Privacy Policy

1. Introduction

Intero Performance, Inc. (“Intero,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use the Intero platform, website at tryintero.com, and related services (collectively, the “Platform”).

Please read this Privacy Policy carefully. By using the Platform, you consent to the data practices described in this Policy.

2. Information We Collect

2.1 Information You Provide Directly

• Account registration information: name, email address, password
• Payment information: processed by Stripe; Intero does not store credit card numbers
• Self-report data: daily logs across five dimensions (sleep quality, perceived stress, physical load, emotional events, cognitive load)
• HRV and biometric data: manually entered heart rate and HRV readings
• Conversation content: messages exchanged with the AI coaching system
• Contextualizer data: event logs including event type, intensity, body sensations, and contextual notes

2.2 Information Collected Automatically

• Log data: IP address, browser type, pages visited, time and date of visits, time spent on pages
• Device information: device type, operating system, unique device identifiers
• Usage data: features used, frequency of use, interaction patterns with the Platform
• Cookies and similar tracking technologies (see Section 7)

2.3 Information from Third-Party Services

• Wearable device data: where you connect a wearable device (Apple Watch, Polar H10), we receive biometric data you authorize through the applicable device platform (Apple HealthKit, Polar API)
• Authentication data: if you use third-party authentication, we receive information consistent with your authorization

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the Platform
• Generate personalized AI coaching responses using the Intero methodology
• Create and track your individual performance baseline and development arc
• Process payments and manage your subscription
• Send transactional emails (account confirmation, billing, protocol reminders)
• Improve the Platform, methodology, and AI coaching quality
• Respond to your inquiries and provide customer support
• Monitor and analyze usage patterns to improve user experience
• Comply with legal obligations
• Protect against fraudulent, unauthorized, or illegal activity

4. Health and Biometric Data — Special Handling

The Platform collects and processes health-related and biometric data including heart rate, heart rate variability, self-reported stress, and sleep quality. We treat this data with heightened care.

4.1 How We Use This Data

Health and biometric data is used exclusively to:

• Generate personalized coaching responses and protocol recommendations
• Track your individual baseline and development arc
• Provide trend analysis within your personal dashboard
• Improve the accuracy and relevance of AI coaching responses

4.2 What We Do Not Do With This Data

• We do not sell health or biometric data to any third party
• We do not share health or biometric data with advertisers
• We do not use health or biometric data for any purpose other than providing the Platform services to you
• We do not use your data to make automated decisions that produce legal or similarly significant effects

4.3 HIPAA Notice

Intero is not a covered entity under the Health Insurance Portability and Accountability Act (HIPAA). The data you provide is not protected health information (PHI) as defined under HIPAA. The protections described in this Policy are contractual, not regulatory under HIPAA.

5. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information. We may share your information only in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who assist us in operating the Platform:

• Stripe: payment processing
• Anthropic: AI infrastructure (conversation data processed to generate coaching responses)
• Neon/Netlify: database hosting and platform infrastructure
• Resend: transactional email delivery

All service providers are contractually required to use your information only to provide services to us and to maintain appropriate security measures.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (such as a court or government agency).

5.3 Business Transfers

If Intero is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you of any such change.

5.4 Protection of Rights

We may disclose your information where we believe disclosure is necessary to protect the rights, property, or safety of Intero, our users, or others.

5.5 With Your Consent

We may share your information for any other purpose with your explicit consent.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide Platform services. If you cancel your account, we will retain your data for a reasonable period following cancellation to allow for account reactivation, after which we will delete or anonymize your personal information, except where we are required by law to retain it.

Anonymized and aggregated data that cannot be used to identify you may be retained indefinitely for Platform improvement purposes.

7. Cookies and Tracking

The Platform uses cookies and similar tracking technologies to operate the Platform, maintain your session, and analyze usage. You can control cookie settings through your browser settings, though disabling certain cookies may affect Platform functionality.

We do not use third-party advertising cookies or behavioral tracking for advertising purposes.

8. Data Security

We implement appropriate technical and organizational security measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include encrypted data transmission (HTTPS), secure database storage, access controls, and regular security assessment.

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

9. Your Rights and Choices

9.1 Access and Correction

You may access and update your account information through your account settings or by contacting us at legal@interoperformance.com.

9.2 Data Deletion

You may request deletion of your personal information by contacting legal@interoperformance.com. We will process deletion requests within 30 days, subject to legal retention requirements.

9.3 Data Portability

You may request a copy of your personal data in a machine-readable format by contacting legal@interoperformance.com.

9.4 Opt-Out of Communications

You may opt out of non-essential communications by using the unsubscribe link in our emails or by contacting us. Transactional emails (billing, account security) cannot be opted out of while your account is active.

9.5 Oregon Residents

If you are an Oregon resident, you may have additional rights under the Oregon Consumer Privacy Act (OCPA), including the right to know what personal data we collect, the right to correct inaccurate data, and the right to opt out of certain data uses. Contact legal@interoperformance.com to exercise these rights.

9.6 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA). Contact legal@interoperformance.com for more information.

10. Children’s Privacy

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a notice on the Platform at least 30 days before the changes take effect. Your continued use of the Platform after the effective date of the revised Policy constitutes your acceptance of the changes.

12. Contact

For questions, concerns, or requests regarding this Privacy Policy or your personal information:

Intero Performance, Inc.
Eugene, Oregon
legal@interoperformance.com