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Legal

PRIVACY AND PERSONAL DATA PROCESSING POLICY – VIRE

Version 2026-10-11 · Updated on October 14, 2026 · Effective from October 29, 2026

STAION S.A.S., NIT 901.973.951-2, domiciled at TV Superior Cr 25 A 1 A Sur 45, Medellín, Antioquia, Colombia, as the controller of the personal data of the VIRE platform, adopts this Policy in accordance with Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and other applicable regulations.

1. DATA CONTROLLER

STAION S.A.S., NIT 901.973.951-2
Address: TV Superior Cr 25 A 1 A Sur 45, Medellín, Antioquia, Colombia
Personal data and complaints: soporte@virecoach.com
Website: virecoach.com

2. PERSONAL DATA WE COLLECT

Professionals: name, email, phone, date of birth, profile photo, ID number and billing information, payment and subscription data, audiovisual content, programs and use of the Platform.

Profile in the professionals showcase: profession, city, tagline, biography, service mode (in person, remote or both), Instagram username if they choose to add it, and WhatsApp number.

Professional verification: the photo or PDF of their COCED professional card and the data we read from that card's public record on the COCED website: name, card number and type, status, degree, institution, graduation year and issue and update dates. We also keep the date on which the professional gave us their authorization. Today verification is only done with the COCED card.

Professionals who sell in the showcase: to receive payments for their plans, a photo of both sides of their ID card and its number, their RUT (tax registration) and their bank certificate. ID and account numbers are stored encrypted. In addition, a photo of the professional holding their ID card (selfie), which is biometric and sensitive data and is only requested with the explicit and separate authorization described in section 3.

Athletes: name, email, phone, date of birth, sex (optional: "prefer not to say" is an option; we use it to estimate body fat percentage and muscle mass), weight, height, body metrics, body fat percentage, progress photos, injuries and medical conditions they choose to declare, purchases of plans in the showcase and activity on the Platform.

Location: the city each user chooses from a worldwide catalog of cities (GeoNames), with its region, country and the approximate coordinates of that city. We do not use the phone's location.

Technical data: IP address, device type, browser, operating system, language and usage events. When a legal document is accepted, we keep its version, the date, and the IP address and browser from which it was accepted.

Unfinished registrations: if someone starts creating their account and does not complete the process, VIRE keeps the data already entered, from the moment they provide their email: the account type (athlete or sports professional), the email, the name if provided, the step where they stopped, the date and whether the registration started on the web or in the mobile app. The password, phone number and social media username are not kept.

3. SENSITIVE DATA

VIRE processes sensitive data in two cases, and in both it does so with the prior, express and informed authorization of the data subject, as required by article 6 of Law 1581 of 2012. The data subject is not required to authorize the processing of sensitive data.

Health data: sex, weight, height, body composition and other body metrics, body photos, injuries and medical conditions. The athlete decides whether to provide them; VIRE asks for their explicit authorization before storing them, and they separately authorize their professional to see them.

Biometric data: the selfie with the ID card of the professional who sells in the showcase, used only to confirm their identity before paying them. It is requested with a separate explicit authorization that the professional accepts before uploading it.

4. PURPOSES OF PROCESSING

  • Operate the Platform and manage accounts.
  • Manage subscriptions, charges and electronic invoicing.
  • Collect payment for the plans professionals sell in the showcase, confirm the professional's identity and pay them.
  • Enable physical follow-up and support the interaction between professional and athlete.
  • Show the professional's profile in the professionals showcase to connect athletes with professionals.
  • Verify the professional registration of those who use VIRE as professionals.
  • Check the minimum age to use the Platform and to make purchases.
  • Show each professional's city and help athletes find nearby professionals.
  • Improve features and prevent fraud.
  • Comply with legal, accounting and tax obligations, and send operational or commercial communications.
  • Perform statistical and usage analysis.
  • Remind by email anyone who started a registration and did not finish it that they can complete it. This data is not used for advertising or phone contact.

Some emails are part of the service and cannot be turned off: security and access emails (account verification and password recovery or change), billing emails (receipts, failed charges, plan renewal and expiry), support replies, and notices about requests and about the relationship between professional and athlete, including reminders of pending requests and of the end of the training plan.

The others can be turned off, including the new personal record email, which arrives at most once per training session, and "We miss you", which is sent to the athlete at 7 and 21 days without training, twice at most. Each of these emails includes an unsubscribe link, and they can also be turned off by topic from the account preferences.

5. LEGAL BASIS

Authorization of the data subject, performance of the contractual relationship, compliance with legal obligations and the legitimate interest in operating and securing the Platform.

To verify the professional, we ask for their prior, express and informed authorization in the same step in which they upload their card, as required by article 9 of Law 1581 of 2012; without that authorization the card cannot be uploaded. The COCED record we consult is publicly accessible.

For unfinished registrations, the legal basis is VIRE's legitimate interest and the pre-contractual relationship with the data subject: the emails sent are transactional and their only purpose is to complete the registration already started, so they do not depend on prior express authorization.

6. RETENTION PERIODS

  • Account, training and health data: while the account is active. When deletion is requested, the account is deactivated and can be reactivated for thirty (30) days; after that it is deleted, except for the following.
  • Accounting and billing records: ten (10) years, under commercial and tax regulations.
  • Documents the professional provides to receive payments (ID card and its number, RUT, bank certificate): ten (10) years after the account is closed, due to accounting obligations; then they are deleted.
  • Selfie with the ID card: while the account is active; it is deleted when the account is closed.
  • Card and verification data: while the professional has a VIRE account. They can also ask us to delete them earlier by writing to soporte@virecoach.com; until they upload a card again they will no longer appear as verified.
  • Unfinished registrations: ninety (90) days from the last attempt; each email includes a one-click link to stop receiving them, which also deletes the registration.
  • Encrypted backups: up to seven (7) days. Technical and security logs: up to thirty (30) days.

7. STORAGE AND SECURITY

Information is stored on cloud infrastructure services. VIRE implements reasonable technical, administrative and organizational security measures. No system is completely invulnerable.

Professional cards, documents for receiving payments and the selfie with the ID card are kept in private storage, without a public link, and only authorized VIRE staff can access them. The ID and bank account numbers of those who sell in the showcase are stored encrypted. None of these documents or numbers is shown or published on the Platform.

8. ACCESS TO INFORMATION

An athlete's data can only be viewed by the data subject, the corresponding professional and authorized VIRE staff when necessary. VIRE does not sell personal data to third parties.

The professional's profile in the professionals showcase is visible to Platform users who are signed in, so they can find them and request training. It shows their name, username, photo, profession, city, tagline, biography, service mode, Instagram username if they added it, whether they are a VIRE ambassador, number of active athletes, workouts supported, how long they have been on VIRE and whether they are verified. The professional controls this visibility and can hide their profile from the showcase at any time from their account.

Their WhatsApp number does not appear in the showcase. If they have this option on, when an athlete sends them a request a WhatsApp conversation with that number opens, and the athlete will be able to see it there. The professional can turn this option off from their account.

Professional's public page: if the professional turns it on and accepts its separate authorization, VIRE publishes on a page of their own their photo, name, verified badge, tagline, specialties, city, intro video and what they write about how they work and in their links. Anyone with the link can see it, and it can appear in search engines such as Google and in the preview when shared. The professional can turn it off at any time. About visitors, VIRE only counts how many visits it gets each day, without storing data about who viewed it.

The card and verification data are not shown to other users: the showcase only shows whether the professional is verified.

9. DATA PROCESSORS

Some providers process personal data on VIRE's behalf, as processors under article 3 of Law 1581 of 2012, only to provide their service to us and under their own policies:

  • Google Cloud (United States): servers, database and file storage.
  • Google Maps Platform: search for the professional's locations.
  • Vercel: hosting of the web app, through which the Platform's traffic passes.
  • Mercado Pago: charging plans and tokenizing cards.
  • SIIGO: electronic invoicing.
  • OpenAI (United States): the VireCoach assistant and automatic replies on WhatsApp.
  • Meta (WhatsApp): WhatsApp messages to those who have authorized them.
  • Our email provider: sending the service's emails.
  • Expo: phone notifications.

10. INTERNATIONAL TRANSFERS

Part of the information is stored and processed outside Colombia, mainly in the United States, on the servers of Google Cloud and the other processors in section 9. VIRE makes these transmissions as controller, with processors that undertake to protect the data, and in accordance with article 26 of Law 1581 of 2012. By accepting this Policy, the data subject authorizes those transmissions to the extent necessary to provide the service.

11. PAYMENTS AND FINANCIAL DATA

Payments are processed through external providers. VIRE does not directly store full card information. Tokenization is handled by authorized providers.

12. DATA SUBJECT RIGHTS AND HOW TO EXERCISE THEM

The data subject can know, update and correct their data; request proof of the authorization they gave us; be informed about how we use it; revoke the authorization or request the deletion of their data when there is no legal duty to keep it; access it free of charge; and file complaints with the Superintendence of Industry and Commerce.

  • Inquiries: answered within ten (10) business days of receipt at most. If that is not possible, we will explain why and give a new date, no more than five (5) additional business days.
  • Claims (correction, update, deletion or breach): answered within fifteen (15) business days from the day after receipt at most. If that is not possible, we will explain why and give a new date, no more than eight (8) additional business days.
  • Channel: soporte@virecoach.com, from the registered email or stating the name, ID and request.
  • Superintendence of Industry and Commerce: the data subject can file a complaint with the SIC once they have completed the inquiry or claim process with VIRE.

13. MINORS

VIRE does not allow professionals under 18. Athletes must be at least fourteen (14) years old, and those under 18 use the Platform with the authorization of their parents or legal representative, who authorizes the processing of their data. VIRE processes minors' data respecting their best interests and fundamental rights, and only users over 18 can make purchases on the Platform.

14. USE OF CONTENT FOR MARKETING

VIRE may use testimonials, trade names, logos, screenshots and public content of professionals for promotional purposes. It will not use body photos or sensitive data of athletes without additional express consent.

15. COOKIES

Essential: those needed for the site and the Platform to work: the signed-in session in the application, the chosen language and the decision about analytics cookies. They cannot be turned off without the service stopping working.

Analytics: Google Analytics, only if the visitor accepts it in the site's cookie notice. Before accepting, no analytics tool is loaded, and anyone who rejects it will not see the notice again.

Visitors choose in the cookie notice shown the first time they visit virecoach.com, and can change their decision by clearing the site's data in their browser.

16. CHANGES TO THIS POLICY

VIRE may update this Policy. Each version is published with its date. VIRE gives notice of each substantial change by email and on the Platform at least fifteen (15) calendar days before it takes effect and, when it changes in a way that requires authorization, the Platform asks the data subject to read it and accept it again.

17. EFFECTIVE DATE

This Policy is effective from October 29, 2026 (version 2026-10-11). Databases will be kept for as long as needed for the purposes described and for the periods in section 6.

18. CONTACT

STAION S.A.S., NIT 901.973.951-2
Address: TV Superior Cr 25 A 1 A Sur 45, Medellín, Antioquia, Colombia
Personal data and complaints: soporte@virecoach.com
Website: virecoach.com

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