Privacy Policy

11.1 Controller and roles

Ironstead is the controller for the coach directory on iron-stead.com, that is for coach profiles, requests, athlete posts (in which athletes describe the coaching they are looking for), offers, reviews and notices (contact details in section 1). Ironstead does not act on behalf of a coach here. When a coach receives your request or sees your athlete post, the coach processes this information as a controller in their own right to decide on coaching you. Once your connection is active, section 1 applies to the coaching data: the coach is the controller and Ironstead processes the data on the coach's behalf. The rules of the directory are set out in the coach directory terms of use.

11.2 Coach profiles

For your coach profile we process: display name, profile photo, short description, specialties, languages, optionally location, qualifications, a link to your website, a price "from €… per month" and a price note, your legal notice details (name, address, email address, other required details) or the link to your legal notice, your confirmation that you offer coaching as a business, with its time, the version of the coach directory terms of use you accepted, whether you accept athletes, the status of the profile, the times of submission, approval and review, the reasons we give you if we reject it, and any internal note by Ironstead on your profile.

Once approved, your profile including photo and legal notice is publicly accessible on the internet, to anyone and without login. Search engines can find and display it. The profile's address contains an identifier formed from your display name that does not change later. The legal basis for publishing and operating your profile is the contract for participating in the directory (Art. 6(1)(b) GDPR). Under the Coach Directory Terms, you must provide at least your name, an address at which legal documents can be served and an email address for your profile, directly or through a legal notice link. You must provide further provider information where required by the law applicable to you; for coaches based in Germany, this includes § 5 DDG. We publish the details or link as part of your profile.

When you submit your profile, we notify the operator through the Telegram messenger with only a case number and a link to our admin page, without names, account identifiers or profile content. Before the first approval a person at Ironstead reviews your profile. We compare your email address, your legal notice address and, if any, your Paddle customer number with the abuse-prevention entries (section 11.9). The legal basis for this comparison is our legitimate interest in protecting the directory from abuse (Art. 6(1)(f) GDPR). A person decides on approval, not an automated process.

We use the time you last used Ironstead to show your profile as "Currently fully booked" after 30 days without use and to tell you so by email. From the times of your answers to requests we calculate the share of requests you answered within 72 hours and use it to form the order in the directory (§ 6 of the coach directory terms of use). We do not show this value publicly and do not pass it on. The legal basis in each case is Art. 6(1)(b) GDPR.

If a change contains a link or contact details, such as a changed link to your website (§ 7(4) of the coach directory terms of use), we store the changed version, the time of the last change and your choice to hide the previous version until we accept or reject the change or you discard it; then we delete the changed version, or, if we accept the change, it becomes the visible version. We notify the operator of such a change through Telegram with only a case number and an admin link. The legal basis is Art. 6(1)(b) GDPR. The changed version is part of your access request and your data export.

An internal note on your profile is part of your data. You receive it with your access request under Art. 15 GDPR and with your account's data export.

We store your profile until you delete your account, also when it is unlisted, rejected or removed from the directory; for rejection, unlisting and removal we also store the reasons there. If you replace your photo, we delete the previous one. If the previous photo is locked after a notice, we keep it as described in section 11.8 for locked photos.

11.3 Requests to a coach

When you send a coach a request, we process: your goal, your experience, your training days per week, your optional message, the time, the status and the outcome of the request (accepted, declined, withdrawn, expired) and the time of a reminder to the coach. Before your first request, first athlete post or first review we also store the time at which you confirmed that you are at least 18 years old, and the version of the coach directory terms of use you last accepted, with its time. In Ironstead the request creates an unconfirmed connection between your account and the coach's account.

Apart from our processors (sections 8 and 11.6), the only recipient is the coach you chose; we do not make the details of your request available to any other coach. The coach sees your first name (without a first name: "Athlete"), your answers and your message. Once your connection is active, the coach sees, as with any connection, your name, your email address and the training data that Ironstead shows to coaches of connected athletes (section 1). If the coach accepts while they have no free place, the connection waits until a place is free; until then the coach does not see your email address. The coach receives a notification about your request and, after 48 hours without an answer, a reminder. You receive a notification when the coach accepts or declines or when the request expires.

The form has no field for health data, and the directory is not intended for such information. Please do not include information about injuries, illnesses, medication or other health data in the message. If we become aware of such information, for example through a notice, we delete the free text concerned. The coach may already have read it by then.

The legal basis for sending and handling the request is the contract for using the directory and steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR).

An open request expires after 14 days. If a request is declined, withdrawn or expired, we keep its details for another 90 days to show them to you and the coach in the overview, to calculate the response rate for the order and to examine notices, and then delete them. If it is accepted, we delete your message as well as goal, experience and training days after 90 days. We keep coach, athlete, the origin (request or offer), the times and the outcome as a record of the connection made through the directory for as long as the connection exists, and delete them 90 days after it has ended. They are part of your data export, and we use them for aggregated evaluations (section 11.7). The legal basis for keeping data after a request is closed is our legitimate interest in calculating the order, examining notices, documenting the placement and evaluating the directory (Art. 6(1)(f) GDPR). We store the status of the connection request in your account as for other connections. If you delete your account, we delete all details of your requests.

11.4 Athlete posts and offers

For an athlete post we process your goal, your experience, your training days per week, your optional message, the times of creation, expiry and closing, and the status. For an offer we process the coach making it, their message, the status and the times. Section 11.3 applies accordingly to health information.

Your athlete post is visible only to logged-in coaches with a published profile. They see your first name and the details of the athlete post, no email address and no other contact details. The athlete post is not public and cannot be found through search engines. A coach does not see your athlete post while your connection in Ironstead is active or while there is an open connection request between you. With a paused connection or one not yet activated, your athlete post may be visible to that coach.

When a coach makes an offer, you see their display name, their profile and their message, and we notify you. If you accept an offer, we connect your accounts. The connection may first wait for a free place with the coach; the coach sees your email address and your training data only once the connection is active. The other offers count as declined. The legal basis is Art. 6(1)(b) GDPR.

An athlete post expires after 30 days; you can close it earlier. At the latest 90 days after it was closed, expired or settled by an accepted offer, we delete the athlete post and all offers on it. Until then we keep it to show it in your overview and to examine notices (Art. 6(1)(b) and (f) GDPR). For an accepted offer, the record of the connection under section 11.3 applies. If you delete your account, we delete your athlete post and the offers on it immediately. If a coach deletes their account, we delete their offers.

11.5 Reviews

For a review we process the stars, the text, the times, your account and the coach reviewed, and also any reply by the coach. We check whether you may review using the connection data: your connection with the coach must have been active for at least 30 days in total.

Your review appears publicly with your first name on the coach's profile as long as the profile is published. The legal basis for the check and the publication is the contract for using the directory (Art. 6(1)(b) GDPR). For coaches, the publication of reviews and replies is part of participating in the directory (Art. 6(1)(b) GDPR).

When you delete your account, you can choose to delete your reviews as well. If you do not, we remove the link between the review and your account. The review then shows "Former athlete"; stars and text remain. The legal basis is our legitimate interest, and that of coaches and visitors, in complete and undistorted reviews (Art. 6(1)(f) GDPR). If reviews disappeared with every account deletion, the overall picture could be changed on purpose. The text may still allow conclusions about you, for example for the coach, who knows their athletes. The review is therefore not anonymous in every case. You can ask us to delete it at any time (Art. 17 and Art. 21 GDPR); write to datenschutz@iron-stead.com and give us details that let us attribute the review to you (Art. 11(2) GDPR), for example the coach, the approximate date and the wording.

You can delete your review yourself at any time. A review or reply we hid after a notice is kept as evidence of the decision for as long as the notice (section 11.8), at most until you delete it or the coach deletes their account. If the coach deletes their account, we delete all reviews about them.

11.6 Notifications

For the directory we notify you in your account, by push and by email:

• as a coach: about incoming requests and once after 48 hours without an answer, about accepted offers, about the approval or rejection of your profile, when your profile shows as fully booked after 30 days without use, and when your profile photo was removed;
• as an athlete: about the answer to your request, about its expiry and about offers on your athlete post;
• all users: about decisions on your content, the receipt of your notices and the decision on them.

The notification settings have one switch each for push and for email for "request" (incoming requests, reminder, accepted offers), "answer" (acceptance, rejection and expiry of your request) and "offer" (offers on your athlete post). All are on by default. Notifications in your account and necessary emails serve the performance of the contract (Art. 6(1)(b) GDPR). We send push notifications only with your consent under section 8; the switches additionally limit the events for which you receive them. We send messages about decisions on your content and on your notices regardless of the switches because Art. 16 and 17 DSA require them (Art. 6(1)(c) GDPR).

We send emails through Resend (section 2).

11.7 Profile views and evaluations

When someone opens a coach profile, we increase a counter for that profile and that day. For this counter we store only the profile opened, the day and the number of views; we do not link an IP address, an account or a visitor identifier to it. We process the IP address only briefly in memory to limit excessive requests; the legal basis is our legitimate interest in preventing manipulation of the counter and excessive requests (Art. 6(1)(f) GDPR). We delete the daily counters after 400 days. Independently of this, sections 2 "Data processed" and 7 "Reach measurement" apply to visits to the website.

From daily counters, requests, acceptances, athlete posts, offers and the records under section 11.3 we form aggregated figures, for example how many athletes connected through the directory are still actively connected after 60 days. Only Ironstead sees these figures. The legal basis is our legitimate interest in measuring and improving the use of the directory (Art. 6(1)(f) GDPR).

11.8 Notices and moderation decisions

When you report content, we process your account, the reported content, the reason, your declaration and explanation, the time and the processing status, as well as our decision with reasons, its time and the person who decided. For notices by email we process your email address and the content of your message. We confirm receipt of your notice and tell you our decision by email. If we take a measure against content, we store the measure, its reasons and the sending of the statement of reasons to the author.

The legal basis for examining notices, the messages to the person reporting and the statement of reasons to the author is compliance with our legal obligations (Art. 6(1)(c) GDPR in conjunction with Art. 16 and 17 DSA). We base our voluntary complaint procedure, the enforcement of our terms of use, the documentation of decisions and aggregated figures on notices on our legitimate interest in a lawful and safe directory (Art. 6(1)(f) GDPR).

The author of content we act against receives a statement of reasons with the content and the ground, but not your name, unless this is exceptionally strictly necessary. Where there are indications of certain serious criminal offences, we inform the law enforcement authorities (Art. 18 DSA) and transmit the necessary data. We notify the operator of incoming notices through the Telegram messenger with only the case number and a link to our admin page, without names, account identifiers or the text of the notice.

For a notice with the reason "depiction of child sexual abuse" or "illegal content", the system first locks a profile photo automatically. The profile stays visible with a placeholder. A person then examines the notice and decides whether the lock continues or the photo is released. You can have the lock reviewed at abuse@iron-stead.com and state your position.

We delete notices on texts and photos in the coach directory, notices by email and the decisions stored with them at the end of the third calendar year after the decision. If you delete your account before then, we remove the link between your notices and your account. We keep a locked profile photo while the case is open and delete it 6 months after the final decision, unless a criminal complaint, a legal dispute or a request from an authority is still open; then until it is closed. We hand depictions of child sexual abuse to the law enforcement authorities and delete them as soon as the authority confirms receipt or demands their deletion. We store decisions without a notice, for example the rejection, unlisting or removal of a profile, with their reasons on the profile (section 11.2).

11.9 Abuse prevention after a coach account is deleted

When a coach who had a directory profile deletes their account, we store an abuse-prevention entry only if there is cause: the coach was removed from the directory, there is an internal note by Ironstead with concrete, documented facts about misuse of the directory, or the average of at least 3 visible reviews is below 3.0 stars. Without one of these causes we store nothing. The entry contains:

• a keyed hash (HMAC) of the email address,
• a keyed hash of the normalised legal notice address, if the coach entered their legal notice in the fields,
• a keyed hash of the Paddle customer number, if any,
• the number and average of visible reviews, without texts,
• Ironstead's internal note, if it is the cause,
• whether the coach was removed from the directory,
• the time of deletion.

The purpose is to recognise whether someone submits a profile with another account to evade a removal from the directory, documented misuse or their previous reviews. A low review average proves neither a violation of the law nor misuse; it serves only to have a person check, on a later submission, whether the review history is being evaded. When someone submits a profile, we compare email address, legal notice address and Paddle customer number with these entries. If there is a match, the reviewing person at Ironstead sees a warning with the stored figures and, if present, the note. That person also checks whether the match may be a coincidence, for example a shared business address. A match alone does not lead to rejection.

The legal basis is our legitimate interest, and that of athletes, in protecting the directory from abuse, false profiles and the evasion of measures and reviews (Art. 6(1)(f) GDPR). The hashes do not contain the email address, the address or the Paddle customer number in plain text. Because we know the key, however, we can check whether a given value matches an entry. The entry is therefore pseudonymised, not anonymous. We delete it 2 years after the account was deleted. You can request access to an entry (Art. 15 GDPR) at datenschutz@iron-stead.com. To find your entry, we compute the hash of the email address you give us.

Right to object: you can object to this processing at any time on grounds relating to your particular situation (Art. 21 GDPR); a message to datenschutz@iron-stead.com is enough. We then delete the entry unless compelling legitimate grounds override, for example documented misuse.

11.10 Your rights in the directory

Your rights under section "Your rights" apply. Access and data export also cover your directory profile including any internal note by Ironstead, your requests as an athlete and the requests to you as a coach, your athlete posts with the offers received, your offers, the reviews you gave or received, and your notices, without naming the person at Ironstead who decided. Access and data export do not include the reason why we keep a locked profile photo beyond the period in section 11.8, for example an open criminal complaint. You can correct or delete most details yourself in the dashboard or on the "Find a coach" page. You can withdraw requests, close athlete posts, delete reviews and end your use of the directory.

Right to object under Art. 21 GDPR: where we process data on the basis of our legitimate interest (sections 11.2 comparison on submission, 11.3 and 11.4 retention after closing, 11.5 reviews after account deletion, 11.7, 11.8 and 11.9), you can object to this processing at any time on grounds relating to your particular situation. A message to datenschutz@iron-stead.com is enough. We then stop processing the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims.

11.11 Retention at a glance

• Coach profile with the reasons for decisions: until the account is deleted. Changed version under review: until we accept or reject it or the coach discards it.
• Open request: at most 14 days. Declined, withdrawn and expired requests: 90 days after closing. Accepted requests: message, goal, experience and training days 90 days; record of the connection until 90 days after the connection ends.
• Athlete post with offers: open at most 30 days, then at most 90 days.
• Age confirmation, accepted terms version with its time, confirmation of coaching as a business and notification settings: until the account is deleted.
• Reviews: until you delete them or the coach's account is deleted; after your account is deleted, without a link to you, until you ask for deletion. Hidden reviews and replies: as long as the related notice.
• Daily profile-view counters: 400 days.
• Notices on texts and photos, notices by email and the decisions on them: until the end of the third calendar year after the decision.
• Required directory emails (contract confirmation, statements of reasons, messages about notices): until the account is deleted. We delete the content of an email about a notice together with the notice; after that only the type, reference, status and times of sending remain.
• Locked profile photos: 6 months after the final decision; while a criminal complaint, a legal dispute or a request from an authority is open, until it is closed; depictions of child sexual abuse until the authority confirms receipt or demands deletion.
• Abuse-prevention entry (only with cause under section 11.9): 2 years after the coach account is deleted.

Open Food Facts: where the food catalog comes from and how we prepare it

Food search results and food details contain information from Open Food Facts. The Open Food Facts database and the catalog we build from it are available under the Open Database License (ODbL 1.0). This description of how we build the catalog is available free of charge under section 4.6(b) of the licence.

Open Food Facts / Open Database License (ODbL 1.0)

Empty or malformed lines are skipped. We start from the complete Open Food Facts product export: openfoodfacts-products.jsonl.gz

We keep a product only if it has a barcode, a product name and values for energy, protein, carbohydrates and fat per 100 g or 100 ml. We read nutrition values from both Open Food Facts formats: the per-100 g fields and, for newer entries, the nutrition of the product as sold. We do not filter by country and do not check the values further.

From each product we keep the name, the first brand, the barcode, energy, protein, carbohydrates, fat, fibre, sugars, salt and saturated fat per 100 g, the serving size and the number of scans. As the name we show the English product name, else the general one, else the German one. If the kcal value is missing we convert the kJ value (divided by 4.184, rounded to one decimal). We keep no other data and no images.

The catalog is a separate database file, kept apart from the food logs and own foods of our users. Each product gets its own ID. We add no content from other sources to the catalog.

For search we store the names of each product (general, English, German) with the brand, separately its generic names (for example sugar), and the name in lowercase without umlauts. From all names we build a list of the words of at least four letters that occur in at least three products; search uses it to correct typos. Among equally good matches, products with more scans rank higher. Duplicate products are not merged.

Download the method description as text (German and English)