrants, or to comply with applicable laws and regulations. This may also occur when we believe in good faith that disclosure is necessary to:\nProtect our legal rights, property, or safety, or the safety of our users or the public.\nInvestigate fraudulent or illegal activities.\nRespond to a legitimate governmental request.\nProtect your vital interests or those of another natural person.\n5. Your Full Control and Rights Over Your Data\nYou have full control over your data at [Your Coaching/Platform Name] and can exercise your rights at any time. We guarantee the following rights, in accordance with applicable data protection laws (such as LGPD in Brazil and GDPR in Europe):\nAccess and Data Portability:\nYou can access, view, and download your own performance data (including original cycling computer files, such as .fit, .gpx, .tcx) at any time through your account's dashboard or settings section on the platform.\nThis allows you to take your data to another service if you wish.\nRight to Rectification:\nYou can edit and update your personal and profile information (e.g., weight, FTP, email) directly in your account settings, ensuring your data is always accurate and up-to-date.\nRight to Erasure (Right to Be Forgotten):\nYou have the right to request the deletion of all your personal and performance data from our systems. Upon requesting deletion, all your data will be permanently removed from our active systems and backups, with the exception of data we are legally obligated to retain for a certain period (e.g., tax records, security audit logs).\nThe deletion process may take up to7 business-days to be completed across all our systems and backups.\nRight to Withdraw Consent:\nYou can review and change your consent preferences for data collection and use at any time, especially for marketing communications. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal.\nRight to Object to Processing:\nYou can object to certain processing of your data if there are legitimate reasons related to your particular situation, or in cases of profiling and direct marketing.\nRight to Restriction of Processing:\nYou can request the restriction of processing of your data under certain circumstances, such as when the accuracy of the data is contested by you, or when processing is unlawful, but you object to deletion.\nRight to Lodge a Complaint with a Supervisory Authority:\nYou have the right to file a complaint with a competent data protection authority in your country if you believe your privacy rights have been violated.\nTo exercise any of these rights, access your account settings or contact us through the channels indicated in Section 9. Our goal is to respond to all legitimate requests within 48 hours.\n6. Data Security\nWe employ robust and state-of-the-art technical, administrative, and organizational security measures to protect your data against unauthorized access, alteration, disclosure, accidental or unlawful destruction. Our security practices include, but are not limited to:\nEncryption: All data in transit between your browser and our servers is protected by TLS/SSL (Transport Layer Security/Secure Sockets Layer) encryption. Data at rest (stored) is also encrypted using standards such as AES-256.\nStrict Access Controls: We implement Role-Based Access Control (RBAC) to ensure that only authorized personnel have access to data, and only to the extent necessary to perform their duties.\nMulti-Factor Authentication (MFA): For internal access to our systems and, if available, for user access to the platform, to add an extra layer of security.\nContinuous Monitoring: Our systems are monitored 24/7 to detect and prevent suspicious activities or unauthorized access attempts.\nSecurity Audits: We conduct regular security audits and penetration testing to identify and mitigate vulnerabilities.\nRegular Backups: We maintain data backups to ensure recovery in case of failures, protecting against data loss.\nAnonymization and Pseudonymization: Where appropriate and technically feasible, we apply anonymization and pseudononymization techniques to protect data identity.\nIncident Response Plan: We have a security incident response plan to act quickly and mitigate any data breaches, notifying authorities and affected users as required by law.\n7. Data Retention\nYour performance data and personal information are retained as long as your account is active on Neutom and as long as necessary to provide the requested services, fulfill legal obligations, or resolve disputes.\nActive Accounts: We retain your data so you can access your training history and ongoing analyses.\nAccount Deletion: If you choose to delete your account or request data deletion, it will be removed from our active systems and backups as described in the \"Your Full Control and Rights Over Your Data\" section. The permanent deletion process aims to remove all identifiable data.\nLegal Obligations: In some situations, we may be required to retain certain data for a longer period to comply with legal, regulatory, tax obligations, or for auditing purposes. In such cases, the data will be stored securely and isolated, with restricted access, only for the time required by law.\n8. Changes to This Privacy Policy\nWe may update our Privacy Policy periodically to reflect changes in our data practices, new platform functionalities, or for legal and regulatory reasons. We will notify you of any significant changes through your account, via email, or by a prominent notice on our platform before the changes take effect. We advise you to review this Policy regularly to stay informed about how we protect your information. Continued use of the platform after the publication of a revised Privacy Policy implies your acceptance of the new terms.\n9. Contact\nIf you have any questions about this Privacy Policy, our data practices, or wish to exercise any of your rights, please contact us via:\nEmail: 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