The “Data” Annex
Version: 2026-10-05 · In force from 5 October 2026
The contract is in English. If a translation says something different, the Romanian version prevails.
Annex to the REPIVO General Commercial Conditions for Gyms and to the Conditions for Trainers
Art. 1. Purpose of the annex
1.1. The annex sets out what data REPIVO uses, whose it is, how REPIVO uses it and what rights the gym or the trainer retains.
1.2. The annex forms part of the contract. If it says something different from the General Commercial Conditions for Gyms or from the Conditions for Trainers, the annex prevails. The accepted Offer prevails over the annex.
1.3. In the annex, the “client” means the gym or the trainer that has concluded the contract with REPIVO.
Art. 2. Categories of data
| Category | What it covers | Is it personal data? |
|---|---|---|
| A. Operational data | the gym’s machines and inventory, their models and brands, their placement in the gym, the aggregate number of scans and reports per machine and per time slot (with no link to a person), faults found, the gym’s opening hours and public information, data transmitted by REPIVO devices installed in the gym, the estimated occupancy of machines and areas, and anonymous flows of people, with no link to a person | no |
| B. Training activity data | the workouts of Members and of trainers’ clients: exercises, sets, repetitions, weights lifted, durations, machines used, scans | yes, of Members |
| C. Health data | body weight, height, measurements, the physical goal described by the person, weights imported from Health Connect or Apple Health | yes, special category (art. 9 GDPR) |
| D. Account, team and invoicing data | names and emails of the team, roles, company details, addresses, payments | yes, for natural persons |
Individual records of scans and reports, linked to a Member’s account, are category B data.
Art. 3. Operational data (category A)
3.1. The client remains the holder of the operational data.
3.2. The client grants REPIVO a non-exclusive, perpetual, royalty-free licence, valid worldwide and transferable to REPIVO’s affiliated companies. The licence allows REPIVO to use the operational data in aggregate form, for any purpose, including commercial, in accordance with art. 7 and 8. The licence also allows REPIVO to use the operational data, in aggregate or anonymised form, to calibrate and train its models and algorithms, including to create reference values common to several gyms for the same machine model, for example for maintenance. When such values are shown to other gyms, they comply with art. 7.
3.3. The licence does not prevent the client from using, copying or transmitting its own operational data, to anyone and for any purpose.
3.4. The licence continues after termination of the contract, only for the anonymous statistics already created or created from data collected while the contract was in force, and for the models and algorithms already calibrated or trained with this data.
Art. 4. Training activity data (category B)
4.1. REPIVO is an independent controller for this data, in accordance with the Privacy Policy. The client does not receive Members’ individual data. The trainer sees their clients’ data only to the extent that those clients share it with the trainer.
4.2. REPIVO uses this data to provide the service and to create anonymous statistics, in accordance with art. 7.
4.3. The anonymous statistics created from this data may be published, licensed or sold, in accordance with art. 7 and 8.
Art. 5. Health data (category C)
5.1. Category C data is used only to provide the service to the person concerned and, if that person chooses, to their trainer. Use is made only with the person’s explicit consent.
5.2. Category C data does not enter any statistics, whether public, internal or sold.
Art. 6. Account, team and invoicing data (category D)
Category D data is used only to provide the service, to communicate with the client, to issue invoices and to comply with legal obligations. It is not used commercially and does not enter statistics.
Art. 7. Anonymous statistics
7.1. Anonymous statistics are aggregate figures, created from category A and B data, which do not allow the identification of a person or of a gym, by the means that a person could reasonably use.
7.2. Each figure in a statistic that is published or made available to a third party meets at least these thresholds:
- (a) it comes from at least 20 distinct persons;
- (b) it comes from at least 5 distinct gyms;
- (c) no gym accounts for more than 50% of the figure’s value.
7.3. Exception: figures concerning a single gym may be shown to that gym or may be published with its agreement, provided that each figure comes from at least 20 distinct persons. The threshold applies to figures created from category B data (for example “the gym’s Members lifted 312 tonnes”). The operational statistics that the Portal shows the gym as part of the service (the number of scans per machine, peak hours, the number of Members who scanned) are not subject to this threshold, because they do not show who scanned or what they trained.
7.4. REPIVO may use the anonymous statistics, for example:
- (a) to improve the service: exercise suggestions, the catalogue of machines, new functions;
- (b) for clients: comparisons with the average of other gyms (benchmarks), including as a paid function;
- (c) in industry reports made available to manufacturers, distributors, investors or other partners, including for a fee;
- (d) publicly: figures about the whole network (“REPIVO Members lifted 5,000 tonnes this year”), rankings, press and marketing materials.
7.5. REPIVO may revise the anonymisation methods following the guidelines of the data protection authorities, without lowering the thresholds in art. 7.2.
Art. 8. What we never do
REPIVO does not sell, rent or make available to third parties:
- (a) data concerning an identified or identifiable person;
- (b) data concerning an identifiable gym, without that gym’s agreement;
- (c) contact lists of Members, teams or clients;
- (d) category C data, in any form.
Art. 9. Access and export
9.1. The client may view and export at any time the operational data and statistics of its own gym, in a structured format (CSV), from the Portal.
9.2. The right of export continues for 12 months after termination of the contract, through historical access to the Portal. After this period, REPIVO may delete the non-aggregated operational data. Anonymous statistics already created are not deleted.
9.3. REPIVO does not make export conditional on payment of any amounts other than those already owed under the contract.
9.4. The export covers all category A data and the content uploaded by the gym: logo, photographs, announcements, the gym’s plan and the assignment of tags to machines.
9.5. Switching provider (Regulation (EU) 2023/2854 [the EU Data Act], Chapter VI):
- (a) the gym may request to switch to another provider or to its own infrastructure with a notice of no more than 30 days;
- (b) after the notice, a transition period of 30 days follows, during which REPIVO offers reasonable assistance for export;
- (c) export and switching provider involve no additional cost for the gym;
- (d) after the retrieval period in art. 9.2, REPIVO deletes in full the gym’s non-aggregated category A data and the content it uploaded, and confirms the deletion on request;
- (e) REPIVO notifies the gym by email 30 days before historical access to the Portal is closed.
Art. 10. Commercial reference and rankings
10.1. For the duration of the contract, REPIVO may show publicly that the gym uses REPIVO: with the gym’s name and logo, on the website, on the map and in the list of partner gyms, in presentations and in marketing materials, including with images of the gym from the App (the gym’s page and the 3D plan).
10.2. REPIVO may create for the gym materials bearing its name and logo, for example posters, banners and materials for Members.
10.3. REPIVO does not use the gym’s name and logo in a way that harms its image and does not suggest anything other than that the gym uses REPIVO. At the gym’s request, REPIVO withdraws or corrects a specific material.
10.4. The gym agrees to appear by name in public rankings and comparisons between gyms, created from statistics that comply with art. 7.3. The gym may withdraw this agreement at any time, by email to [email protected]. The withdrawal applies to materials created after it is received.
10.5. After termination of the contract, REPIVO removes the gym from the map and from the list of partner gyms within no more than 30 days. Materials already printed or published need not be withdrawn.
Art. 11. Trainers
For trainers, the annex applies as follows:
- (a) category A does not apply, if the trainer does not manage a gym;
- (b) the trainer’s clients are treated as Members in categories B and C;
- (c) the trainer appears in statistics only under the conditions of art. 7.2, and art. 10 applies to the trainer only if they give their separate agreement, from the Portal.
Art. 12. Changing the annex
The annex is changed according to the rules in art. 15 of the General Commercial Conditions for Gyms, and in art. 12 of the Conditions for Trainers respectively. A change that lowers the thresholds in art. 7.2, extends the use of category C data or restricts export is always a material change.