DRAFT — for review by a lawyerThis text has no legal effect yet. Values in brackets [LIKE THIS] are missing and will be filled in.
Points for the lawyer (13)
  1. Missing details: [COMPANY REG. NO. (GEMI)], [VAT NO.], [TAX OFFICE (DOY)], [DATA PROTECTION OFFICER] (if one is appointed — to be assessed whether one is required, Article 37 GDPR). The address support@gymbly.app is temporary.
  2. Providers not yet chosen: [SMS PROVIDER] (the code supports Twilio or a generic HTTP provider), [E-INVOICING PROVIDER], [EMAIL PROVIDER] (the code does NOT yet send email through our own provider; payment receipts are sent by Stripe), [MAP PROVIDER] (OpenStreetMap is used in development; a commercial provider will be used in production).
  3. Roles: TBHUB is the controller for Gymbly Play accounts and for the accounts of businesses; for the members/customers of a gym the gym is the controller and TBHUB the processor. The single account (the same for Play and for gyms) needs review: possibly joint or successive responsibility for the shared details (name, mobile).
  4. Stripe is treated here as an independent controller for its own processing (fraud checks, regulatory obligations) and as a processor for executing payments — to be checked against Stripe's terms.
  5. AI (only in the gym app, not in Play): the AI Coach code sends to Anthropic (without the name, since 20/10) sex, age, height, weight, level, goals, injuries, days/duration and notes; nutrition sends a profile (goals, sex, age, weight, height, diet, allergies, preferences) without the name, and a photo or description of a meal for an estimate. Injuries and allergies = health data (Article 9 GDPR): lawful basis explicit consent, collected by the gym (the controller).
  6. Transfers outside the EU: Stripe, Anthropic, Google/Apple (sign-in), Google Maps (entering a business's address), WHOOP/Strava (if a member connects them) may process data in the USA. For each one, certification under the EU–US Data Privacy Framework or the Standard Contractual Clauses should be confirmed.
  7. Location: the browser asks for permission; the coordinates are sent as a parameter with every search for venues/matches so that the server can calculate distances; they are NOT stored in a database and are not written to the application's logs (only the path is logged on an error). In other words they do NOT stay only on the device, as we had assumed. It should be confirmed that the reverse proxy (Caddy) does not keep access logs with the query string. For the gym entry QR (geofence) the location is checked on the server and not stored; on failure the member's name + distance are written to the log.
  8. Cookies: only strictly necessary ones (session, language, test version) + Stripe's security cookies in the payment form. No advertising or statistics cookies. Assumption: no consent banner is needed (Article 4(5) of Law 3471/2006) — to be confirmed.
  9. Retention: receipts/invoices «for as long as tax law requires, as a rule 5 years» — the exact duration should be checked (Law 4308/2014, Tax Procedure Code Law 5193/2025 or as in force). Logs, backups, SMS codes: [PERIOD] to be decided.
  10. Deletion: written from src/lib/accountdelete.ts of 20/10 (being built in parallel): anonymisation, not deletion of the record; future bookings are cancelled as a player cancellation (the service fee stays); anything that can no longer be cancelled BLOCKS the deletion; the member record at the gym stays (the gym's record); receipts keep the buyer's name. The /account-deletion page is being built by someone else — to be checked that its text agrees.
  11. Question: «the service fee is not refunded» also when the cancellation is due to account deletion — to be assessed whether this is reasonable.
  12. Minimum age 16 (assumption); the code does not check age.
  13. English version (21/10/2026): this English text is a convenience translation and states that the Greek version prevails in case of conflict. It should be checked whether this is acceptable for a privacy notice, which under Article 12 GDPR must be given in a concise, intelligible form and clear and plain language to the data subject (i.e. whether the English notice must itself be complete and binding for English-speaking users).
Gymbly · Gymbly Play

Privacy Policy

Last updated: [EFFECTIVE DATE]

Here we explain which personal data Gymbly uses, why, who sees it, how long we keep it and what rights you have, in accordance with the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Greek Law 4624/2019.

For the rules of use, payments and cancellations, see the Terms of Use.

English translation for convenience; in case of conflict the Greek version prevails.

Basics

1. Who we are

Gymbly and Gymbly Play are provided by TECHBUILDERS HUB ΜΟΝΟΠΡΟΣΩΠΗ Ι.Κ.Ε. (TECHBUILDERS HUB SINGLE MEMBER P.C.), trading as TECHBUILDERS HUB («TBHUB», «we»).

  • Registered office: Kolokotroni 61, 166 73 Voula, Greece
  • Company registration number (GEMI): [COMPANY REG. NO. (GEMI)] · VAT number: [VAT NO.] · Tax office: [TAX OFFICE (DOY)]
  • Email for data matters: support@gymbly.app [TEMPORARY EMAIL — NOT WORKING YET]
  • Data Protection Officer: [DATA PROTECTION OFFICER]

2. Who is responsible for your data

  • Players of Gymbly Play: the controller is TBHUB.
  • Businesses (owners and staff who use the front desk, billing details): the controller is TBHUB.
  • Members and customers of a gym or venue (memberships, attendance, payments at the till, workouts, nutrition): the controller is the gym/venue itself, and TBHUB processes the data only on its behalf, as a processor (see Terms of Use — Processing of data). For this data, contact your gym first; if you write to us, we will forward your request.
  • When you book a court through Play, the venue receives the booking details (name, mobile, time) and processes them as a controller in its own right in order to serve you and issue its receipt.

What data and why

3. What data we collect

  • Account: full name, email, mobile, password (stored only as a hash), language. If you sign in with Google or Apple, an identifier of your account there and the email they give us.
  • Player profile: photo (if you upload one), sports, level, reliability, statistics, trophies, friends, teams, personal invitation code.
  • Activity: bookings, open matches, results, messages in a match's chat, comments, tournament entries, booking requests to venues, notifications.
  • Payments: amount, date, status of payment and refund, Stripe identifiers. We do not see or store your card details — you give them directly to Stripe.
  • Receipts: your name and email on the Receipt for Services Rendered for the service fee.
  • Businesses: details of the owner and staff (name, mobile, email), billing details (company name, VAT number, tax office, address), address and location of the venue.
  • Gym app (on behalf of the gym): membership, payments and instalments, QR entries (and a check that you are at the gym at the moment of check-in, if the gym requires it), class bookings, workouts, and whatever you give for the AI Coach or nutrition (see Artificial intelligence). If you connect WHOOP or Strava, the activities of the last 7 days (calories, heart rate, intensity).
  • Technical: session cookies (see Cookies) and the server's error logs.
  • Contacts you invite: when you invite someone who does not have Gymbly to a team or tournament, the name and mobile number you give, so that we can send them the invitation SMS.

4. Why we use it and on what legal basis

  • To run your account and the service (bookings, matches, teams, tournaments, friends, ranking, notifications): performance of the contract with you (Article 6(1)(b) GDPR).
  • For payments and refunds through Stripe: performance of the contract (Article 6(1)(b)).
  • For tax documents (receipts, invoices, myDATA) and their retention: legal obligation (Article 6(1)(c)).
  • For security (mobile verification by SMS, prevention of fraud and abuse, backups, fixing errors): legitimate interest (Article 6(1)(f)).
  • To sort venues by distance: only if you give location permission on your device (see Location).
  • For invitation SMS to friends who do not have Gymbly: legitimate interest, yours (to invite them) and ours; one SMS per invitation, without advertising.
  • For promotional updates from TBHUB: only with your consent, which you can withdraw whenever you want.

We do not sell your data, we do not use it for third-party advertising and we do not take automated decisions with legal or similarly significant effects for you. Level and ranking are calculated automatically from the results, only so that matches are well matched.

5. Location

Your location is used only if you give permission on your device or browser, and only to sort venues and matches by distance from you. The coordinates are sent with each search to our server so that the distances can be calculated; they are not stored in the database and are not linked to your account. Without permission, the app works normally with a default area.

Where your gym requires a location check for the entry QR, your location is checked at the moment you request the QR, to confirm that you are inside the gym. Here too the location is not stored; if you are outside, only the distance is logged, for troubleshooting.

6. Artificial intelligence (only in the gym app)

Gymbly Play does not use artificial intelligence on your data. In the app of a gym, and only if the gym has enabled these features and you use them:

  • AI Coach (training programme): the answers you give (goals, level, sex, age, height, weight, injuries, days and duration, notes) and the gym's equipment are sent to Anthropic; not your name or contact details.
  • Nutrition: your nutrition profile (goals, sex, age, weight, height, type of diet, allergies, preferences) is sent without your name, and — for the estimate of a meal — the photo or description you give.

Anthropic processes this information as a sub-processor in order to return the programme or the estimate; under its commercial terms it does not use it to train its models [TO BE CONFIRMED]. Injuries and allergies are health data: you give them only if you want to, and the gym (as the controller) asks for your explicit consent.

Who sees the data

7. What other users see

  • Other players see your name, photo, level, trophies and your place in the ranking, and — in the matches, teams and tournaments you take part in — your participation and results.
  • The venue where you book sees the booking, your name and mobile number, and whether you have paid.
  • The organiser of a tournament or the captain of a team sees the participants and, to tell people with the same name apart, only the last 3 digits of their mobile number.
  • Your mobile number and email are not shown in full to other players.

8. Providers who help us (processors)

  • Hetzner Online GmbH — hosting of the application and the database in data centres in the EU.
  • Stripe — payments by card, Apple Pay, Google Pay, refunds, the businesses' subscriptions (Stripe privacy policy).
  • [SMS PROVIDER] — sign-in codes, invitations and notifications by SMS.
  • [E-INVOICING PROVIDER] — issuing receipts and invoices and transmitting them to AADE's myDATA.
  • [EMAIL PROVIDER] — sending email from the service.
  • [MAP PROVIDER] — the tiles of the venues map; it receives your device's IP address and the area of the map you are viewing, not your account.
  • Google and Apple — only if you choose to sign in with your account there. Google Maps — only at the front desk, when a business looks up its address.
  • Anthropic — only in the gym app and only as described in the section Artificial intelligence. WHOOP / Strava — only if you connect them yourself.

In addition, data is given to AADE (the Independent Authority for Public Revenue, myDATA) for tax documents, and to public authorities only when the law requires it.

9. Transfers outside the European Union

The application and the database are hosted in the EU. Some providers (e.g. Stripe, Anthropic, Google, Apple) may also process data in the USA. In those cases the transfer is made with the safeguards of the GDPR: the provider's certification under the EU–US Data Privacy Framework or the European Commission's Standard Contractual Clauses. You can request a copy of the safeguards at our email.

How long, how, and your rights

10. Cookies and storage on your device

We use only strictly necessary cookies, to keep you signed in and to remember your language. We do not use advertising or statistics (analytics) cookies.

  • gba — your sign-in to your Gymbly account (up to 365 days or until you sign out).
  • gb — your sign-in to the app of a gym (up to 60 days).
  • gbp, gbk, gbsupport — sign-ins of TBHUB staff and partners (not relevant to players).
  • lang — the language you chose (365 days).
  • gbgate — only in the test version, that you entered the access password (30 days).
  • Stripe cookies (e.g. __stripe_mid, __stripe_sid) — only in the payment form, for the security of the payment and fraud prevention.

The app also keeps small preferences on your device (local storage), e.g. which sport you chose last. These do not leave your device.

11. How long we keep data

  • Account and profile: for as long as you have an account. On deletion, they are erased or anonymised.
  • Bookings already played and results: they remain anonymised after deletion (without name, mobile, email), because they are part of the history of the venue and of the other players.
  • Receipts, invoices and payment records: for as long as tax law requires, as a rule 5 years from the end of the financial year to which they relate, including after the account is deleted.
  • SMS codes: a few minutes, until they are used or expire.
  • Error logs: [LOG RETENTION PERIOD].
  • Backups: [BACKUP RETENTION PERIOD]; then they are replaced.
  • Data of gym members: as set by the gym and for as long as its Gymbly subscription lasts.

For the lawyer: The retention period for tax records (5 years, or longer in certain cases) should be checked by a lawyer/accountant.

12. Deleting your account

You can delete your account whenever you want, inside the app or from the Account deletion page.

  • First the bookings are settled: your future bookings are cancelled as if you cancelled them yourself (the court price is refunded, not the service fee) and you leave the matches you take part in. If there is a booking or share that can no longer be cancelled (after the free cancellation limit), the deletion takes place after it has passed.
  • Then your details are anonymised (name, email, mobile, photo, profile, Google/Apple sign-ins), friends, messages, comments and notifications are deleted, and you are signed out of all devices. In teams and tournaments you appear as «Deleted user» («Διαγραμμένος χρήστης»).
  • Bookings already played, results and trophies remain without your name. Receipts remain as they were issued, for as long as tax law requires.
  • Your record at a gym is the gym's record: the deletion removes its link to your account and your sign-in details. To have the record itself deleted, contact the gym.

13. Security

The connection to the service is encrypted (https), passwords are stored only as a hash, sign-in cookies cannot be read by the page's scripts, only those who need it have access to the database, and we keep backups. If a breach occurs that affects you with a high risk, we will inform you, as the GDPR requires.

14. Minors

To have an account of your own you must be at least 16 years old. For younger people, the account is opened and managed by their parent or guardian. If we learn that someone younger has opened an account without a guardian, we will delete it.

15. Your rights

You have the right of:

  • access — to find out what data of yours we hold and to get a copy;
  • rectification — you can correct much of it yourself in your profile;
  • erasure — see Deleting your account;
  • portability — to receive the data you gave us in a machine-readable format;
  • restriction of and objection to processing based on legitimate interest;
  • withdrawal of consent whenever you want (e.g. location permission from your device's settings), without affecting what was done before.

Write to us at support@gymbly.app [TEMPORARY EMAIL — NOT WORKING YET] from the email of your account; we reply within one month. For data concerning your gym, contact the gym (see Who is responsible).

If you believe your rights are being infringed, you can lodge a complaint with the Hellenic Data Protection Authority (Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα, www.dpa.gr).

16. Changes to this policy

If we change this policy, the date at the top will change too. For material changes (e.g. a new purpose or a new type of provider) we will inform you inside the app or by email before they take effect.