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Privacy

Version 1.0, effective from 25 October 2026 to 28 October 2026 (archive). It describes consent v3, which stays valid until you replace it with a newer one; the processing today is described on the current Privacy page. Since the morning of 28 October 2026 the conversation with your coach no longer runs on the GLM model (Z.ai) but on the Claude model (Anthropic) through OpenRouter; see the current Privacy page. Slovenska različica: Zasebnost (v3).

1. Controller

The controller of personal data in Cycling Mentor is BeFly, oddaja nepremičnin, d.o.o. (BeFly d.o.o.), Ljubljanska cesta 38B, 1293 Šmarje-Sap, Slovenia, registration number 7475039000. Contact: info@befly.si. The service is for people aged 18 or older who open an account by signing up or receive one by invitation; the Terms of Use also apply.

2. Legal basis

Health and training data are not a legal requirement, but the service needs them: without them the coach cannot plan your training. You can withdraw consent at any time; withdrawal does not affect the lawfulness of processing before it.

3. What data we process

The content of messages that the code recognises as a health warning is neither stored nor sent to the language model.

For the annual report we send to the authors of the questionnaire (PAR-Q+ Collaboration) as a condition for using it, on the basis of this consent we count the outcome categories of your health screening (PAR-Q+ and ePARmed-X+) for each 12-month period. If you withdraw consent or delete your account, we subtract your outcomes from every period whose report has not yet been sent. In reports already sent they remain only as part of a total from which you cannot be identified. The report shows the breakdown by category only when every category has at least 5 riders. Otherwise it shows only how many riders were screened, and only if there are at least 5.

Separately from this consent and not based on it: the time you recorded an outcome and the time the operator confirmed or reset it are kept with your account's internal label in the alert and audit records for 5 years, also after your account is deleted, like the rest of the audit trail. These records hold neither answers nor the outcome category, but the confirmation record shows that your outcome was reviewed.

4. Where the data comes from

From your intervals.icu account (rides, wellness, training settings), from Withings if you connect it (weight and body composition), from Garmin Connect if you connect it (activities and daily health values), from Telegram (your messages) and from what you enter yourself on the dashboard, in the guide or in the chat.

5. What for

To plan your training and adapt it as you go, to assess readiness and training load, for nutrition advice, for the conversation with your coach in Telegram, for the dashboard and for the safety check before intense training.

6. Where it is kept and how it is protected

In a separate database for you only, on a server in the EU managed by BeFly; today this is a Mac computer. The database is encrypted; every account has its own key, kept in this Mac's key store (Keychain). An export we prepare on the Mac at your request and accepted suggestions from the occasional review of how the coach is helping you are stored unencrypted in your folder; these two folders are excluded from the Time Machine copies on the external disk, but stay in the Mac's local snapshot of the whole disk for up to 24 hours.

Encryption protects copies of your database and files that leave the Mac without the key: someone who has only a copy cannot read it. It does not protect the running Mac, because the program on it opens the database. It does not protect a stolen Mac or its disk: the disk is not encrypted, and the Mac signs in automatically at start-up, which unlocks the key store.

7. Copies

All copies are in the EU.

8. Who else receives data

Our processors:

Independent controllers of your own accounts (we send data there on your instruction; their privacy policies apply):

9. Transfers outside the EU

Under its privacy policy OpenRouter transfers data to servers in the United States and to other countries outside the EEA. The data processing agreement with OpenRouter is part of its terms of service (section 10.2); transfers outside the EEA rest on the EU Standard Contractual Clauses, Module 2 (controller to processor, section 13.2 of the agreement); its list of sub-processors is Schedule 3 of the agreement at trust.openrouter.ai. We do not restrict the choice of model providers: the providers of the GLM model are mostly headquartered in the United States, some in the EU, Singapore or China; the providers of the Claude models are in the United States.

Cloudflare and Microsoft are companies headquartered in the United States and may also process data outside the EU. We send data to Telegram, Garmin and the other independent controllers on your instruction; their privacy policies apply, including to their transfers outside the EU.

10. Artificial intelligence

Numbers (training load, rest, calories, safety limits) are computed by code. A language model writes the coach's messages and explanations within the limits the code sets; its answer can be wrong. The conversation runs on the GLM model (Z.ai), training questions and the weekly review on Claude models (Anthropic), both through OpenRouter.

The model receives your message and the recent messages of the conversation, a photo if you send one, your profile and summaries: training load, weight, readiness (level and reason, no raw measurements), plan and nutrition, but never data we receive through our own Garmin Connect connection or anything derived from it (section 11); for an occasional review of how the coach is helping you, also your messages from the last 28 days. Rides, HRV and sleep that intervals.icu imports from any device or service, including your Garmin Connect account, we process like other intervals.icu data, including with the language model.

Every request is set so that only providers that do not collect data may take it (data_collection: deny); under OpenRouter's rules this means they do not use your data to train models. It does not mean they do not keep it: we have not switched on zero data retention (ZDR), and some providers keep prompts for a while, Anthropic for example for 30 days. OpenRouter itself does not train models on your data.

Profiling: from your data, code and the model build an assessment of readiness and training load and a training plan. We make no decisions based solely on automated processing that have legal or similarly significant effects on you; clearance for training after the PAR-Q+ questionnaire is done by a person. You can ask for human review at info@befly.si.

11. Garmin Connect

Optional, once the connection is available. You connect your own Garmin Connect account on Garmin's authorization page; we never see your Garmin password. When you connect, we ask you separately for consent to this data.

12. Who at BeFly sees your data

In the account overview the person at BeFly who runs the service sees the state of your account and connections and the date of your last ride, with no health data; receives system alerts with your account's internal label; and sees the outcome of the PAR-Q+ questionnaire when clearing you for training. Because that person runs the Mac, they can technically read all your data. No one else who uses Cycling Mentor sees your data.

13. How long

After your account is deleted, the following remain until those 5 years run out: the row of your account in the register (internal label, without e-mail or Telegram), the record of this consent and of any withdrawals, the audit trail (who did what and when; it also holds the numbers of your intervals.icu and Withings accounts, settings changes with old and new values, and reasons the operator enters) and closed alerts, for example that you submitted the PAR-Q+ questionnaire. Lines with your account's internal label in program logs remain until their 90 days run out. In annual reports already sent to PAR-Q+ Collaboration your outcomes remain only as part of a total from which you cannot be identified.

14. Your rights

You have the right of access to your data, rectification, erasure, restriction of processing, data portability and the right to object to processing based on our legitimate interest.

15. Changes

For a new purpose of processing, new kinds of data, a transfer of health data to a country outside the EEA or a longer retention period, we ask for your consent again; until you give it, we do not process your data in the new way.

We tell you about other changes that affect you (a new processor, a new hosting provider with servers in the EU or EEA, a change of contact details or of how you exercise your rights) by e-mail or in Telegram at least 30 days in advance; until then you can withdraw consent or request deletion, and if you request deletion before the date of the change, we do not move your data to the new provider. We use a shorter notice only when the change is urgent for security or a legal obligation; then we tell you at once and give the reason.

Corrections that do not change the processing are published on this page with a date and version number; this page also keeps the current list of our processors (section 8).

Cycling Mentor does not replace medical care.