LEGAL
Nana Privacy Policy
APRIL 2026
This policy explains what personal information Nana collects, why we use it, who may process it on our behalf and the rights and choices you have. We have written it to be read — not merely accepted.
CONTENTS
- Introduction
- Who is the Data Controller?
- What data do we process?
- Purposes and legal bases
- Automated decision-making and AI-driven personalisation
- Retention periods
- Recipients and transfer of data
- Security of your data
- Your rights as a data subject
- Cookies and similar technologies
- Changes to this privacy policy
- Contact and complaints
01
Introduction
At Nana, we attach great importance to your privacy and the protection of your data. In this privacy policy, we explain what data we collect, why we collect it, how long we retain it, and what rights you have as a user. Because our app processes health data, some of the data falls under the special categories of personal data (Art. 9 GDPR). We ask for your explicit consent for this.
02
Who is the Data Controller?
The data controller for your data is:
| Company name | Nana Amparo |
| Legal form | BV |
| Registered office | Skiweg 3, 9000 Gent, Belgium |
| Company number | BE1037.941.966 |
| Email (privacy) | hello@nana.coach |
03
What data do we process?
3A. ACCOUNT DATA (PERSONAL DATA)
- Last name and first name
- Email address
- Date of birth
- Password (hashed and encrypted)
3B. HEALTH DATA
The data below are special categories of personal data within the meaning of Art. 9 GDPR. We process these exclusively on the basis of your explicit consent.
| Weight, height, BMI | Entered by user or via integration |
| Cycle data (menstruation start date, cycle length, current phase: follicular, ovulation, luteal) | Entered by user or via integration |
| Hormonal status | Derived from cycle data, entered by the user or via integration |
| Subjective well-being data (energy, mood, recovery) | Entered by user |
| Nutritional intake/eating pattern | Generated by the application |
- Personal goals (performance improvement, health maintenance)
- Food allergies or intolerances/injuries or medical limitations (only what you enter yourself)
3C. DATA VIA WEARABLE INTEGRATION
When you link your wearable (e.g. Polar or Garmin) account, we receive the following data via the relevant API, but exclusively the categories for which you give consent. You can disconnect this integration at any time via the app settings or directly in your wearable account.
- Training activities (type, duration, intensity) and recordings (routes, pace, elevation profile)
- Heart rate measurement (resting and during training) and HRV (heart rate variability)
- Sleep data (sleep stages, duration and quality score)
- Activity data (steps, activity rings)
- Energy expenditure and recovery status (e.g. Polar Recovery Pro)
3D. TECHNICAL AND USAGE DATA
- IP address and device identification
- Operating system and app version
- Log data and crash reports (anonymised)
- In-app behaviour data (screens visited, features used) for UX improvements
- Push notification token (if you have enabled notifications)
04
Purposes and legal bases
| Creating and managing your account | Necessary for the performance of a contract (Art. 6 GDPR) |
| Drawing up personalised nutritional plans | Explicit consent (Art. 6 and 9 GDPR) |
| Drawing up personalised training plans | Explicit consent (Art. 6 and 9 GDPR) |
| Integration with wearable (activity and biometric data) | Explicit consent (Art. 6 and 9 GDPR) |
| Improving the app (analytics) | Legitimate interest, exclusively for non-sensitive and strictly necessary processing (Art. 6 GDPR) |
| Sending transactional emails (account, password) | Necessary for the performance of a contract (Art. 6 GDPR) |
| Sending newsletters and offers | Explicit consent (Art. 6 and 9 GDPR) |
You have the right to withdraw your consent at any time. If consent to collect health data is withdrawn, certain app functionalities may no longer be available.
05
Automated decision-making and AI-driven personalisation
Nana uses artificial intelligence (AI) and machine learning to improve its services. The AI engine processes both the data you provide directly and the data generated by your activity in the app.
The plans generated by Nana are recommendations, not binding decisions. You always have full control: you can reject, adjust, or ignore any suggested meal or training. They do not constitute medical advice, diagnosis, or treatment. Users with medical conditions are advised to consult a healthcare professional before following a plan.
Nevertheless, we apply the safeguards of Art. 22(4) GDPR as best practice:
- You can always request a human review of any algorithmically generated schedule. We do not derive characteristics unrelated to health, fitness, and nutrition. Any schedule that indicates a potential issue triggers a human-review alert, not an automated account restriction.
- We do not use black-box models for health-sensitive recommendations without human expertise and explanation. When third-party AI models are used, we disclose this in the relevant feature in the app.
- We do not use your data to train, fine-tune, or benchmark our AI models. All model training is carried out exclusively on anonymised, aggregated, or synthetic datasets.
| Strict safety measures | The algorithm is programmed with absolute lower limits (e.g., minimum calorie thresholds per sports nutrition guidelines) that cannot be overridden by AI. Any plan that would breach these thresholds is automatically referred for human review. |
| Regular algorithm audits | Our AI models are reviewed at least once a year by an independent expert and checked for bias. |
06
Retention periods
We do not retain your personal data longer than necessary for the purpose for which it was collected, or as long as legally required. Specifically, we apply the following periods:
| Account data | retained for as long as your account is active. After deactivating your account, these are retained no longer than necessary. |
| Health and fitness data | retained for as long as your account is active or until withdrawal of your consent. |
| Wearable data | retained for as long as the integration is active. After disconnecting, synchronised data is deleted within 30 days, unless it has already been incorporated into your personal activity log. |
| Technical log data | retained for a maximum of 12 months and then automatically deleted or anonymised. |
| Billing and accounting data | retained for 7 years in accordance with statutory retention periods. |
07
Recipients and transfer of data
7.1 PROCESSORS
We use selected third parties who process data on our behalf. We conclude a Data Processing Agreement (DPA) with each of them in accordance with Art. 28 GDPR:
| Railway (cloud hosting) | for storage and processing of app data |
| Polar Electro Oy | for API integration; their privacy policy applies to processing on their side |
| Garmin Ltd. / Garmin Connect | for API integration; their privacy policy applies to processing on their side |
| TrainingPeaks LLC | for API integration; their privacy policy applies to processing on their side |
| CookieYes (consent management) | for showing the cookie banner and storing your cookie choices (consent log) |
| Brevo (email) | for marketing emails |
| PostHog (analytics, EU Cloud instance) | for anonymised usage statistics |
| Google Tag Manager (Google Ireland Ltd., tag management) | or loading our website’s analytics and consent tools; it only fires non-essential tags after you give consent via the cookie banner |
| Apple, Google, and RevenueCat | process and manage subscription payments and entitlements for iOS and Android users; payment card data is handled directly by Apple/Google and is never stored by or shared with us |
| Auth0 | for account sign-in, authentication, and transactional emails (account, password) |
| Partners and third parties | only where explicitly provided for and with your consent. |
7.2 TRANSFER OUTSIDE THE EEA
No, all data is processed within the European Economic Area.
7.3 NO SALE OF DATA
We never sell your personal data to third parties, nor do we use it for third-party advertising.
08
Security of your data
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or disclosure.
In the event of a serious data breach that poses a risk to your rights and freedoms, we will notify you personally as soon as possible.
09
Your rights as a data subject
Under the GDPR, you have the following rights. A request to exercise these rights can be submitted via hello@nana.coach
| Right of access (Art. 15) | You can request an overview of all personal and health data we process about you. |
| Right to rectification (Art. 16) | You can have incorrect or incomplete data corrected or supplemented. |
| Right to erasure (Art. 17) | You can request deletion of your data (“right to be forgotten”), subject to legal retention obligations. |
| Right to restriction (Art. 18) | You can request a temporary restriction of processing. |
| Right to data portability (Art. 20) | You can request your data in a structured, machine-readable format (JSON / CSV) and have it transferred. |
| Right to object (Art. 21) | You can object to processing based on legitimate interest. |
| Right to withdraw consent (Art. 7) | You can withdraw your consent at any time, including for health data and wearable integrations. |
| Right to lodge a complaint (Art. 77) | You can lodge a complaint with the Data Protection Authority (GBA): www.gegevensbeschermingsautoriteit.be. Drukpersstraat 35, 1000 Brussel. contact@apd-gba.be |
10
Cookies and similar technologies
The Nana app and website use cookies and similar technologies. We distinguish:
| Strictly necessary cookies | required for the app to function (session authentication). No consent required. |
| Analytical cookies | for insight into the use and performance of the app. Require your consent. |
| Preference cookies | for remembering your settings and language preference. Require your consent. |
You can manage cookie preferences in the app or in your browser.
11
Changes to this privacy policy
We may update this privacy policy from time to time, for example, if the app receives new features or if legislation changes. We will inform you of material changes via the app or by email.
The most up-to-date version is always available at https://nana.coach/privacy. The date of the last amendment is stated at the top of this policy.
12
Contact and complaints
Do you have questions about this privacy policy or about the processing of your personal data? Please contact us: hello@nana.coach