SCD Privacy Policy

Effective Date: September 05, 2025

Last Updated: November 24, 2025

This Privacy Policy ("Policy") provides information about the personal information that SCD Project LLC dba SCD ("SCD," "we," "us", or "our") may collect from users ("you" or "your") of our website ("Site") and/or our application(s) ("App") (where the Site and App are collectively referred to as "Service") and how we use and share such information.

IMPORTANT: SCD operates as a marketplace and distribution platform connecting fitness trainers and coaches with end users. We do not claim ownership of, and we do not process or use, trainer-created workout content or personal data relating to trainers and their clients except as strictly necessary for platform operations, payment processing, and legal compliance.

By using the Service, you agree to the terms of this Policy. We reserve the right to modify this Policy from time to time, and any modifications will take effect upon posting. If we make material changes, we will notify you via email or a prominent notice on the Service. Please review our Policy regularly. Your continued use of the Service after changes are posted constitutes your agreement to the changes. If you do not agree to the terms of this Policy, please discontinue your use of the Service.

Summary of Key Principles

Marketplace Model: SCD provides technology infrastructure for content distribution. We are not the creator, owner, or controller of trainer workout content. Trainers retain all intellectual property rights in their content.

Limited Data Processing: We collect and process personal data only to the extent necessary to:

No Secondary Use: We do not use trainer content, workout data, or user fitness information for advertising, profiling, third-party sales, or any purpose unrelated to platform operation.

Trainer Independence: Trainers are independent contractors, not SCD employees. Personal data shared between trainers and their clients is controlled by the trainers, not SCD.

1. Information We Collect

a. Information You Provide Directly:

When you create an account, make purchases, or interact with the Service, you may provide:

Trainers may additionally provide:

b. Information Collected Automatically:

When you use the Service, we automatically collect certain technical information:

c. Information from Third Parties:

Social media information if you connect your account to social media platforms (name, profile picture, email)

Payment processing information from our payment service providers

Analytics data from third-party analytics services

2. How We Use Your Information

We use collected information for the following purposes:

a. Platform Operation:

b. Platform Improvement:

c. Security and Fraud Prevention:

d. Legal Compliance:

e. Communications:

IMPORTANT LIMITATION: We do NOT use trainer workout content, user fitness data, or personal workout information for advertising, third-party sales, behavioral profiling, or any commercial purpose unrelated to platform operation.

3. Trainer Content and Data Ownership

a. Trainer Intellectual Property:

Trainers retain all intellectual property rights in their workout content. SCD's access to and processing of trainer content is limited to technical hosting, delivery, and moderation as described in our Terms of Use.

b. Trainer-Client Relationships:

When users purchase access to trainer content, any personal data shared between the trainer and user (such as progress tracking, personal messages, or coaching notes) is controlled by the trainer, not SCD. Trainers are responsible for their own data protection practices in their relationships with clients.

c. SCD's Limited Role:

SCD operates as a technology platform and payment processor. We do not control, analyze, or commercialize the substance of trainer-client interactions or personal fitness data generated through trainer programs.

4. How We Share Your Information

a. We Do Not Sell Personal Information:

SCD does not sell or rent your personal information to third parties.

b. Service Providers:

We share information with third-party service providers who perform services on our behalf:

These service providers are contractually required to protect your information and use it only for the purposes we specify.

c. Trainers:

When you purchase trainer content, the trainer may receive limited information about you (username, purchase date, access period) to facilitate content delivery and support.

d. Business Transfers:

If SCD is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred to the acquiring entity, subject to continued protection under this Policy.

e. Legal Requirements:

We may disclose your information if required by law, court order, or governmental authority, or if we believe in good faith that disclosure is necessary to:

f. With Your Consent:

We may share information with third parties when you explicitly consent to such sharing.

5. International Data Transfers

SCD is based in Georgia and operates globally. Your personal information may be transferred to and processed in countries outside your country of residence, including the United States and European Union member states.

When we transfer personal data internationally, we implement appropriate safeguards, including:

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

User accounts: Retained while your account is active and for a reasonable period thereafter to comply with legal obligations and resolve disputes.

Trainer content: Retained as long as the trainer maintains an active account and makes content available, plus a reasonable archival period for users who purchased access.

Payment and transaction data: Retained as required for tax, accounting, and regulatory compliance (typically 7-10 years).

Marketing communications: Retained until you opt out or request deletion.

You may request deletion of your personal information by contacting us at info@sportclubdigital.com. Note that we may retain certain information as required for legal compliance or legitimate business purposes.

7. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

a. Access and Portability:

Request a copy of the personal information we hold about you in a structured, commonly used format.

b. Correction:

Request correction of inaccurate or incomplete personal information.

c. Deletion:

Request deletion of your personal information, subject to legal and contractual obligations.

d. Objection and Restriction:

Object to or request restriction of certain processing activities.

e. Withdraw Consent:

Where processing is based on consent, withdraw consent at any time (without affecting prior lawful processing).

f. Opt-Out of Marketing:

Unsubscribe from marketing emails using the link in each email or by contacting us.

g. Do Not Track:

Our Service does not respond to Do Not Track signals, but you may adjust browser and device privacy settings.

h. Data Protection Authority:

Lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

To exercise your rights, contact us at info@sportclubdigital.com. We will respond within the timeframe required by applicable law (typically 30 days).

8. Regional Privacy Rights

a. European Union and United Kingdom (GDPR/UK DPA):

If you are located in the EU or UK, you have the rights described in Section 7 above. Our legal basis for processing your personal data includes:

b. California (CCPA/CPRA):

If you are a California resident, you have the right to:

To exercise CCPA rights, contact us at info@sportclubdigital.com or call [phone number if available].

c. Other Jurisdictions:

We respect privacy rights under applicable laws in other jurisdictions, including Brazil (LGPD), Canada (PIPEDA), Australia (Privacy Act), and others. Contact us to exercise your rights.

9. Children's Privacy

The Service is not intended for individuals under the age of 13 (or under 16 in the European Union). We do not knowingly collect personal information from children. If you are under the applicable age limit, do not use the Service or provide any personal information.

If we learn that we have collected personal information from a child without parental consent, we will delete that information promptly. If you believe we have collected information from a child, contact us at info@sportclubdigital.com.

10. Security

We implement reasonable technical, administrative, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

11. Third-Party Services and Links

The Service may contain links to third-party websites, services, or applications ("External Sites"). This Policy does not apply to External Sites, and we are not responsible for their privacy practices.

When you interact with External Sites (such as payment processors or social media platforms), those third parties may collect information about you. We encourage you to review their privacy policies.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, legal requirements, or Service features. When we make material changes, we will:

Your continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

13. Apple-Specific Notice

To the extent you access the Service through a mobile application downloaded from the Apple App Store:

Any questions or concerns about data practices should be directed to SCD at info@sportclubdigital.com

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: info@sportclubdigital.com

Mail: SCD Project LLC
Georgia, City Tbilisi, Saburtalo District, Tashkenti Lane, N9

Data Protection Officer (if applicable): [Contact information if DPO appointed]

We will respond to your inquiry within 30 days (or as required by applicable law).

Last Updated: November 24, 2025

By using the SCD Service, you acknowledge that you have read and understood this Privacy Policy.