SwimAI
Privacy Policy
Version v1.0.0 — Effective 2026-10-06
1. Data Controller
MAD DIGITAL TECHNOLOGIES INOVA SIMPLES (I.S.), CNPJ 68.742.110/0001-62, headquartered at R. Joaquim João de Bem, 140, ap. 104, bl. 1 · Araranguá/SC · CEP 88906-506, is the controller of personal data processed under this Policy. Contact: privacy@swimai.pro.
2. Data Subject Contact Channel
Under ANPD Resolution CD/ANPD No. 2/2022, MAD DIGITAL TECHNOLOGIES INOVA SIMPLES (I.S.) is a small-sized processing agent and is exempt from appointing a data protection officer. The communication channel with data subjects and with the ANPD is the email privacy@swimai.pro, through which we handle requests, questions and communications about the processing of personal data.
3. Data Collected
We collect: (a) registration data (name, email, profile photo); (b) authentication data, according to the sign-in method you choose (social network account or email and password); (c) health and physical activity data (see Section 4); (d) payment data, processed directly by our payment processor — we do not store your full card number; (e) location and language data (country, time zone, language).
4. Health and Fitness Data (Sensitive Data)
The following data are classified as sensitive data under art. 11 of the LGPD: training goal, experience level, critical swim speed, weekly frequency, session duration, gender, date of birth, weight, height, physical limitations or injuries, training methodology, available equipment and training history. The legal basis for this processing is the data subject's explicit and specific consent (LGPD art. 11, I), collected at registration. These data are used exclusively to generate and adjust your training plans. To do so, we share with our artificial intelligence provider only the training parameters that are strictly necessary — such as goal, level, target events, availability and equipment. Physical limitations or injuries, weight, height, date of birth, gender and the comments you write about your workouts are not sent to the artificial intelligence provider.
5. Processing Purposes
We process your data to: (a) deliver the contracted service (legal basis: contract); (b) generate AI-personalized workouts (legal basis: explicit consent for sensitive data); (c) process payments and billing (legal basis: contract); (d) service communications (legal basis: contract/legitimate interest); (e) comply with legal and tax obligations (legal basis: legal obligation); (f) prevent fraud (legal basis: legitimate interest).
6. Data Sharing
We share personal data only with processors that provide essential services to us, contractually bound to process it solely according to our instructions and with appropriate security measures: (a) authentication provider, for sign-in and session management; (b) payment processor, for charges and subscriptions; (c) artificial intelligence provider, to generate training plans, within the limits described in Section 4; (d) email delivery provider, for communications about your account and subscription; (e) cloud infrastructure providers, for secure hosting and data storage. We may also share data when required by law or by order of a competent authority. We do not sell, rent or share your data with third parties for advertising or marketing purposes. The current list of processors can be requested at privacy@swimai.pro.
7. International Transfers
Some of our processors process and store data on servers located outside Brazil. These international transfers take place under art. 33 of the LGPD, using standard contractual clauses under ANPD Resolution CD/ANPD No. 19/2024 or other safeguards recognized by law. You can request more information about these transfers at privacy@swimai.pro.
8. Retention Periods
We retain your data while your account is active. After closure, registration and financial data are kept for 5 years to meet fiscal and legal obligations. Health data is deleted within 30 days of an account deletion request, unless there is a legal obligation to retain it.
9. Your Rights (LGPD Art. 18)
You have the following rights regarding your data: (1) confirmation that processing exists; (2) access to your data; (3) correction of incomplete, inaccurate or outdated data; (4) anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data; (5) data portability; (6) deletion of data processed based on consent; (7) information about the entities with which we share data; (8) information about the possibility of not giving consent and its consequences; (9) withdrawal of consent; (10) objection to processing. Part of your registration and training data can be corrected directly in your profile. To exercise the other rights, email privacy@swimai.pro; we may ask you to confirm your identity before fulfilling the request. We respond within 15 days (users in the European Union have 30 days under the GDPR).
10. Security
We adopt technical and organizational measures commensurate with the nature of the data processed, including encryption in transit (TLS), role-based access control, and security monitoring. In the event of a security incident that may risk data subjects, we will notify the ANPD and affected users within 72 hours.
11. Cookies and Tracking
We use essential cookies and local storage to keep your session signed in and to remember your language and country preferences. We record affiliate attribution through a referral parameter (referral cookie). We do not use advertising cookies or third-party tracking.
12. Minors
SwimAI is not intended for persons under 18 without express parental authorization. If we have inadvertently collected data from minors, please contact privacy@swimai.pro for immediate deletion.
13. Contact and Updates
To exercise your rights, ask questions, or report incidents: privacy@swimai.pro. This Policy may be updated periodically. Significant changes will be communicated 30 days in advance.