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Privacy Policy

Last updated: 17 February 2026

Your privacy is fundamental to AXELON. This Policy describes how we collect, use, and protect your information, in compliance with the General Data Protection Regulation (GDPR), the Brazilian General Data Protection Law (LGPD), and other applicable regulations.

Security Commitment (Bio-Vault):
Your health data and progress photos are encrypted. We do not sell your biometric data to third parties.

1. Data We Collect (Provided by You)

All data collected is voluntarily provided by you to enable the system’s intelligence. Without this data, AXELON cannot adapt your training.

  • Biological Profile: Age, weight, height, gender, body fat percentage, experience level, and pre-existing injuries.
  • Health Data (Wearables): Optional integration with Apple Health/Google Fit for reading HRV (Heart Rate Variability), sleep (deep/REM), resting heart rate, and active calorie expenditure.
  • Bio-Vault (Digital Health Record):
    • Blood tests and hormonal reports (Testosterone, Cortisol, etc.) that you choose to upload for analysis.
    • Physical assessments and body composition tests (DEXA, Bioimpedance).
    • Physical progress photos (encrypted).
  • Nutrition and Routine Data: Meal photos, water intake logs, supplementation, and daily routine schedules.
  • Training Metadata: Loads, repetitions, RPE (Rate of Perceived Exertion), and pain/comfort feedback during exercises.

2. How We Use Your Data

Your data exclusively powers the system’s intelligence:

  • Personalisation and Monitoring: Adjusting volume and intensity based on your recovery, monitoring workout execution in real time, and tracking your progress towards established goals.
  • Score Calculation: Generating your daily discipline and consistency score.
  • Proprietary Algorithm Evolution: Anonymised data is used to refine AXELON’s exclusive mathematical and artificial intelligence models.

3. Storage and Security (Encryption)

We employ rigorous security standards. Your progress photos and sensitive data are stored in encrypted form in the database, meaning they are unreadable without the specific security keys.

However, we believe in full transparency: although we maintain encryption keys in secure and separate environments, no digital system is infallible. In the remote event that a malicious actor gains simultaneous access to both our database and encryption keys, reading the data would be technically possible.

4. Data Sharing

We do not share your personal data with third parties for marketing purposes. We may share data:

  • Legal Obligation: If required by law or court order.
  • Essential Services: With cloud and payment providers (e.g., AWS, Stripe, Google) strictly for service operation.

5. Your Rights (GDPR / LGPD)

You have the right to:

  • Confirm the existence of data processing.
  • Access your data and request correction of incomplete or inaccurate data.
  • Request anonymisation, blocking, or deletion of unnecessary data.
  • Revoke your consent at any time (which may prevent the AI from functioning).

6. Account Deletion

You have full control over your data. There are two ways to permanently delete your account and all associated data:

  • In the app: Go to Settings > Preferences > Delete Account.
  • By e-mail: If you no longer have access to the app, send an e-mail to [email protected] from your registered address.

In both cases, our architecture guarantees the complete purging of all biometric data from Axelon OS within 30 days.

7. Contact

For privacy-related enquiries, contact our Data Protection Officer (DPO) at: [email protected].


Data Controller: LISTA BRASIL LTD (Co. 16868714).