Privacy policy
Draft: details marked in yellow are still missing, and this text has not yet been reviewed by a lawyer. Not legal advice.
1. Who is responsible
[Your full name, or company name with legal form]
[Street and house number]
[Postcode and city]
Austria
Email: [Contact email]
We are responsible (controller) for the data of visitors to this website and of coaches who use Followthru. For the data of students who use a coach's course companion, the coach is the controller and we process it on their behalf – see section 9 and our data processing agreement.
2. No tracking, no analytics
We do not use tracking or marketing cookies and no analytics tools. Fonts are served from our own server. The only cookies we set are technically necessary sign-in cookies (for coaches, students and our own admin access). They contain a random session ID and are not used for advertising or to follow you across websites.
3. Hosting
This website and app are hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. When you visit the site, Vercel processes technically necessary data (e.g. IP address, time, requested page, browser information) to deliver and secure the site. Legal basis: Art. 6(1)(f) GDPR (secure and reliable operation). Vercel is certified under the EU-US Data Privacy Framework; in addition, standard contractual clauses apply.
4. Database
Account, course and companion data is stored in a database operated by Neon, Inc. (USA) in its EU region (Frankfurt, Germany).
5. AI answers
To generate answers – in the demo on this website and in a coach's course companion – messages and the relevant course content are sent to Anthropic PBC (USA). Under Anthropic's commercial terms, this data is not used to train AI models. Please don't enter personal or health data in the public demo. Legal basis for the demo: Art. 6(1)(f) GDPR (providing the demo you are using).
To limit misuse, we count demo messages per visitor. For this, your IP address is turned into an irreversible hash, which is kept in the server's memory for at most 24 hours. The IP address itself is not stored, and demo chats are not saved.
6. Emails
We send emails (sign-in codes, notifications, reminders) via Resend, Inc. (USA), using its EU sending region (Ireland).
7. Contact form and coach accounts
If you send us a request via the contact form, we receive your name, email address, course topic and approximate number of students by email and use them only to answer you. Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures). We delete the request when it has been dealt with, unless it leads to a contract.
If you create a coach account, we process your name, email address, the course platform you use, your course content and your settings in order to provide Followthru. You sign in with a one-time code sent to your email. Legal basis: Art. 6(1)(b) GDPR (contract). We keep this data while your account exists and delete it within 30 days after you ask us to, or after your subscription has ended – except where we are legally required to keep it longer (e.g. invoicing records).
8. Payments
Our order process is conducted by our online reseller Paddle.com (Paddle.com Market Limited, 30 Old Bailey, London EC4M 7AU, UK). Paddle is the Merchant of Record: it processes your payment and billing data as its own controller, under its own privacy policy. We never see your card details. From Paddle we receive your name, email address, country, the plan you chose and the status of your subscription, so we can activate your course companion. Legal basis: Art. 6(1)(b) GDPR (contract) and Art. 6(1)(c) GDPR (retention duties under tax law).
9. The course companion (for students of our coaches)
If your coach uses Followthru, we process on behalf of your coach: your first name and email address (to sign you in with an email code), your chat messages, the goal you share in the chat, which lessons you have ticked off and when you were last active. If the companion is built into your course platform, it also notes when you open a course page there (time and, if available, the lesson). Messages are answered by AI (see section 5). Questions the companion can't answer from the course – and anything health-related – are passed on to your coach together with your first name. Your coach also sees your progress and last activity. After a few days without activity, the companion may send you a short reminder email (at most two in a row). For questions about this data, please contact your coach; we support them in answering.
10. Your rights
You have the right to access, rectification, erasure, restriction of processing, data portability and to object, and to withdraw any consent at any time. Just email us. You can also lodge a complaint with a supervisory authority – in Austria the Österreichische Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at.
Last updated: [date]