App Privacy Policy
This policy explains how personal data is handled in the ATS mobile application and the service behind it. It is written to satisfy Articles 13 and 14 of the EU General Data Protection Regulation (GDPR) and the Croatian Act on the Implementation of the GDPR. For this website, see the website Privacy Policy.
1. Who is responsible
The ATS application is operated by Athlete Thermography Screening j.d.o.o., Radnička cesta 50, 10000 Zagreb, Croatia (OIB 36520028470), hereinafter "ATS". For any data-protection matter contact vlaho@athletethermographyscreening.hr. We have not appointed a Data Protection Officer because we are not required to under Article 37 GDPR.
Athlete data. Data about the athletes you scan is processed on behalf of the club, organisation or institution that subscribes to ATS. That subscriber is the controller and ATS is the processor under Article 28 GDPR, on the terms of the data processing agreement between them. Where you use ATS under an individual plan rather than through a club, you are the controller for the athletes you scan.
Your account. For the data about you as an app user (your account, sign-in, support conversations and diagnostics), ATS is the controller.
Camera distributors. A distributor that supplies a thermal camera does not receive athletes' or users' personal data because it delivers the camera, and it is not a recipient of that data. If a distributor ever needs access to personal data, for example to help a club with the service, it gets access only under a written agreement that sets out its role, the legal basis and its data protection obligations, and we will name it in this policy. Who owns the camera does not change who is the controller or the processor.
2. What we process and why
Account and sign-in. Your email address, your name, the club you belong to, and when you signed in. You sign in with a one-time code sent by email; a code expires after 10 minutes and a session after 30 days without use. Legal basis: Article 6(1)(b) GDPR (performance of the contract).
Athlete profiles. Name, team, jersey number, position, category, date of birth, height, weight, dominant side, sport, and an optional profile photo, as entered by the club.
Scans. Thermal images and visible-light photos of the athlete's body taken during a scan; the regional skin temperatures, left-against-right asymmetry and training guidance derived from them; and the training and wellness context entered with a scan (training load, how the athlete feels, sleep quality, notes), which can be filled in or corrected after the scan. Reports and exports are generated on request; we keep a generated copy so that it opens quickly the next time, and delete it after 30 days without use. Thermal images can reveal information about an athlete's health and may be special-category data under Article 9 GDPR. The club, as controller, is responsible for a valid legal basis, including explicit consent where required, and for informing its athletes. For athletes who are minors, this includes the consent of a parent or guardian where the law requires it.
Support assistant. Kelvin is an AI assistant. Where it is available to your club, the messages you write are sent to OpenAI to generate an answer, together with a limited context: your first name, your club and plan, the app version and language, and your most recent steps in the app, with email addresses and sign-in codes removed. It does not receive your athletes or their scans. OpenAI is instructed not to store the conversation; we keep the conversation history to provide support. Please do not type athlete health details into the chat. If you report one of its answers, the answer and the conversation are sent to our team to review. Legal basis: Article 6(1)(b) GDPR.
Problem reports. When you report a problem (through the assistant, or with shake to report where it is switched on), we receive your description, your email address, your club, the app version, the device model and the operating system, and, if you choose to include them, a screenshot of the screen and your most recent steps in the app. We use them only to find and fix the problem. Legal basis: Article 6(1)(f) GDPR.
Diagnostics. When the app hits an error it sends us the error message, where it happened, the app version, the device model and the operating system, with email addresses, sign-in codes, access tokens and search terms removed. We use this only to find and fix faults. Legal basis: Article 6(1)(f) GDPR (our legitimate interest in a working and secure service).
Email. We send sign-in codes, a welcome message when you are added to a club, and service notices. If an email address without access to ATS asks for a sign-in code, we send it one message about how to get ATS instead of a code.
On your device. To work where the signal is poor, the app keeps some data on the phone or tablet. A scan that has not been uploaded yet (its images, the athlete it belongs to and its training context) stays in the app's storage until it is uploaded, and is then deleted; it also stays after you sign out, so that it is not lost, and can be deleted under Settings > Pending uploads. The last athlete list and scan list you opened, and the thermal images you viewed, are kept so that they can be shown offline; they are deleted when you sign out. Your sign-in session is kept in the device's secure storage (Keychain or Keystore). A report or file you share is written to the app's temporary storage first.
Device permissions. The camera is used to capture thermal scans through the FLIR camera and to take profile photos. Bluetooth, local network and location access are used only to find and connect to the FLIR camera; we do not collect or store your location. Photo library access is used only to choose a profile photo.
The app contains no advertising, analytics or tracking SDKs, and we do not sell personal data.
3. Anonymised data for research
ATS may use anonymised and aggregated data for scientific and sports research, algorithm development, statistical analysis, and the publication of professional and academic papers. Anonymisation means processing the data irreversibly, so that no athlete can be identified directly or indirectly, including by combining it with other data. We never publish personal data or the identity of an athlete. Data that is only pseudonymised remains personal data and stays under this policy.
To develop our measurement algorithms, we keep an anonymised copy of every image taken with the app: the thermal image, the camera image with the head and face pixelated and its embedded metadata removed, the outline of the body regions, and technical labels (the view, image quality, region temperatures, the sport and the training context chosen in the app). The copy carries no name, club, account, date or free text and is not linked to any athlete, scan or account. It is kept separately from the app's data, only ATS administrators can access it, and it is kept when scans, athletes, accounts or clubs are deleted.
4. Where the data is kept and how it is protected
All application data is stored with Amazon Web Services in the European Union (region eu-central-1, Frankfurt). Data is encrypted in transit (TLS 1.2 or higher) and at rest (AES-256). Access is role-based: club staff see only their own club's data, and ATS staff access data only as far as needed to operate the service, provide support or follow the club's instructions. Everyone with access is bound by confidentiality. Sharing accounts, sign-in codes or passwords is not allowed.
5. Sub-processors
We use the following providers to run the service:
- Amazon Web Services: hosting, database and file storage (EU, Frankfurt).
- Resend: sending sign-in codes and service email.
- OpenAI: answers in the support assistant, where it is available.
Clubs are told in advance of any new or replaced sub-processor, as set out in their data processing agreement.
6. International transfers
Resend and OpenAI are based in the United States. Transfers to them rely on the EU-US Data Privacy Framework where the provider is certified under it, or on Standard Contractual Clauses (SCCs) adopted under Article 46(2)(c) GDPR. Athlete profiles and scans are not sent to either of them.
7. Retention
Athlete data is kept for as long as the club's contract with ATS runs. When it ends, the data is returned, deleted or anonymised, at the club's choice, unless the law requires us to keep it; on request we confirm the deletion in writing. Your account data and support conversations are kept while your account exists. Problem reports and diagnostics are kept as long as we need them to fix the problem. Generated report copies are deleted after 30 days without use. Sign-in codes stop working after 10 minutes. Database backups are overwritten within days. The anonymised copies described in section 3 are not personal data and are kept.
8. Personal data breaches
If a personal data breach occurs, we notify the affected club without undue delay and, where reasonably possible, within 48 hours of becoming aware of it, with what we know about its nature, the data and people affected, the likely consequences and the measures taken. Where ATS is the controller, we notify the supervisory authority and the people affected as the GDPR requires.
9. Your rights
Under the GDPR you have the right to: access your data (Article 15); rectify inaccurate data (Article 16); request erasure (Article 17); restrict processing (Article 18); receive a portable copy (Article 20); object to processing based on legitimate interest (Article 21); and withdraw consent at any time where processing is based on consent (Article 7(3)).
Athletes should send requests about their data to their club, which is the controller; we help the club answer them. App users can delete their account in the app under Settings > Delete Account, or ask by email as described on Delete your ATS account. Deleted in the app, the account is closed at once and everything stored with it is permanently removed after 30 days; asked by email, we delete it within 30 days of the request. Deleting an account does not delete the club's athletes or scans, which belong to the club.
You also have the right to lodge a complaint with the Croatian supervisory authority, Agencija za zaštitu osobnih podataka (AZOP), azop.hr.
10. Automated processing and medical use
The app analyses thermal images automatically and flags regions for the club's staff to review. It makes no decision about an athlete that has legal or similarly significant effects: people decide. ATS is a sports-performance and wellness tool. It is not a medical device and does not replace medical diagnosis.
11. Changes to this policy
We may update this policy when our processing changes or when the law requires it. Material changes will be announced on this page.