Important Notice: This website collects sensitive health data. Please read this policy carefully to understand how we collect, use, and protect your personal and health data.
Introduction
Welcome to F.T.W Sports and Wellness (the "Website", "F.T.W", "we", "us"). We are F.T.W Sports and Wellness, a company registered in the Arab Republic of Egypt, with registered address at Building 43, El Thalateen Street, First District, Hurghada, Red Sea Governorate. Our business activity is Sports Facilities Operation (Activity Code: 9311), Tax Registration Number: 778-194-698. We are fully committed to protecting your privacy and personal data in accordance with the Egyptian Personal Data Protection Law (PDPL) No. 151 of 2020 and its Executive Regulations.
1. Data Controller & Data Protection Officer
1.1 Data Controller
- Name: F.T.W Sports and Wellness
- Registered Address: Building 43, El Thalateen Street, First District, Hurghada, Red Sea Governorate, Egypt
- Business Activity: Sports Facilities Operation (Activity Code: 9311)
- Tax Registration Number: 778-194-698
- Governing Authority: Ministry of Youth and Sports
- Email: info@ftwsport.com
1.2 Data Protection Officer (DPO)
- Email: info@ftwsport.com
- Contact: Via the Website or email
2. Explicit and Prior Consent
Fundamental Principle: We do not collect or process any personal data, especially sensitive health data, without obtaining your explicit, prior, and informed consent.
2.1 Consent Mechanism
- Dedicated Consent Page: Upon registration and before using any feature requiring sensitive data, a clear consent page will appear explaining the data required and its purpose.
- Separate Consents: You can consent to some types of data and refuse others.
- Clear Language: We use simple, clear language without complex legal terms.
2.2 Withdrawing Consent
You can withdraw your consent at any time through:
- Privacy settings on the website (Profile → Privacy)
- Contacting the Data Protection Officer via email
- Requesting complete account deletion
Withdrawing consent does not affect the lawfulness of processing performed before withdrawal.
3. How We Use Your Data
3.1 Primary Purposes
- Creating personalized workouts based on your profile, goals, and recovery score
- Tracking your progress in workouts, nutrition, and measurements
- Calculating recovery score and providing nutrition recommendations
- Wearable device integration and personalized AI assistant responses
3.2 Secondary Purposes
- Improving the website through aggregated usage data analysis (de-identified)
- Technical support, notifications, and motivation
3.3 Purposes We Do NOT Use Your Data For
We commit to NOT:
- Sell your personal data to any third party
- Use your data for targeted advertising
- Share your health data with insurance companies or employers
- Use your data for research purposes without separate consent
4. Your Rights Under Egyptian Law
The Egyptian Personal Data Protection Law No. 151 of 2020 grants you the following rights:
| Right | Description | How to Exercise |
|---|---|---|
| Right to Know | Know whether your data is being processed and how | Read this policy or contact us |
| Right of Access | Obtain a copy of all your personal data | Profile → Privacy → Export My Data |
| Right to Rectification | Correct any inaccurate or incomplete data | Edit profile directly |
| Right to Erasure | Request deletion of your data (right to be forgotten) | Profile → Settings → Delete Account |
| Right to Withdraw Consent | Withdraw consent for processing specific data | Profile → Privacy → Manage Consents |
| Right to Restrict Processing & Object | Request temporary suspension or object to data processing | Contact the DPO |
| Right to Data Portability | Receive your data in machine-readable format | Profile → Privacy → Export My Data (JSON) |
| Right to Complain | File a complaint with the PDPC | Egyptian Personal Data Protection Center |
4.1 Response Times
- Access and rectification requests: Within 15 business days
- Deletion requests: Within 30 business days
- Consent withdrawal requests: Immediate (within 24 hours)
5. Data Security
5.1 Security Measures Implemented
- Encryption: All data encrypted in transit (TLS 1.3) and at rest (AES-256)
- Passwords: Encrypted with bcrypt algorithm, never stored in plain text
- Authentication: JWT system with short-lived refresh tokens
- Access Control: Strict Row Level Security (RLS) policies at database level
- Monitoring: Continuous monitoring for suspicious activity
- Backups: Encrypted daily backups
5.2 Data Breach Notification
Our Commitment: In the event of a personal data breach:
- We notify the PDPC within 72 hours
- We notify you personally within 3 business days if the breach poses a risk to your rights
- We take immediate action to contain the breach and minimize harm
6. Data We Collect and Retention Periods
We retain your personal data only for as long as necessary to provide you with the F.T.W Sports and Wellness services and to fulfill the purposes described in this Privacy Policy. Below is a detailed overview of the data we collect, why we collect it, and how long we keep it.
6.1 Account and Profile Data
| Data Type | Examples | Purpose | Retention Period |
|---|---|---|---|
| Registration Data | Email, password (encrypted), full name | Creating and managing your account | Account duration + 3 years |
| Sign in with Apple / Google | User ID, email, name | Facilitating registration and login | Account duration |
| Personal Data | Date of birth, gender, profile picture | Personalizing experience and recommendations | Account duration |
| Preferences | Fitness goals, workout and nutrition preferences | Customizing the service | Account duration |
6.2 Health and Fitness Data
Special Classification: This data is classified as "sensitive personal data" under the Egyptian PDPL and requires explicit, specific consent.
| Data Type | Examples | Purpose | Retention Period |
|---|---|---|---|
| Workout Data | Workout type, duration, sets, reps, weights, calories burned | Progress tracking and improving recommendations | Account duration + 1 year |
| Nutrition Data | Meal log, nutritional values (protein, carbs, fats, calories), hydration | Daily nutrition tracking | Account duration + 1 year |
| Recovery Data | Recovery score, sleep hours, stress level, mood | Determining body readiness for exercise | Account duration + 1 year |
| Body Measurements | Weight, height, BMI, body circumference, body fat percentage | Physical progress tracking | Account duration + 1 year |
6.3 Wearable Device & Health Connect Data
Important Note: When you connect your wearable device or health app (Apple Health / Google Health Connect), the app reads and syncs the following health data to our servers to provide the service:
| Data Type | Purpose | Retention Period |
|---|---|---|
| Steps | Daily activity tracking and achievement calculations | Account duration + 1 year |
| Calories Burned | Energy expenditure tracking and nutrition recommendations | Account duration + 1 year |
| Distance | Walking and running activity tracking displayed in the daily health dashboard | Account duration + 1 year |
| Sleep Data | Recovery score calculation and determining body readiness for exercise | Account duration + 1 year |
| Heart Rate | Monitoring workout intensity and calculating average and maximum heart rate during exercises | Account duration + 1 year |
| Resting Heart Rate | Key indicator for recovery score calculation and fitness level assessment | Account duration + 1 year |
| Heart Rate Variability (HRV) | Physical recovery assessment and determining appropriate workout intensity | Account duration + 1 year |
| Hydration | Daily water intake tracking | Account duration + 1 year |
This data is synced to our secure servers to enable recovery score calculation, track progress over time, and provide personalized workout recommendations. You can stop syncing at any time from the wearable device settings in the app.
6.4 Usage and Technical Data
| Data Type | Purpose | Retention Period |
|---|---|---|
| Device Information | Technical support and compatibility | 1 year |
| Crash Logs | Bug fixing and stability improvement | 90 days |
| Usage Analytics | Improving user experience (de-identified) | 1 year |
6.5 Account Deletion
When you request account deletion:
- Your account is deactivated immediately
- All personal and health data is permanently deleted within 30 days
- Some aggregated data (de-identified) may be retained for statistical analysis
- Transaction logs are retained for 5 years as required by law
You can request deletion of your data at any time by:
- Deleting your account in the app (Profile → Settings → Delete Account)
- Contacting us at info@ftwsport.com
7. Children's Privacy
Age Restriction: This website is not intended for persons under 16 years of age. If we learn that a child has provided personal data without parental consent, we will delete this data immediately.
8. Policy Updates
We may update this policy from time to time. We will notify you of any material changes via on-site notification or email. Your continued use of the website after an update means you accept the updated policy.
9. Governing Law and Dispute Resolution
- Governing Law: Egyptian Personal Data Protection Law No. 151 of 2020 and its Executive Regulations
- Governing Authority: Ministry of Youth and Sports
- Jurisdiction: Competent Egyptian courts in Hurghada
- Amicable Settlement: We encourage you to contact us first to resolve any dispute amicably
10. Egyptian Personal Data Protection Center
If you are not satisfied with how we handle your data, you have the right to file a complaint with:
Personal Data Protection Center
Ministry of Communications and Information Technology
Arab Republic of Egypt
Website: www.mcit.gov.eg
Ministry of Communications and Information Technology
Arab Republic of Egypt
Website: www.mcit.gov.eg